IR 05000261/1980031
| ML14175B248 | |
| Person / Time | |
|---|---|
| Site: | Harris, Brunswick, Robinson  |
| Issue date: | 02/02/1981 |
| From: | Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B247 | List: |
| References | |
| 50-261-80-31, 50-324-80-40, 50-325-80-43, 50-400-80-24, 50-401-80-22, 50-402-80-22, 50-403-80-22, NUDOCS 8102170224 | |
| Download: ML14175B248 (21) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 11 101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report Nos.:
50-324/80-40,50-325/80-43, 50-261/80-31, 50-400/80-24, 50-401/80-22, 50-402/80-22, and 50-403/80-22 Licensee:
Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name:
Brunswick, Robinson and Harris Docket No. 50-324, 50-325, 50-261, 50-400, 50-401, 50-402, and 50-403 License N DPR-62, DPR-71, DPR-23, CPPR-158, CPPR-159, CPPR-160 and CPPR-161 Meeting at CP&L Corporate Offices, Raleigh, NC Attending Personnel:
See Details Approved by:
E. c. A
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Z C. Lewls, Acting Chief, RONS Branch Date Signed SUMIARY Meeting conducted October 17, 1980 This special, announced management meeting was conducted to discuss the results of NRC's evaluation of CP&L's regulatory performance as concluded in the System atic Assessment of Licensee Performance (SALP) progra Results A summary of the licensee performance evaluation was presente Areas of concern were discussed with corporate management. CP&L's performance is considered to be acceptable although one area was identified for increased inspection emphasi IIQ
DETAILS Personnel Attending Meeting Carolina Power and Light Company A. B. Cotter, Manager Nuclear Power Plant Engineering L. W. Eury, Vice President, Power Supply B. J. Furr, Vice President, Nuclear Operations P. W. Howe, Vice President, Technical Services Department M. A. McDuffie, Senior Vice President, Engineering and Construction S. D. Smith, Vice President Construction R. B. Starkey, General Manager Robinson Plant A. C. Tollison, Jr., General Manager Brunswick Plant E. E. Utley, Executive Vice President Power Supply and Engineering Construction Nuclear Regulatory Commission F. J. Long, Acting Deputy Director, Region II R. C. Lewis, Acting Chief, RONS Branch P. J. Kellogg, Chief, RPS #3, RONS Branch NRC Resident Inspector J. E. Ouzts Areas Discussed A brief summary of the Systematic Assessment of Licensee Performance (SALP)
was presented to include the basis for the evaluation and its purpos The results of the SALP evaluation of the licensee's performance were discussed. CP&L's performance to date is considered acceptable; al though one area was identified for increased inspection emphasis by the NRC. The SALP evaluations are contained in Enclosures 1 through 4 to this repor Items of concern were discussed with corporate management to include those areas where the NRC considers additional licensee management attention may be warrante ENCLOSURE 1 SYSTEHATIC ASSESSHENT OF LICENSEE PERFORMANCE FOR CAROLINA POWER AND LIGHT COMPANY
1-Region II UTILITY PERFORMANCE EVALUATION Utility:
Carolina Power and Light Company Units:
Brunswick 1 and 2 H. B. Robinson 2 Shearon Harris 1, 23 3 and 4 Appraisal Period:
April 1, 1979 -
August 31, 1980 Review Board Members:
R. C. Lewis, Acting Chief, RONS Branch P. J. Kellogg, Chief,Reactor Projects Section 3 C. M. Upright, Acting Chief, Nuclear Support Section 2 A. R. Herdt, Acting Chief, RC&ES Branch F. S. Cantrell, Chief, Projects Section 2 J. K. Rausch, Acting Chief, Projects Section 1 D. Neighbors, Licensing Project Manager, NRR*
J. Hannon, Licensing Project Manager, NRR*
J. Wilson, Licensing Project Manager, NRR*
- By Telephone Background SALP evaluations for each site were generated as prerequisites to the NRC identi fying the general performance level of each utility with an NRC license. These evaluations are forwarded to an interoffice review board formed of senior members from all Offices of the NRC involved in licensed activities. The board will, by virtue of receiving all SALP evaluations, form a national perspective of licensee performance. Additionally, the evaluations will provide a means for highlighting areas of NRC programs that may require changes or redirectio In developing the site evaluations it was determined that an overall evaluation of the utility's performance in its nuclear activities was desirabl Additional enclosures document the individual site evaluation The utility and site evaluations were presented in a meeting with senior corporate management in order to provide the decision makers of each utility with the NRC's evaluation of its overall performance in nuclear activitie Areas of Good Performance CP&L is generally responsive to NRC regulations and to findings of noncom pliance. Corporate and site reorganizations have occurre These changes have improved corporate management attention to the sites. Additional man agement positions at the sites, and related personnel changes have improved management controls at the site Areas Where Improved Performance is Warranted CP&L has had several operational events during the appraisal period, which appear to be the result of lack of procedural adherence, lack of management controls, and poor work practices. These areas have been highlighted to corporate management. Increased attention to the performance of operations at the site would improve these condition Problems have been identified in the areas of contamination and cleanliness control Although improvements have been observed, subsequent findings indicate additional improvement is require Although emphasis has been placed on the Quality Assurance/Quality Control areas for both construction and operations, the areas of procedural accep tance criteria and procedural controls require further improvemen Addi tionally, emphasis is required on the many divisions/departments of QA/QC which overlap in some areas and are void in others and for which overall effective coordination is lackin Overall Evaluation CP&L is, in general, responsive to NRC requirements, findings of noncompli ance, and information requests from the NR Their performance is evaluated to be below average for Region I However, their reorganization appears to be improving their performanc A continuation of this uptrend is expecte ENCLOSURE 2 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMlANCE FOR BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2
2-1 Region II LICENSEE PERFORMANCE EVALUATION (OPERATIONS)
Facility:
Brunswick Steam Electric Plant Unit Nos. 1 and 2 Licensee:
Carolina Power and Light Company Unit Identification:
Docket N License No./Date of Issuance Unit N DPR-71/September 8, 1976
50-324 DPR-62/December 27, 1974
Reactor Information Unit 1 Unit 2 NSSS General Electric General Electric MWT 2436 2436 Appraisal Period:
April 1, 1979 through March 31, 1980 These dates were used to provide a comparable basis for all operating reactors in Region II significant events or enforcement items occurring after these dates were considered in arriving at the indicated conclusion Appraisal Completion Date:
September 18, 1980 Review Board Members:
R. C. Lewis, Acting Chief, RONS Branch J. E. Ouzts, Senior Resident Inspector (By Telephone)
A. K. Hardin, Project Coordinator P. Kellogg, Chief, Reactor Projects Section 3
J. Hannon, Licensing Project Manager (By Telephone)
2-2 Number and Nature of Noncompliance Items Noncompliance Category:
Unit 1 Unit 2 Violations
0 Infractions
16 Deficiencies
4 Areas of Noncompliance:
Unit 1 Unit 2 (Points)
(Points)
Security
24 Fire Protection
40 Radiation Protection
20 Quality Assurance
34 Environmental
10 Administrative
40 152 168 The board in its deliberation of noncompliance items considered the results of previous regional audits and arrived at the conclusion that no adverse trends with respect to noncompliance had been note The review board noted that problems related to radiation protection and contamination had been observed toward the latter part of the audit perio These problems are not reflected in the audit statistics but resulted in the actions dis cussed in paragraph E and in the boards conclusion that increased emphasis should be placed on radiation protection and contamination control inspection The general conclusion the board reached is that Brunswick has been responsive to NRC regulations and findings of noncomplianc The recent reorganization at the corporate and site levels appears to be providing increased responsive ness to our concern Number and Nature of Licensee Event Reports Type of Events:
Unit 1 Unit 2 Component Failure
61 Defective Procedure
3 Personnel Error
11 Design and Fabrication Error
9 Other
20 Licensee Event Reports Reviewed (Report Nos.)
Unit 1 LERs79-001 through 79-118 (118 Reports)
Unit 2 LERs79-001 through 79-109 (109 Reports)
2-3 Evaluation of Above Tabulation For Brunswick 1 and 2, 227 LERs were issued during 1979, 118 for Unit 1 and 109 for Unit 2. The licensee responses are generally adequate and timel No chronic problems have been identified other than there appears to be a large number of instrument drift events which require calibration to bring the instruments within TS limits. However, this problem may be partially resolved by the conversion of instrumentation from digital to analo Escalated Enforcement Actions Civil Penaltie None Orders
-
None Immediate Action Letters On February 21, 1980, an immediate action letter was issued concerning the absence of adequate reactor building evacuation alarm The letter required action to ensure evacuation alarms would function at maximum audibility and verified to be audible in all reactor building location The action letter also required training of personnel and a test of the evacuation syste On March 28, 1980, an immediate action letter was issued concerning inadver tent release of radioactivity to unrestricted areas. The releases occurred through the steam and condensate system of a normally uncontaminated aux iliary steam boiler. The letter required action to assure cleaning of the steam and condensate system, sampling programs to prevent further contami nation and evaluation of other plant systems for potential unknown pathways for release of radioactivit Management Conferences Held During the Audit Period There was one management conference held during the audit perio The conference was convened to discuss a steam line high radiation event which occurred as a result of resin intrusion into the primary coolant syste The actions to be taken by the licensee prior to returning the reactor to power were establishe Justification of Evaluations of Functional Areas Categorized As Requiring an Increase in Inspection Frequency/Scope (See Evaluation Sheets)
The functional area designated as requiring increased attention does not, in total, result from the statistical data generated during the audit perio During an inspection conducted in March 1980 we found that on February 22, 1980, there was an unmonitored, uncontrolled release of airborne radioactive material to the environment from the Brunswick facility. This release was due to improper operation of the auxiliary boiler with radioactive contami nation present in the boiler mud tan The environmental consequences of the release were minor; however, the licensee's failure to recognize the potential safety significance of the situation and the licensee's inadequate
2-4 response to the event were matters of concern to Region I Low-level contamination which spread to public beaches about ten miles downwind of the plant was of concer The inspection revealed three items of noncom pliance which caused or contributed to the unplanned release and three items of noncompliance related to shortcomings in the licensee's occupa tional Radiation Exposure Control Progra During an inspection on April 28, 1980, an inspection scheduled because of Health Physics Program concerns, a Region II inspector found licensed material from the Brunswick facility improperly released to the Brunswick County sanitary landfill near Southport, North Carolin Subsequently, other inspectors determined that other items contaminated with licensed material had been sold by Carolina Power and Light Company to salvage dealers in Wilmington and Goldsboro, North Carolin The above problems resulted in increased inspection attention and escalated enforcement actio In each event, Region II radiation specialists were dispatched to the site and conducted an in-depth review of licensee activitie Independent measurements were made and licensee management involvement was thoroughly examine Based on the concerns identified by our inspectors, an enforce ment conference was conducted in the Region II office with responsible licensee managers following each event. The safety significance of each event, the enforcement significance of each event, and proposed corrective actions of each event were discusse Comparison of Unit 1 with Unit 2 A comparison of Unit 1 with Unit 2, both in operation, indicates no appre ciable difference exists between the unit Problem areas identified are programmatic in nature and apply to the entire sit Overall Evaluation The performance of licensed activities was adequate during the appraisal period as compared to other Region II facilitie Subsequent performance would indicate a well below average performance as indicated by recent inspection findings in the areas of radiation control, contamination con trol, and environmental protection progra These areas are being closely monitored by Region II and corrective action is being taken by the license.
Appendix A-- Functional Areas Appendix B - Action Plan (Internal Use Only)
APPENDIX A 2-A-1 FUNCTIONAL AREAS (Operations)
INSPECTION FREQUENCY AND/OR SCOPE FUNCTIONAL AREA INCREASE NO CHANGE DECREASE Management Control X
Plant Operations X Refueling Operations and Activities X
S Maintenance X
5. Surveillance and Preoperational Testing X Training X Radiation Protection X Environmental Protection X
9. Emergency Planning X
1 Fire Protection X
1 Security and Safeguards X
1 Design Changes and Modifications X
1 Reporting X
1 QA Audits x
1 Committee Activities X
1 Quality Control x
1 Procurement X
(BRAN H CHIEF)
(DATE)
ENCLOSURE 3 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE FOR H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2
3-1 Region II LICENSEE PERFORMANCE EVALUATION (Operations)
Facility:
Robinson Steam Electric PlantUnit 2 Licensee:
Carolina Power and Light Company Unit Identification Docket N.
License No./Date of Issuance Unit N DPR-23 -
July 31, 1970
Reactor Information NSSS Westinghouse MWt 2300 Appraisal Period:
April 1, 1979 through May 30, 198 These dates were used to provide a comparable basis for all operating reactors in Region I Significant events or enforcement items occurring after these dates were considered in arriving at the indicated conclusion Appraisal Completion Date:
May 30, 1980 Review Board Members:
R. C. Lewis, Acting Chief, RONS Branch R. C. Sauer, Project Inspector C. Upright, Acting Chief, Nuclear Support Section #2 P. Kellogg, Chief, Reactor Projects Section 3 D. Neighbors, Licensing Project Manager, (Contacted by telephone for input on May 29)
3-2 Number and Nature of Noncompliance Items Noncompliance category:
Number Violations
Infractions
Deficiencies
Areas of Noncompliance:
Points Part 21
Security
Administrative
Radiation Protection
Quality Assurance
Total Points 124 The board in its deliberation of noncompliance items considered the results of previous regional audits and arrived at the conclusion that no clear adverse trends with respect to noncompliance had occurre The general conclusions the board reached is that Robinson has been responsive to NRC regulations and findings of noncomplianc Number and Nature of Licensee Event Reports Type of Events:
Personnel Errors
Component Failure
Defective Procedures
Design and Fabrication Error
Other
Licensee Event Reports reviewed (Report Nos.)
Robinson 2 LERs 79-05 through 80-05 (38 reports)
Evaluation of Above Tabulation For Robinson 2, 38 LER's were issued during the audit perio The licensee's responses are generally adequate and timely. No chronic problems have been identified; however 5 of the 7 design and fabrication errors and all of the defective procedure events have occurred over the past six months (September 1979 through April 1980).
Future LER's in these areas will be monitored closely to ensure the licensee is taking appropriate corrective action to resolve problems in these area Escalated Enforcement Action Civil Penalties Non Immediate Action Letters April 13, 1979
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Restricted plant startup until seismic analysis of reactor coolant piping was confirme Concurrence of the seismic analysis and plant start was provided on May 4, 197 June 15, 1979
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Restricted plant startup until the feedwater nozzle crack evaluation and repairs were confirme Concurrence of this matter was provided on July 13, 197 July 19, 1979
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Restricted power operation until conformance with the requirements of IEB 79-02 were con firme Concurrence was provided on this item on July 24, 197 March 13, 1980
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Required a revision of emergency instruction EI-1,
"Incident Involving Reactor Coolant System Depressurization" to agree with the Westinghouse Owners Group guidelines "Refer ence Emergency Operating Instructions". Management Conferences Held During Twelve Months No enforcement conferences were held during this audit period, however, Carolina Power and Light Company officials requested a management meeting on November 6, 1979 to discuss changes in the Carolina Power and Light Company Corporate and Plant Organization These changes involved the Corporate, H. B. Robinson and Brunswick Plant Management and supervisory structure Justification of Evaluations of Functional Areas Categorized as Requiring an Increase in Inspection Frequency/Scope (See evaluation sheets).
The regional office review board has concluded that continuation of the inspection program without an increase or decrease in emphasis is warrante Overall Evaluation The performance of licensed activities is slightly above average as compared to other Region II facilitie The licensee is responsive to NRC findings and good communications exist between the licensee, the NRR project manager and the Region II offic.
Appendix A - Functional Areas Appendix B - Action Plan (Internal Use Only)
APPENDIX A 3-A-1 FUNCTIONAL AREAS (Operations)
INSPECTION FREQUENCY AND/OR SCOPE FUNCTIONAL AREA INCREASE NO CHANGE DECREASE Management Control X Plant Qperations X Refueling Operations and Activities X
4. Maintenance X Surveillance and Preoperational Testing X Training X Radiation Protection X Environmental Protection X Emergency Planning X
1 Fire Protection x
1 Security and Safeguards X
1 Design Changes and Modifications X
1 Reporting x
1 QA Audits X
1 Committee Activities X
1 Quality Control X
1 Procurement X
(BRA CH CHIEF)
(DATE)
ENCLOSURE 4 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE FOR SHEARON HARRIS UNITS 1, 2, 3,
4-1
REGION II
LICENSEE PERFORMANCE EVALUATION (CONSTRUCTION)
Facility:
Shearon Harris Licensee:
Carolina Power and Light Company Unit Identification:
Docket No CP Nos./Date of Issuance Unit No CPPR-158/1-27-78
50-401 CPPR-159/1-27-78
50-402 CPPR-160/1-27-78
50-403 CPPR-161/1-27-78
Reactor Information:
Unit 1 Unit 2 Unit 3 Unit 4 NSSS Westinghouse Westinghouse Westinghouse Westinghouse HJWt 2785 2785 2785 2785 O
Appraisal Period:
September 1, 1979 through August 31, 1980 Appraisal Completion Date:
October 15, 1980 Review Board Members:
A. R. Herdt, Acting Chief, RC&ES Branch F. S. Cantrell, Chief, Projects Section #2 J. K. Rausch, Acting Chief, Projects Section #1 J. N. Wilson, Licenseing Project Manager (By Telephone) Number and Nature of Noncompliance Items Noncompliance category:
Unit 1 Unit 2 Unit 3 Unit 4 Violations
0
0 Infractions
7
7 Deficiencies
6
5
4-2 Areas of Noncompliance:
Unit 1 Unit 2 Unit 3 Unit 4 (Points)
(Points)
(Points)
(Points)
Procedures inadequate or not followed Welding
0
0 Concrete work
34
34 QA/QC
34
32 Cleanliness and Housekeeping
14
14 Total Points 126
80 80 Number and Nature of Deficiency Reports (CDRs)
Rebar Omissio Deficient Welds
Other
NOTE:
A total of 32 potential CDR items were reported during the audit period. After further evaluation 27 were determined as not being significant under the terms of 50.55(e). Escalated Enforcement Action
Civil Penalties Non Orders Non Immediate Action Letters A Confirmation of Action Letter was issued on October 30, 1979, concerning rebar omission in Unit 1 containment building. The letter confirmed that the licensee would; discontinue all placements of Category I concrete until obtaining RII's concurrence, determine the cause of rebar omission and whether or not a problem existed with the QC control, evaluate the adequacy of already embedded rebar, and provide detail of changes to be made to the licensee's QA/QC program. A Confirmation of Concurrence Letter was issued November 6, 197 The NRC's concurrence was based on a review of pertinent documentation provided during the management meeting at Region II on October 30, 1979 with the licensee and licensee letters dated November 1 and November 2, 197 A Confirmation of Action Letter was issued on April 10, 1980, concerning rebar omissions in the Unit 1 containment exterior wal The letter confirmed that the licensee would; discontinue all placements of Category I concrete in the Unit 1 containment building until obtaining RII's concurrence, determine the cause of rebar failures and whether or not problems existing during. a previous rebar omission had been correcte A Letter of Concurrence was issued April 22, 1980, releasing the licensee to continue placing concrete in the Unit 1 containmen The NRC concurrence was based on a management meeting with the licensee held in the RII offices on April 17, 1980, and an NRC inspection of the Harris site on April 22, 198 A Confirmation of Concurrence Letter was issued on September 10, 1979, concurring with the licensee's plan to remove the Category I fill from the emergency service water intake channel and to replace with new Category I fill in accordance with specifications. This concurrence was based on the licensee's letter dated September 6, 1979 to the Office of Nuclear Reactor Regulation. The licensee's program for the new fill placement and technical criteria is in that lette Management Conferences Held During Past Twelve Months Management meetings were held on October 30, 1979, and April 17, 1980 between NRC Region II personnel and CP&L managemen Licensee reporting, corrective actions, QA/QC effectiveness, enforcement history and problems that appear generic to nuclear facilities under construction were discusse The licensee committed to implementing a training program to educate all crafts, QC and supervisory personne In addition, the licensee committed to additional engineering routine checks to prevent recurrence of rebar omissio S Justification of Evaluations of Functional Areas Categorized as Requiring an Increase in Inspection Frequency/Scope (See evaluation sheet)
A review of the types of nonconformances indicates that QA/QC programmatic procedure preparation needs closer surveillanc The licensee's constructi-on and inspection programs have been maintained on schedule. No action other than continuation of the routine program with emphasis.on the QA aspects is considered necessar Comparison of Units Due to the completion status of the units, the problems identified have been programmatic in nature and therefore applicable to all unit As construction continues unit specific problems may arise. This area will be monitored by the recently established resident offic Overall Evaluation The licensee's performance of licensed activities in the construction area is slightly below average. This performance level is primarily due to a lack of effectiveness in the QA/QC programs for identifying and correcting problems. This area has been highlighted to the licensee and will continue to receive close scrutiny by the resident inspecto Appendix A - Functional Areas Appendix B - Action Plan (Internal Use Only)
APPENDIX A 4-A-1 FUNCTIONAL AREAS (Construction)
INSPECTION FREQUENCY AND/OR SCOPE FUNCTIONAL AREA INCREASE NO CHANGE DECREASE Quality Assurance, Management & Training X
2. Substructure & Foundations X
3. Concrete X
4. Liner (Containment & Others)
X 5. Safety-Related Structures X
.
6. Piping & Hangers (Reactor Coolant & Others)
X 7. Safety Related Components (Vessel Internals
& HVAC)
X 8. Electrical Equipment X
9. Electrical (Tray & Wire)
X 1 Instrumentation X
1 Fire Protection X
1 Preservice Inspection X
1 Reporting x
(BRANCH C. P
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("D A'