BSEP-93-0081, Responds to Violations Noted in Insp Repts 50-324/93-20 & 50-325/93-20 on 930413-21.Corrective Actions:Ned Training Program Will Be Revised to Include Procedure Compliance Training for New Ned Personnel by 930709
| ML20045D385 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/21/1993 |
| From: | Hinnant C CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BSEP-93-0081, BSEP-93-81, NUDOCS 9306280313 | |
| Download: ML20045D385 (3) | |
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Carolina Power & Light Company Brunswick Steam Electric Plant -
.s P.O. Box 10429 Southport, North Carolina 28461 June 21,1993 SERIAL: BSEP-93-0081 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 REPLY TO NOTICE OF VIOLATION Gentlemen:
On May 20,1993, the Nuclear Regulatory Commiss;on issued a Notice of Violation for the Brunswick Steam Electric Plant, Unit 2. Details of'the underlying NRC inspections are provided in Inspection Report Nos. 50-325/93-20 and 50-324/93-20 dated May 20,1993. Carolina Power &
Light Company hereby responds to the Notice of Violation. Enclosure.1 to this letter provides CP&L's reply to the Notice of Violation in accordance with the provisions of 10 CFR 2.201.
Please refer any questions regarding this submittal to Mr. R.~ C. Godley at (919) 457-2412.
Yours very truly, CS/
a C. S. Hinnant, Director Site Operations Brunswick Nuclear Plant GMT/gmt Enclosures cc:
Mr. S. D. Ebneter Mr. P. D. Milano Mr. R. L Prevatte I
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O ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 and 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62 REPLY TO NOTICE OF VIOLATION VIOLATION :
During an NRC inspection conducted on April 13-21, 1993, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," the violation is listed below:
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions or procedures of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions or procedures.
Contrary to the above, as of April 21,1993, NRC identified that Short Term Structural Integrity (STSI) cumulative effects walkdowns performed to evaluate STSI items in the Unit 2 drywell under 10 CFR 50.59 criteria were accomplished without the use of documented instructions or procedures.
This is a Severity Level IV violation (Supplement I).
RESPONSE TO VIOLATION:
Admission of Violatian Carolina Power & Light admits this violation.
Reason for Violation l
Engineering activities were being performed to support a cumulative effects safety evaluation for Short l
Term Structural Integrity (STSI) items as requested by an NRC SER dated October 8,1992. Three l
engineers developed a process to perform the cumulative effects evaluation which included a sample review of the Unit 2 Drywell. On February 22,1993, these engineers performed a walkdown of the Unit 2 Drywell to validate the process. On February 26,1993, the engineer / supervisor developed a draft revision of DG 111.16 Attachment F, based upon the results of the February 22 walkdown. He reviewed this information with the other two involved engineers and obtained written acknowledgment that the field reviews performed were consistent with the draft guideline. Credit was then taken for the draft guideline as the controlling procedure for the Drywell portion of the cumulative effects walkdown. Thus the walkdown was performed without an approved procedure.
The violation occurred because management expectations for procedural compliance were not clearly communicated to NED personnel, in addition, training on previous procedural discrepancies was limited to the work groups involved and did not make provisions for personnel transferred from other NED sections or newly hired NED personnel. The engineers involved in this event had not been formally trained on the previous procedural discrepancies or the prohibited use of draft design guides. Two of the engineers were newly hired and the supervisor was on loan from another NED section.
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Corrective Actions Which Have Been Taken and Results Achieved The revision adding Attachment F to NED Design Guide Ill.16 was approved on March 18,1993,and sbbsequent walkdowns were performed in accordance with DG 111.16.
Walkdown information obtained prior to the approval of DG 111.16 Attachment F was reviewed to confirm compliance with the approved document. The results of this review reflect that prelirninary and subsequent walkdowns were performed to the criteria documented in the approved version of in DG ll1.16 Attachment F.
CP&L is committed to preparing and implementing documented approved procedures for performance of safety related work activities. NED management provided training for NED Brunswick section personnel (including NED supervised contractors). This training emphasized familiarization with procedures, and the expectations of a procedural compliance ethic. This training has been completed for personnel performing safety related work activities.
Corrective Steos Which Wili Be Taken to Avoid Further Violations NED Training Program (NED 2.2) is being revised to include procedure compliance training for new NED personnel. This will be completed by July 9,1993.
Procedural compliance training will be performed for the remaining NED sections (Robinson and Harris nuclear plants).
An internal assessment will be performed to ensure the effectiveness of corrective actions.
Date When Full Comoliance Will Be Achieved 1
Carolina Power & Light is in full compliance.
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