ML20245K305
| ML20245K305 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/28/1989 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-88-149, NLS-89-123, NUDOCS 8905050019 | |
| Download: ML20245K305 (3) | |
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Carolina Power & Light Company l-APR 2 81989 SERIAL: NLS-89-123 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 SUPPLEMENTAL REPLY TO A NOTICE OF VIOLATION (EA 88-149)
FINAL IMPLEMENTATION SCHEDULE - SYSTEM ENGINEERING PROGRAM Gentlemen:
The NRC issued a notice of violation and proposed imposition of civil penalty for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2 on i
December 30, 1988.
Carolina Power & Light Company (CP&L) acknowledged the violation in its response on January 27, 1989 (NLS-89-021).
In that response, CP&L committed to provide a final implementation schedule for the system engineering program at BSEP.
Enclosed is a description of the activities to be implemented in order to effectively establish the BSEP system engineering program.
Final program implementation is expected by March 30, 1990.
Please refer any questions regarding this subtaittal to Mr. Stephen D.
Floyd at (919) 546-6901.
Yours very truly, 2d &
R. A. Watson Senior Vice Presidant Nuclear Generation BAB/bab
(\\cor\\syseng)
Enclosure ec:
Mr. S. D. Ebneter Mr. W. H. Ruland Mr. E. G. Tourigny 0905050019 890428
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ENCLOSURE Problems within the system engineering group have been recognized by site and senior management.
This is well documented in the Corporate Management Oversite Team (CMOT) report.
A new position description was developed and approved to clearly define the role, functions, and responsibilities of the CP&L system engineers. The experience, training, qualifications, and performance prerequisites were established for promotion to this new position by a corporate task force representing CP&L's nuclear sites. A BSEP task force was formed in 1988 to study and define the role of system engineers. Manpower analysis and site engineering consolidation studies were conducted for system engineering at BSEP.
From this large amount of system engineering research, several changes have begun toward the goal of increased effectiveness:
1.
An internal res11gnment of technical support supervisor responsibilities has been conducted.
Instead of system engineers reporting to one second line supervisor, they are aligned among the three supervisors. This realignment has also added four first line supervisors responsible for system engineering functions.
Site management has provided additional personnel to the system engineering area by reassignment of construction / design engineers to the technical support organization, and by addition of engineering positions. The dependence on contract engineers has almost been eliminated.
2.
A consolidation of the site engineering functions (technical support and maintenance groups) is in progress. The maintenance engineering group now reports to the Manager - Technical Support.
3.
Action plans are being developed to redistribute work activities to facilitate implementation of the system engineering concept.
j This will include the transfer of certain technical support activities to the Nuclear Engineering Department. A plan for increased training, facilities improvement, and engineer retention is being developed. A plant procedure, "The System Engineering Program," is being developed to define the function, accountabilities, structure, goals and objectives, training / development, and various other aspects of the system engineering organization.
There is management sensitivity to the needs of the Technical Support Unit at BSEP, with solid steps being taken to improve the overall health of the organization.
The changes made to date have lowered the overtime hours of many individuals aud created a vehicle for improved engineering effectiveness.
Issues such as the RHR valve erosion problem, the HPCI valve MAC problem, and the standby gas treatment problem are only a few of the recent issues where system engineering has exhibited detailed and thorough engineering investigation and root cause determination.
l The following is a list of the remaining items necessary for completion of the implementation of the BSEP system engineering program. As the program is implemented, adjustments in scope and focus for these activities is expected.
Final program implementation, including completion of these items, is expected by March 20, 1990.
1.
Issuance of the plant procedure, "The System Engineer Program."
2.
Revision of the job descriptions for Associate Engineer, Engineer, and Senior Engineer in the system engineering area.
3.
Generic basic work functions and performance measures to be established by a team of system engineering supervisors.
q 4.
First-line supervisors are to develop a plan for each subordinate which includes basic work fun:tions, performance measures, and a training schedule.
This plan will integrate self-study and classroom training.
Its goal will be to bring system engineers to an appropriate level of know7 edge of plant systems, accident analyses, and plant technicat specifications.
Additionally, instructions on engineering methods and technology will be provided, as applicable.
5.
For modifications implemented after the 1989 Unit 2 outage, system performance tests will be written and directed by systems engineers.
Code required tests (e.g., hydro-tests), construction tests (e.g., cable meggering), and component functional tests l
(e.g., valve stroke tests) will be performed by the modification implementation group.
6.
A documented program for monitoring and trending performance parameters of selected systems will be implemented.
7.
A program will be implemented for periodic comprehensive assessments of the condition of selected systems. This assessment will consider actual conditions versus design, performance trends, maintenance histories, and requested modifications.
The assessment will include recommendations for improvements and a prioritization of needed changes.
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