IR 05000235/1987019
| ML14174A975 | |
| Person / Time | |
|---|---|
| Site: | Harris, Brunswick, Robinson, 05000000, 05000235 |
| Issue date: | 01/29/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML14174A976 | List: |
| References | |
| NUDOCS 8802080111 | |
| Download: ML14174A975 (7) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDE)
ACCESSION NIRSSO2080111 DOC. DATE:
88/01/29 NOTARIZED:
NO DOCKEI FACIL:50-000 Generic Docket 0500C000 50-261 H.B. Robinson Plant, Unit 2, Carolina Power & Light C 05002r1 50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 0500040'
50-324 Brunswick Steam Electric Plant Unit 2, Carolina Powe 050C)2 4 50-325 Brunswick Steam Electric Plant, Unit 1, Carolina Powe 0500032'
AUTH.NAME AUTHOR AFFILIATION GRACE Region 2, Ofc of the Director RECIP.NAME RECIPIENT AFFILIATION UTLEY> Carolina Power & Light C SUBJECT: Provides evaluation of util 871113 comments on SALP Repts 50-261/87-22,50-400/87-24,50-324/87-19 & 50-325/87-1 Errata to SALP Repts 50-324/97-19 & 50-235/87-19 enc DISTRIBUTION CODE:
IE40D COPIES RECEIVED:LTR 4ENCL (
SIZE:P TITLE:
Systematic Assessment of Licensee Performance (SALP)
Report NOTES:Application for permit renewal file RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA
0 PD2-1 PD i
ECCLESTON, V,
1 BUCKLEYB
1 SYLVESTERE
1 INTERNAL:
AEOD BAILEY,B
0 AEOD/DOA
1 AEOD/DSP/TPAB
1 COMMISSION
5 DEDRO
1 NRR MORISSEAUD
1 NRR/DEST/SIB
1 NRR/DLPG/HFB
1 NRR/DLPG/PEB
1 NRR/DOEA/EAB
1 NRR/DREP/EPB
1 NRR/DREP/RPB
i NRR/DRIS DIR
1 NRR/PMAS/ILRB
1 OE LIQR MANJ
1 OGC/HDS1
1 RE FIL
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RGN2 FILE
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EXTERNAL: H ST LOBBY WARD
1 LPDR
3 NRC PDR
1 NSIC
1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 33 ENCL
JAN 2 I Docket Nos. 50-325, 50-324, 50-400, 50-261, License Nos. DPR-71, DPR-62, NPF-63, DPR-23, Carolina Power and Light Company ATTN:
Mr. E. E. Utley Senior Executive Vice President Power Supply and Engineering and Construction P. 0. Box 1551 Raleigh, NC 27602 Gentlemen:
SUBJECT:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT NO /87-19, 50-324/87-19, 50-400/87-24 AND 50-261/87-22 This refers to the NRC Systematic Assessment of Licensee Performance (SALP)
Board reports for your Brunswick, Shearon Harris, and H. B. Robinson facili tie The report for Brunswick and Shearon Harris was sent to you on September 23, 1987 and the H. B. Robinson report was sent on October 6, 198 We conducted our site SALP presentations, respectively, on September 30, October 1 and October 13, 198 You provided comments by letter dated November 13, 198 We appreciate the effort you have expended in reviewing these reports and have reviewed your comments very closel After my staff had conducted a thorough review of your response, the SALP Board was reconvened on December 29, 1987, to address your comments and requests for reassessment. The Regional Adminis trator's office participated in this review of your comment Although all your functional area comments were reviewed and considered by the Board, only those where you specifically requested a SALP change are addressed in this lette Although some of your general comments may not affect our deliberation over this specific SALP period, they do provide information that can be factored into the next SALP perio We welcome your comments not only to individual functional areas, but also to the SALP process as wel We do recognize that you are striving to improve your safety performanc The following is our evaluation of your specific plant-related comments:
H. B. Robinson:
With respect to your comments on the Radiological Controls functional area since our position relates to both the Robinson and Brunswick sites, our discussion of this area is included under the Brunswick facilit PDR ADOCK o5000261 tps leter.Altoug soe o
yor gnerl ommntsmaynotaffct ur elieraio
Carolina Power and Light Company
JAN 2 9 1988 In the area of Fire Protection, we have evaluated your comments with respect to separating the fire protection program and its implementation from the 10 CFR 50, Appendix R problems. We continue to believe that the results of the Safety System Functional Inspection (SSFI)
indicated significant weaknesses related to the demonstrated ability of the operating staff to shutdown the reactor in the event that the control room had to be evacuated due to a fir Inspections of these type activities cross many functional area Accord ingly, it is appropriate to indicate these deficiencies in relevant areas such as Operations, Training, Engineering and Fire Protectio After review of the information you presented, the BoardEstill views this functional area as a Category 2 for the evaluated perio In the area of Engineering Support, we acknowledge that our evaluation was based on two team inspections during the latter part of the SALP evaluation period, namely the SSFI and Equipment Qualification (EQ)
inspection We further acknowledge that, as you state in your comments, some of our concerns relate to original design or modifications performed prior to this SALP perio We also acknowledge that there may have been strengths in engineering support (although not specifically inspected or evaluated by the Board), maintenance procedures, construction of both the Independent Spent Fuel Storage Installa tion and the new Radiological Control Building, outage planning, chewfftry control and NUREG-0737 requirement Nevertheless, the two team inspections revealed significant deficiencies in the quality of engineering support for the Robinson facilit We note that the majority of deficiencies were identified by NRC inspections and not by CP& Specifically addressed in the details of the inspection reports, in the SALP report, and conveyed to you at the SALP presentation on October 13, 1987, were the following deficiencies:
o Lack of measures for controlling calculations which form the operating basis for the plan o Absence of analysis to validate the design basis for the plan o Electrical calculations did not address actual field conditions or valida tion of electrical system desig o Deficiencies (identified by you) of the interrupting capability of circuit breakers used in the 480 volt emergency power source were not promptly correcte o Inadequate engineering evaluations of load sizing of safety-related batterie o Inadequate engineering reviews of compliance with 10 CFR 50.49 (EQ) led to NRC identified deficiencies in cable connector, valve operator and seal cable entrance qualification As we stated in our transmittal of the Robinson SALP on October 6, 1987, we believe that there was a significant lack of quality in the engineering support afforded to the Robinson site. We agree that progress has been made by CP&L to upgrade engineering support for the Robinson site and we will evaluate the quality of this support during the next evaluation perio Carolina Power and Light Company
JAN 2 9 988 In view of the above, the Board believes a Category 3 rating in this functional area is warrante Brunswick:
First, let me address your general concerns over the comparison between this Brunswick SALP and the previous repor As I'm sure you are aware, a
Category 1 is given for excellent performance, not just better than average, and also a Category 3 is given in areas that demonstrate more than just incidental lapses in performance. As such, there is a wide range of Category 2 rating ranging between borderline 1 to borderline In the previous SALP report, the term "improving" was defined as "Licensee performance has generally improved over the course of the SALP assessment period"; whereas in the current report, the definition in the SALP process for "improving" is "Licensee perfor mance was determined to be improving near the close of the assessment period."
With the current SALP definition, an "improving" trend listing is uncommon, as the Board is basically saying that it expects not just an improved performance, but an improved SALP category, assuming continued good performanc With this change in the definition, it is clear that a SALP change from a "2-Improving" to a "2" is not necessarily a decrease in performance. Overall, we do consi-der that Brunswick has improved its safety performance from the previous SALP to the current one. Additionally, it is important to point out that we consider a Category 2 as a satisfactory ratin In the Surveillance functional area, our review reveals little difference between your response and our SALP Board finding We concur that your surveillance performance history is excellen We consider leak rate testing to be very important; and, in this area, we also concur in your improved performances. While we concur that the referenced violation does not directly affect leak rate testing performance, this functional area covers more than just surveillance performanc As such, this violation will remain in the Surveillance functional are However, based on our reevaluation, we believe that the Surveillance functional area should be upgraded to a Category 1 SALP rating. The enclosure to this letter contains the appropriate errata sheets to the SALP repor The information that you have provided for the Outages functional area was, statistically, very impressiv We concur that your outages have become more efficient and, from this perspective, also concur that outage management has improved. Although we recognize the massive work effort that has been expended in this area, safety performance is the controlling basis for our evaluatio In this light, the enforcement history does not reflect the outstanding performance necessary to receive a Category 1; thus the Board has decided not to change the category rating in this functional are With respect to your comments on the Radiological Controls area for Robinson and Brunswick, you stated that a great amount of time, effort, and resources has been expended to effect program changes and to make numerous exposure-saving modifications at the facilities which have helped reduce exposure totals at the plant As we stated in our letters transmitting both the Brunswick and the Robinson SALPs, we concur that your annual exposure is improvin While we consider this a positive trend, and recognize your efforts, the relative ALARA
Carolina Power and Light Company
JAN 2 9 1988 standing of these two plants reveals that even more effort is needed before these plants can be recognized as exhibiting truly outstanding ALARA perform ance We considered the actions you have taken to make modifications to the plant that will result in long-term cumulative exposure savings. However it is our position that the effectiveness of these modifications and actions has yet to be demonstrate The NRC will continue to review your exposure reduction activities during the current SALP period and will assess the success of your program at the end of the SALP perio Your response also stated that you believe the SALP Board placed too much emphasis on the station's cumulative dose rather than an overall assessment of the radiological protection progra We did assess the overall adequacy of each CP&L plant's radiation protection program. However, the NRC does consider cumulative radiation exposure to be one of the principal measures of success of the program. It is indicative of effective radiological controls as well as management's commitment to keeping radiation exposures as low as reasonably achievabl CP&L also expressed concern that the NRC gives no recognition to CP&L's excellent performance in the area of reducing individual exposur Although the average radiation dose per worker at CP&L plants is less than the national average, it is difficult to assess the significance of these number Average exposure per worker could effectively be reduced by distributing the total plant exposure over a larger number of individuals, many of whom received little or no exposur It is the NRC's position that cumulative radiation exposure is a better measure of a plant's commitment to keeping radiation exposure as low as reasonably achievable, particularly because of the likely stochastic nature of the effects of low level radiatio The preceding comments specifically address your discussion of radiation exposure at Brunswick and Robinson. Although we believe that the continued relatively high cumulative exposures for the two plants is our main concern in the area of Radiological Control, it is not our only SALP category rating measurement, as your response implie After reviewing our analyses of the total Radiological Controls functional area and your ALARA comments, the Board believes that the Category 2 ratings for Brunswick and Robinson are appropriat Your licensing comments note that a need-date for NRC actions is usually identified in licensing submittals, and that, recently, CP&L has provided a comprehensive listing/prioritization of significant licensing issues pendin We recognized that for most significant licensing actions, a need-date is identified by the licensee. However, the SALP Board evaluation was directed to the way the need-dates are characterized in the licensee submittals and the impact of the proposed schedules on licensee and NRC staff resource In some cases, a need-date was identified that related more to plant convenience than actual need to support plant operatio However, based on the number of untimely applications submitted by CP&L, it is not apparent that your licensing management is aggressive in working with plant personnel to identify licensing needs to the NRC with sufficient lead time for NRC revie Consequently, expedited NRC review was sometimes requested on a schedule to meet a conveni ence date for the plan We recognized that, in some instances, a licensing
Carolina Power and Light Company
JAN 2 9 088 action that must be processed on an expedited schedule is identified by on-site personne However, the number of such items that have been submitted by CP&L is judged to be excessiv You provide arguments to show that previous licensing action submittals have compared well with other licensee submittals throughout the industr You state that Brunswick submittals have required less time than the average for NRC review, and have required fewer supplemental submittal With regard to the number of supplemental submittals required, the conclusion reached by CP&L is misleading. The low number of supplemental submittals is explained more by the early guidance provided by the NRR technical staff and Project Manager in conference calls and meetings than to the initial effort expended by CP& Based on this review, the Board has concluded that the Category 2 rating is correct for this functional are Harris:
Your response to the Preoperational and Startup Testing provided information on the speed and efficiency of the Harris Preop/Startup progra We concur that the activities conducted under this functional area were performed with only minimal problems, after fuel load. However, the delay from low power licensing (October 1986)
to initial criticality (January 1987) reflects lack of out standing performance in planning. This is further compounded by the number of tests that were deferred from the initial approved progra Accordingly, performance was not considered to be outstanding. As such, the Board continues to believe that a Category 2 rating is appropriat In conclusion, while we agree with your comments in the various functional areas, we do not believe them to be of such substance to effect a change in our ratings except as noted abov Looking forward to the next SALP evaluations, the Harris site will be evaluated for the period July 1, 1987 through June 30, 1988. This SALP period is due to our policy to review newly licensed plants over a one-year period after beginning power operation The Brunswick and Robinson SALP periods will be determined at a later dat No reply to this letter is required; however, should you have any questions concerning these matters, I will be pleased to discuss them with yo Also enclosed are copies of the slides the staff used at the SALP presenta tion
Sincerely, J. Nelson Grace Regional Administrator Enclosures:
(See page 6)
Carolina Power and Light Company
JAN 2 9 1988 Enclosures:
1. Errata Sheets Brunswick SALP Report 2. SALP Presentation Slides for Brunswick, Shearon Harris, and Robinson cc w/encls:
M. A. McDuffie, Senior Vice President Nuclear Generation Group P. W. Howe, Vice President Brunswick Nuclear Project C. R. Dietz, Plant General Manager G. P. Beatty, Jr., Vice President Robinson Nuclear Project Department R. E. Morgan, Plant General Manager R. A. Watson, Vice President Harris Nuclear Project 0. L. Tibbitts, Director of Regulatory Compliance J. L. Willis, Plant General Manager bcc w/encls:
NRC Resident Inspector, Harris NRC Resident Inspector, Brunswick NRC Resident Inspector, Robinson DRS Technical Assistant C. Barth, OGC A. Upchurch, Chairman, Triangle J Council of Governments Document Control Desk State of North Carolina State of South Carolina RII RII R 'I RII s1PFreitickson:er DVerrelli WH h1 yes 01/J /88 01/;S/88 01/v7 /88
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RIl RI RH Abon Js MErnst 01 /3/88 01/,,'88 01/ /88