IR 05000324/1989028
| ML19332C156 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/03/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19332C103 | List: |
| References | |
| 50-324-89-28, 50-325-89-28, NUDOCS 8911220371 | |
| Download: ML19332C156 (34) | |
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- ENCLOSURE
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' INTERIM SALP REPORT
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NUCLEAR _' REGULATORY COMMISSION-(NRC)
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REGION II-
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i SYSTEMATIC ASSESSMENT OF LICENSEE: PERFORMANCE-i
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INSPECTION: REPORT NUMBERS-i
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'50-325/89-28.AND 50-324/89-28 f
- CAROLINA POWER ~AND LIG'HT' COMPANY-(CP&L)-
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BRUNSWICK-1 AND 2
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31, 1989-
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- SEPTEMBER 1, 1988 - AUGUST
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SUMMARY OF RESULTS Brunswick has been operated in an overall safe manner during the assessment period, but with mixed performance.
Improvements were noted in the areas of engineering / technical support and safety assessment / quality verification.
A major strength continued in the area of security.
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Monagement efforts in the plant operations area were successful in arresting the declining trend observed during the last assessment period.
Specifically, management involvement to reduce challenges to operators'
effectiveness were evident by the significant decrease in the number of trouble tags on the control board and the implementation of the operators'
" ten most wanted list".
Also, the addition of an extra reactor operator per shift was effective in providing the operators with greater opportunity to find problems and monitor the plant.
The licensed operations staff continued to perform satisfactorily during off-normal transient conditions, but still experienced some problems in controlling plant conditions for a shutdown unit.
Plant house keeping and the drywell closecut process continued to be a strength.
Although the licensee's
- Appendix R audit was untimely, sound technical judgement was demonstrated with respect to resolving the identified deficiencies.
Despite the increased management attention in plant operations, action taken with respect to personnel errors, particularly in the areas of configuration control and clearances, were yet to be effectiv /
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L The ' health physics (HP) program continued to be adequately implemented.
The overall quality and experience level of the HP staff remained. a program strength.
The successful completion of the dechanneling and subsequent shipment of spent fuel.to Shearon. Harris, as well as the improvements made in effluent monitor operaoility and controlling personnel contamination, reflected positive management attention in these areas.
The station's collective radiation dose remained relatively high,
with intergrannular stress corrosion cracking related activities being the significant contributor.
The commitment to replace recirculation pipe was
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a positive step in reducing dose in the longterm;. however, hydrogen water
chemistry control had not been fully implemented and response to NRC-initiatives involving ALARA improvements lacked necessary management attention.
For the most part, the maintenance / surveillance area produced good results.-
A significant improvement in reducing the number of safety system failures was seen during this assessment period..Although not
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fully implemented, the motor operated valve program was considered a strength, and the automated tracking systems continued to be excellent-tools in managing the maintenance and surveillance of the station.
Weaknesses were noted in the component identification labeling program, inservice inspection / testing program, and in the maintenance work planning and performance process.
Additionally, some recurring problems still
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lacked the necessary attention for prompt and complete resolution.
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The-capability to implement critical aspects of emergency preparedness.
(EP) was demonstrated during simulated and actual emergency events.
The EP -training program had been sufficiently changed to include proctored exams and auditable training records.
Some essential elements : of emergency response were identified as requiring improvement during the 1988 annual exercise.
One of these elements, the providing of followup reports while emergency notification responsibility remained in the control room, continued to be a problem in the 1989 emergency exercise, as well as during a subsequent event.
Security activities continued to be a strength.
Secu-ity personnel observed in the performance of their duties were knowledgeable, alert, and capable.
Security management continued to be intimately involved in security force activities, aggressively seeking effective and lasting solutions to security-related problems.
Performance in the engineering / technical support area was, mixed, with improvement evident in the latter half of the assessment period.
Engineering support was not aggressive in resolving several service water (SW) issues.
The resolution of these SW issues, once prompted by the NRC, was thorough, but revealed inadequacies in the program for design change development.
In contrast, effective technical support and management involvement was demonstrated on a number of technical issues, including reliability improvements in high pressure coolant injection systems and resolution of crack indications in the Unit 1 reactor vessel nozzles.
Improvements in system engineering investigation and root cause
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determinations were evident -in the latter half of the assessment period, as related corrective actions were implemented.
Significant progress was
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made towards the reduction of the engineering work request-backlog,
through the. completion of their initial review and disposition.
Actions
- taken - towards the end of the _ assessment period to address EWR related material problems and obsolete parts, confirmed management's intentions to resolve this issue.
Operator training was considered good, with a noted
. improvement int training reference material.
Management's commitment towards improving the plant specific simulator was seen in the large number of deficiencies corrected since August 1988, and those planned for correction in the future to meet certification standards.
The functional area = cf safety assessment / quality verification displayed inconsistent performance.
To-address historical root cause determination problems, the corrective action program was improved through the site wide implementation of a corrective action procedure.
Improvements were seen-in_ the licensee's ability to adequately assess the safety significance of discrepant conditions and take the appropriate corrective action.
However, on several occasions safety reviews lacked the necessary vigorous questioning and were hampered by a failure to get the right people involved when issues emerged.
Once an issue was properly categorized and the appropriate levels of plant management were aware, actions to resolve the issue were' extensive.
The Onsite Nuclear Safety group's impact onsite had diminished this assessment period due to reduced staffing.
Onsite quality assurance -activities were properly focused, with an increased trend toward performance based surveillances.
Overview The specific assigned ratings for the last rating period and the current period are shown in the following table.
l Rating Last Period Rating This Period Functional Area 7/1/87 - 8/31/88 9/1/88 - 8/31/89 Plant Operations 2 (declining)
Radiological Controls
2 Maintenance / Surveillance
2 Security
1 Engineering / Technical Support
2 Safety Assessment / Quality
2 Verification III. CRITERIA Licensee performance is assessed in the selected functional areas shown above.
Functional areas normally represent areas significant to nuclear l
safety and the environment.
Special areas may be added to highlight significant observations.
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The evaluation criteria which were used, as applicable, to assess each
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functional area are described in detail in NRC Manual Chapter 0516.
This
' chapter is in the Public Document files.
Therefore, these criteria are r
not repeated here, but will be presented in-detail ont the public meeting to be held with licensee management on November 9,- 1989.
However,'the NRC is. not limited to these criteria and othert may have been used where appropriate.
On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. -The definitions of these performance categories are shown here only because of some changes in the NRC Manual. Chapter noted above.
These new performance categories are defined as follows:
F 1.
Category 1.
Licensee management attention and involvement are readily. evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements.
Licensee resources are ample and effectively used so that a high level of plant and personnel performance -is being achieved.
Reduced NRC attention may be appropriate.
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Category 2.
Licensee manag9 ment attention to and involvement in the performance of nuclear safety or safeguards activities are good.
The licensee has attained a lovel of performance above that 'needed to meet regulatory requirements.
Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is
.being achieved.
NRC attention may be maintained at normal levels.
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-Category 3.
Licensee management attention to an involvement in the performance of nuclear safety or safeguards activities are not sufficient.
The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements.
Licensee resources appear to be strained or not effectively used.
NRC attention should be increased above normal levels.
The' SALP Board included an appraisal of the performance trend of certain
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functional areas where considered necessary.
Performance trends are used when both a definite trend of performance within the evaluation period is i
noted and the Board believes that continuation of the trend may result in a change of performance level.
The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving near the close of the assessment period.
Declining:
Licensee performance was determined to be declining near the close of the assessment period and the licensee had not taken meaningful steps to address this pattern.
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IV, PERFORMANCE ANALYSIS r
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PLANT OPERATIONS e
L Analysis This functional area. addresses tne control and performance of activities directly related to oparating the units.
This area includes activities involved with monitoring plant conditions, system lineups, norrhal ' operations, response to transient and off-normal conditions, control-manipulation, control room professionalism, plant housekeeping, equipment conditions, fire protection, and ' interfacing activities that support plant operations.
This assessment is based on routine inspections, as well as the Diagnostic Evaluation team assessment, the Emergency Operating Procedures team inspection, and the Appendix R team inspection' conducted by the NRC staff during the assessment I
period.
Unit' operations performance with the units connected to the grid was comparable to - the last assessment period; showing both strengths and weaknesses.
Three automatic scrams occurred, two on Unit 1 and one on Unit 2, due to equipment failure.
In addition, Unit 2 was manually scrammed per procedure when both recirculation pumps tripped upon loss of of T-site power.
In comparison,.there were two scrams last assessment period, with one caused by equipment failure.
Staffing levels in the control room were increased by management to provide the operators' with greater opportunity, to find problems and monitor the plant.
An extra reactor operator per shift was assigned to each unit to take routine logs and make routine observations of control room main and back' panels.'. This j
action resulted in fewer NRC identified equipment / instrument'
j problems in the control room compared to last assessment period.
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Overall staffing levels of licensed operators exc.eeded minimum j
staffing requirements by three licensed personnel, on the-average.
The licensee-failed to pre-approve excess overtime for
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auxiliary operators; a repeat problem from last assessment i
period. With respect to this problem, immediate supervisors are now required to be informed about overtime performed by their shift personnel on other shifts.
Management directed the use of uniform attire in the control room to foster professional attitudes.
While the licensee continued to use the detailed turnover checklists developed last assessment period, exceptions were noted.
Overall, shift turnovers were thorough and professional.
Numerous clearance problems continued throughout the assessment period.
Six reportable events, two violations, and a civil penalty were the result of inadequate or incomplete equipment
clearances and related system restoration.
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also occurred last assessment period.
To correct one aspect of
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the clearance problem (i.e.,
clearance development), the licensee instituted a clearance center which provided dedicated licensed operators to research clearance boundaries.
At the end of the assessment period the licensee was in the process of
taking actions to strengthen the clearance center, since one of
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the. violations mentioned above occurred after the center was-
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established.
Controlling plant conditions for a shutdown unit continued to be a major-weakness throughout the assessment period.- Examples of
problems while~ shutdown included-inoperable standby gas treatment system, poor control of ' reactor coolant system
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pressure, and an increased number of reportable events.
Management has initiated corrective actions, like a special cotputer display of shutdown parameters, to help solve some of the problems.
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Procedural adherence was generally adequate with only an occasional example of failure to follow procedure.
Alternate safe-shutdown procedures were. detailed and comprehensive.
Inspection of the plant E0Ps early in the assessment period indicated that the licensee had taken extensive measures to correct deficiencies noted during previous inspections and that the controls covering the development of the E0Ps had improved.
Subsequent inspection indicated that the licensee was still enhincing the E0Ps.
L The : licensed operations staff continued to perform satisfactorily during off-normal and transient conditions.
An inadvertent emergency core cooling system actuation was handled timely and without error.
Actions taken in response to a loss of off-site power were appropriately accomplished after an
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initial maintenance error caused the event.
However, several communications problems contributed to the event:
a shift operating supervisor failed to timely carry out the plant manager's power reduction instructions; and the control room operators did not understand the nature of the troubleshooting done by the relay crew at the startup auxiliary transformer.
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The licensee's Appendix R fire protection program was essentially implemented satisfactorily once the decision was made to perform an in depth self-assessment of the program.
Af ter the required Unit 2 compliance deadline, the licensee found numerous problems with their hardware and certain procedure prob? ems.
The licensee delayed start-up of Unit 1 until the hardware problems were fixed on that unit. Unit 2 continued to operate with fire watches as compensatory measures until the September 1989 refueling outage.
While the licensee showed sound technical judgement in resolving the issues, the followup audit was untimely.
Certain problems were noted by the
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L NRC after the internal audit', including a violation of the cable separation criteria.
Ef forts to' reduce challenges-to operators' effectiveness were evident during this assessment period.
Specifically, the number of trouble tags on the main control board trended downward, especially during the first six months of the assessment period.
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This positive response occurred' due to plant: management'
involvement in the issue.
Operations ~ personnel were also involved by informing maintenance of items to be worked through
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the use of the " ten most wanted list."
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Plant housekeeping, as well as the drywell closeout process, continued to be a strength.
The licensee found capped drywell pressure instrument sensing lines prior to a unit restart, because of the additional check required in the operations closeout procedure.
However, a repeat problem with damaged insulation for the safety relief valve acoustic monitor. cables
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occurred, showing that more attention is needed during outages
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to prevent damage to those instruments.
The licensee's actions regarding human performance this assessment period were mixed.
Human performance evaluation system (HPES) training was provided to 38 staff members; however, the coordinator position, which was established at a s
senior level, remained unfilled.
A human performance related improvement. of main control board key control was implemented during this assessment period.
This - resulted in reducing the operator response time, while still requiring two actions to operate a key lock switch.
Personnel errors in the-area of configuration control-had not been corrected, as the licensee continued to find valves out lof position.
Management actions L
were ineffective in addressing this problem.
In the latter half of the assessment period, licensee management took several other initiatives to improve operations performance.
These included a-. method to capture conditions
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adverse to quality through assigning individual responsibility, and a semi-annual review of operations events to find overall
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trends and suggest improvements.
These and other improvements need additional management direction and time to produce i
results.
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E'.even violations were identified.
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Performance Rating l
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Recommendations Managenent efforts were successful in arresting the declining trend which was observed in this functional area during the last assessment period.
Increased management attention and involvement is necessary to improve those areas being hindered by personnel errors.
The high level of inspection effort should continue.
B.
Radiological Controls 1.
Analysis This ' functional area consists of evaluation of activities related directly to radiological controls including occupational '"
radiation protection, radioactive materials and contamination controls, radiological surveys and monitoring, and ALARA programs.
Other activities which are evaluated include those related to radioactive waste' management, radiological effluent.
control and monitoring, offsite dose calculations, radiological-
environmental monitoring, confirmatory measurements, and transportation of radioactive materials.
Tnis assessment is-based on the ALARA ' team inspection conducted in September 1988,-
and on routine inspections throughout the assessment period.
The licensee's radiation protection staffing levels, including health physics (HP), radwaste, and transportation were considered adequate to support routine and outage operations.
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The licensee made limited use of contract HP technicians during outage operations to supplement the permanent staff.
All of the 54 authorized HP technician positions were filled with American National Standard Institute qualified personnel.
Although the i
licensee's organizational analysis resulted in a reduction of i
six HP technician positions, the staffing was still considered adequate.
The overall quality _ and experience level of the HP staff was considered a program strength.
The. training programs for general employee radiation protection (GET). and for ~HP technicians continued to be adequate and well
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defined during this assessment period.
The GET training covered
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not only the standard topics as outlined in 10 CFR 19, but other safety and industrial hygiene topics, industry e"' n?.s, and g
recent NRC findings.
Management's support of and teemitment to
L training were evident, in that sufficient time war f located for j
employees to attend the training sessions.
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Licensee response to NRC initiatives lacked in timeliness and
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thoroughness during this assessment period.
During a radio-i logical controls inspection conducted in August 1989, it was
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observed that the licensee's responses to several program i
weaknesses which were identified during an ALARA team inspection
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conducted during this assessment period were inadequate.
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l examples of this inadequacy were demonstrated in the licensee's
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audit program.
In the first example, the NRC initiative was to identify and track dose due to rework, since the licensee indicated that rework had - historically been a significant-contributor to the facility's annual collective dose.
Although the licensee's response appeared viable, subsequent efforts _ to-identify and track the related rework dose' contributors had not U
been effective.
In the second example, the NRC initiative was.
to. develop more thorough-and comprehensive audits of: the ALARA r
program.since a number of ALARA program weaknesses were i-identified by the NRC ALARA assessment team, yet the. licensee's audits.of the ALARA program over the last 5 years did not result
'in any substantive findings or recommendations.
In response to the NRC initiative, the licensee augmented related audit teams with HP specialists.
The only audit performed since the new initiatine failed to identify any new radiological deficiencies; indicating:that audits in this area remain ineffective.
Additionally, the licensee's capability of prior planning and assignment of priorities was reviewed with regard to the Unit 2 recirculation pipe replacement.
Although it appeared that ALARA considerations lacked adequate planning and preparations prior-to. the start of the September 8, 1908 outage, a Radiation Protection Plan for the recirculation pipe replacement project
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was issued on September 1,1989, one day after the end of this assessment period.
In addition, the.. licensee took. the'
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initiative to send representatives to another BWR site that was L
undergoing similar pipe replacement, in order to gain first hand
l information on techniques-used to reduce dose.
Also, two
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contractors with the ALARA group from that facility were
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employed to provide needed experience for this outage.
The licensee planned to provide mockup training to personnel assigned to perform outage related tasks prior to performing the operation in the plant.
During this assessment period, the station's collective radiation dose was 1358 person-rem.
There were 192 outage days during this period, with the most significant contributors to the station's relatively high collective dose being inter-granular stress corrosion cracking inspections and nozzle weld
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overlays in Unit 1.
There was no significant change in the station's collective radiation dose when compared to 1378 person-rem /184 outage days in the previous assessment period.
The licensee demonstrated positive management involvement in
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controlling personnel contamination.
The licensee acquired four new IPM-8 whole-body friskers to better control and identify contamination events.
These monitors are more sensitive ir.
detecting contamination than hand-held friskers and therefore, the licensee's efficiency in personnel contamination detection increased.
This led to an increase of personnel contamination
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d incidents from 59 last assessment period to 106 this assessment period. _ In addition, the licensee also limited power block egress to one location during normal operation for better contamination control.
T The licensee made three shipments of spent fuel to the Harris plant during this assessment period.
Prior to shipment, the
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complex task of dechanneling the spent fuel was-performed.
The licensee used mockup training, remote video monitoring, and.
explicit - administrative controls to remove, compact, and ship
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the fuel channels off-site.
The successful completion of the
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dechanneling and subsequent shipment of the spent fuel without incident was indicative of good planning, proper staffing, and effective-training.
During - this assessment period, the licensee maintained approximately 79,000 square feet in the facility (excluding drywells) under contamination controls.. This area represented approximately-19 percent of.the radiological controlled area at-the-facility including the reactor buildings, auxiliary building, turbine building, and radwaste building.
The percentage of contaminated area did not change significantly from.the previous assessment period.
Improvements were made in effluent monito'r operability since the last period.
The Units 1 and 2 Reactor. Building and Turbine Building ventilation flow rate measurement devices had been modified, repaired, and placed back in service.
These devices
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had been previously inoperable, requiring the licensee to use continuous compensatory measures.
No significant trends were noted in gaseous effluents and liquid tritium discharges from 1986 through the first half of 1989.
Liquid. fission ant activation products, however, did show-slight increases during 1986 through 1988, with a significant increase during the first half of 1989.- The increase in 1989 was due to fouling of the radwaste demineralizers during torus water cleanup and leakage from a reactor water cleanup system valve.
y Projected offsite radiation doses from liquid and gaseous effluents for 1988 were a small fraction of the permissible limits established by the Technical Specifications,10 CFR 50 Appendix I, and 40 CFR 190.
No abnormal liquid or gaseous releases were reported during 1988 or the first half of 1989.
This was a significant improvement ever 1987 during which there were 3 abnormal releases.
The effluent release data is summarized in the table in Section V.H of this report.
A confi rmatory measurements comparison for tritium, Stronti um-89, Strontium-90 and Iron-55 showed excellent agreement.
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maintained within the guidelines recommended by the BWR Owners Group.~
The licensee' implemented hydrogen water chemistry (HWC)
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control in Unit 2 to help' reduce' crack growth rates in reactor I
coolant system (RCS) piping and welds caused byc intergranular stress corrosion cracking.
Although restricted from optimum HWC control by Technical Specifications, due to main steam line.
radiation monitor setpoints, there have been reductions in RCS dissolved oxygen and conductivity.. Pre cracked and artificially-stressed 304 Stainless Steel and Inconel-182 specimens installed in the Unit's sample line showed significant decrease in crack growth rates during hydrogen injection.
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No violations were identified.
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Category:
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Recommendations The-current level of inspection and ALARA oversight efforts should continue.
C.
Maintenance / Surveillance 1.
' Analysis-This functional area includes evaluation of activities related to diagnostic, predictive,. preventive, and corrective main _tenance of plant structures, systems and components.
-Activities related = to procurement, control and storage of components, ~ qualification controls and installation-of plant modifications were also evaluated.
The conduct of surveillance
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and. inservice testing' activities is based on the special
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Maintenance team inspection conducted' in January 1989, the
.l special Diagnostic Evaluation team assessment conducted in April
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and May 1989, and routine inspections throughout the assessment jl period.
The maintenance organization was adequately staffed.
Although the maintenance organization reduced its staff.at the end of the j
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. assessment period as part of CP&L's Organizational Analysis, j
L maintenance staffing and experience were judged to be ample.
- Turnover-rate was very low, morale was good, and the atmosphere y
of team work displayed within the maintenance group was above
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average.
The journeyman technical development training is a strength at
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L the Brunswick facility.
The standardization of technical training, implementation of qualification cards, and the L
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-a1d leadership from corporate management.
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The overall planning. and scheduling of maintenance work ac '.i vi ti es showed improvement during the assessment period.-
'This was evident by the steady downward trend in outstanding i
work request / job orders -(WR/J0).
The licensee continued to use
the Site Work Force Control Group to effectively plan and schedu?e maintenance work activities.
In addition, backshift, weekend, and holiday coverage was established. - This initiative has met with some success in eliminating delays and providing for a quicker response for emergent work items.
A weakness reported in the previous SALP period was the lack of effective -' methods for identifying and tracking repetitive failures.
The improvement in the area was attributed to management establishing a system to track - rework based on the similar cause descriptions in the WR/J0.
Based on information obtained from this system, a report of identified repetitive failures was issued monthly and presented to the plant nuclear -
safety committee for review and disposition.
The established
tracking system showed a rework rate of about 2 percent at the i
end of the assessment period.
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The licensee's-program for upgrading component identification labeling and correcting existing labeling deficiencies was found
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to be deficient.
Specifically, the organization responsible for the program was marginally staffed to accomplish this task and a systematic cnd comprehensive approach for the identification, evaluation, and prioritization of plant labeling deficiencies had not been developed.
An additional hindrance to this effort was that maintenance technicians and supervisors indicated that
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they were unaware of program requirements to identify labeling i
deficiencies which were noted during tests they were conducting.
i The licensee, recognizing the problems in the plant labeling l
program, plans to have implemented by early 1990, a comprehen-l sive and definitive; tagging and labeling improvement program.
Continued improvements in the licensee's preventive and predictive maintenance programs included the implementation of y
an Infrared Thermography program to monitor the performance of l
electrical equipment to detect problems before equipment i
failure.
This initiative was considered to be an asset to the overall maintenance program.
L The licensee's overall maintenance program was good.
However, some weaknesses occurred during implementation.
Certain isolated examples of inadequate procedures or failure to follow procedures occurred during the assessment period, and control of fuses was a recurring problem. However, no reportable events were directly related to poor maintenance.
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.The. licensee's resolution _of equipment deficiencies has
generally been good, once resources were focused on a problem,
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and' usually the prescribed corrective action was of high
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quality.
This was evident by the significant ' improvement in
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reducing. the number of safety system failures 7 during this assessment period.
Examples of this are. the ' high pressure coolant injection (HPCI) and reactor core isolation. cooling-
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(RCIC) systems, which unlike the last assessment period,.have not experienced operability concerns due to malfunction of -
system valves.
However, certain problems lacked the necessary attention for prompt and complete resolution.
Examples of this included the recurring problems with the. keepfill systems-and-high moisture in the HPCI turbine oil sump.
Also, the passive fire protection features in the diesel generator building basement and the-auxiliary transformer bus ductwork had not been adequately maintained.
The latter contributed to the Unit 2 loss of offsite power. event / manual scram.
-3 The-licensee's upgrade of maintenance and surveillance procedures continued during the assessment period.
The licensee has provided a staff of experienced procedure writers specifically dedicated to this task.
Maintenance and surveil-lance procedures were noted to be consistently formatted and-
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well organized for ease of use.. Procedures reviewed were technically adequate and provided a high -level of detail.
The
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licensee plans to. complete the upgrade program by January 1994.
At the end of the. assessment period, the total project scope was l
about 1250 procedures, one-third of which were complete.
The. Automated Maintenance Management System, the Equipment Data Base System, and the Surveillance Tracking and Scheduling System (STSS) - continue to. be excellent tools in managing _the maintenance '. and surveillance of the station.
Using their
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automated systems, the. licensee established the repetitive
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failure program discussed earlier.
This program was initiated partially in response to a weakness in this area identified last assessment period.
The licensee effectively controlled / tracked the performance of identified Technical Specification related surveillances through their STSS.
However, during a review of the licensee's Technical Specification interpretations, the NRC found that the licensee had improperly stopped testing several containment isolation valves after submitting a change request to delete the valves from Technical Specifications.
When. brought to their attention, the licensee returned to testing the valves while awaiting approval of the Technical Specification change request.
Observation of surveillance test activities in progress showed personnel conducting the tests were technically knowledgeable and were effective in coordinating test activities with ongoing
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plant operations.
Although there were no reportable events
caused - by - maintenance surveillance-test procedural problems,
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there were several cases where technicians shortea ' instrument
' leads inside equipment, causing' unnecessary safety system actuations.
The licensee plans to install clips to help solve
>
thh problem.
The inservice inspection (ISI) program and repair welding activities were-examined during an-outage for Unit.1 (December
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1988).
Planning and management involvement in the examination of piping and components for intergranular stress corrosion cracking (IGSCC) was evident by the frequent evaluation of data and attention to detail during the examinations.
There were, however, several identified weaknesses concerning the ISI and
,
inservice test (IST): program.
Specifically, there was no corporate policy or organizational guidance responsible for the ISI/IST. program and lessons learned from other CP&L facilities were not incorporated into the Brunswick program.
Additionally, the IST program had not incorporated the good practices and the more detailed testing exhibited by the predictive maintenance pump vibration program.
Program enhancements such as the ones discussed above, may have prevented the inadequate test controls which were observed during head-flow-testing of the 2B nuclear
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service water pump in April 1989.
t During the assessment period there were several instances where post maintenance testing (PMT) was not adequately prescribed and or performed.
The majority of these, which were identified by the-licensee, involved safety-related valves that were either replaced, disassembled and rebuilt, or had limit switches adjusted.
In one of. these instances, the nonconformance report resolution was deferred for approximately 10 months by extensions.
The number of identified PMT deficiencies indicated weakness in maintenance work planning and performance process; i
thereby warranting further management attention.
Significant resources and management involvement have been applied to the motor operated valve (MOV) program.
Strelgths in the program include M0V technical training, in-house expertise on the use of motor actuator characterized (MAC) testing equipment, and the high quality of corrective maintenance procedures.
However, the program was not fully implemented as-evidenced by the number of MOV preventive maintenance tasks that were still outstanding.
The licensee did identify a significant number of errors and conflicting information in the administrative procedures used to establish control over MOV torque and limit switch settings.
The majority of these problems were identified by the MOV task force during August through December 1988.
The primary reason attributed to the errors in the controlling documents was due to
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the' ongoing plant modifications which changed from Fisher to Jamesbury valves.
Four Violations were identified.
-2.
Performance Ratinos g
Category:
3.
Recommendations
-Inspection effort in this area should be maintained.
D.
Analysis
'This functional area includes evaluation of activities related to the implementation of the Emergency Plan and its implementing procedures.. These activities include Emergency Plan develop-ment, ' support and training of -onsite and offsite. emergency response organizations, licensee performance during emergency
- exercises and actual emergencies, and implementation of the Emergency Plan during exercises and actual events.
Performance is also evaluated in event notifications, recovery actions, protective actions, and interactions between onsite and-'offsite emergency response organizations during exercises and actual-events.
This assessment is based on inspections conducted-during the two annual emergency preparedness exercises, the
,
routine emergency preparedness inspection, and observations
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during actual events.
j The routine inspection during this assessment period indicated that the licensee was adequately maintaining its Emergency Plan, emergency facilities, staffing, and equipment.
Additionally, the licensee's training program had been sufficiently changed to include proctored exams (vice the open book take home exams l
'
previously used) to qualify emergency organization personnel and -
i l._
make training records auditable, j
During the 1988 annual exercise the licensee demonstrated an
,
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ability to take appropriate protective measures in the event of an emergency; however, some essential elements of emergency response were identified as requiring improvement.
These elements included notification methods and procedures, the onsite emergency organization, and the emergency classification system.
The notification issue concerned the failure of the control room staff to provide required followup reports to offsite authorities during the initial phases of the emergency when the responsibility for offsite notifications rested with
the Site Emergency Coordinator in the control room.
Because d
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.this same issue was also an exercise weakness in the 1987 exercise, it was identified as_ a violation.
The onsite emergency organization weakness-involved emergency management and coordination problems which hampered-accident assessments in
'the - technical' support center.
The emergency classification
,
weakness concerned a failure'of onsite personnel to demonstrate an effective utilization of the emergency action level scheme in
~
classifying the simulated emergency conditions.
In addition to the above violation ano two exercise _ weaknesses, additional concerns for followup included a need to demonstrate onsite-accountability and a need for a more critical ritique to management on exercise performance.
.
Thc _1989 emergency exercise did not have a sufficiently challenging scenario to adequately demonstrate effective
' emergency response capabilities or permit significant improve-ment in the emergency response o' ganization.
-This was identified as an exercise weakness.
Additionally, the licensee identified the failure to make followup notification from the control room as a ' deficiency.
This. deficiency was indicative that the corrective action.taken in response to the. violation addressed above had not been effective.
Shortly thereafter, the q
licensee had an actual event at the site resulting in
declaration of an Alert.
Once again, no followup reports were O
provided from the control room for the approximate two hours j
that emergency notification responsibility remained with the i
control room.
!
I During ~ the assessment period, plant management adequately demonstrated ef fective use _ of the emergency organization during events.
Also, the licensee pursued program enhancements such as flowcharting Emergency Action. Levels to aid in emergency classification.
Overall the licensee demonstrated a capability to implement critical aspects of emergency preparedness during simulated and actual emergency events.
However, the licensee's performance during emergency exercises indicates a need for
,
increased management attention to assure improvement.
{
t One violation was identified.
2.
Performance Rating
Category:
j i
3.
Recommendations
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The licensee should re-examine the effectiveness of their I
corrective action program in light of the repeated failure to make followup offsite notifications from the control room.
An increase in NRC inspection effort is warranted.
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E.
' Security 1.
Analysis
.This functional area evaluates the _ adequacy 'of the security-program to provide protection for-plant. vital - systems and equipment. ~ The scope of this assessment includes all licensee activities associated with the security plan and implementing
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procedures, management effectiveness, security audit program, records and reports, testing and maintenance, access control, physical barriers, detection and assessment, armed response, alarm stations, power supply, communications, and compensatory measures for degraded security systems and _ equipment.
_The'
evaluation is based on inspections and observations throughout-the assessment period.
Authority and responsibilities associated with the security organization were clearly delineated and effective.
The site's contract security force is adequately staffed and appropriately trained and equipped.
Security personnel observed in the
-
performance of their duties were knowledgeable, alert, and capable of implementing instructions - and exercising proper judgement relative to assigned security tasks.
The facility Guard Trainicg and Qualification Plan is implemented on a continuing basis at all levels of the security organization using the onsite training staff.
Members of the onsite training staff appear. capable and motivated.
Security management continues to demonstrate awareness of, and participation in, security force activities.
Both' site and corporate security managers are responsive to security program needs and aggressively seek-effective and lasting solutions to security-related problems.
Effective communications and
,
managerial interface between the proprietary security' management staff and the contract security force management is evident.
The-licensee's upper management support was demonstrated during a time of utility personnel reductions, in that the security force management personnel allotment increased.
During this rating period the security function was realigned directly under
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the Plant General Manager.
The licensee has provided the security force with adequate procedures.
Security plan changes are submitted on a timely basis and licensee records are complete, well maintained, and readily available.
The licensee continues to log and report, as appropriate, physical security events in accordance with 10 CFR 73.71.
Event reports are prompt and complete.
The licensee is responsive to NRC Notices / Bulletins on NRC concerns i
presented in reports.
Problem solutions and written responses are technically sound and through.
The licensee implements and
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V maintains an adequate program for the protection of safeguards
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information.
-The licensee maintains an effective audit program that has contributed to security program improvements through identifica--
tion of deficiencies and areas needing enhancement. _ The
,
licensee continues to aggressively audit contractor's background screening ' programs and to require imaediate correction of identified inadequacies.
During this rating period two non-cited violations were identified:
the inattentiveness 'of_ a - guard posted as a -
compensatory measure for a degraded vital area barrier; and the failure to report this event in a timely fashion.
Both were identified by the licensee and corrective measures were promptly implemented.
No violations were identified.
2.
Conclusion:
Category:
l 3.-
Board Recommendations:
The reduced level of inspection effort should continue in this
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area.
F.
Engineering / Technical Support l
1.
Analysis The Engineering / Technical Support functional area addresses the.
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adequacy of engineering and' technical support for all plant activities.
It. includes licensee activities associated with plant modifications, technical support.provided for operations,-
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maintenance, configuration management, and licensed operator
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training.
This evaluation-is based on routine and special inspections conducted by the NRC in this area and related functional areas.
The Diagnostic Evaluation team assessment, the Maintenance team inspection, and the special audits of the Safety Parameter Display System, the Detailed Control Room Design Review, and the Station Blackout Rule were conducted during this assessment period.
During the assessment period, the licensee continued its reorganization of the engineering orgcnization.
This reorganization was completed near the end of the assessment period.
It included the transfer of design functions offsite to the corporate Nuclear Engineering Department and consolidation of the site engineering function under Technical Support.
The
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changing internal and external-interfaces during the organiza-tional transition hampered communications vithin the Engineering and Technical Support organizations, and between the plant staff and Technical Support.
These communication weaknesses were evident on several ' plant, issues and activities.
Examples a
include:
problems with corroded service water pump lubricating water. pipe supports not being clearly communicated. to
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management; the delay in identifying a Limiting Condition for Operation due to Operations not interfacing with Technical Support about RCIC injection valve problems;- and the delay of about two weeks in completing the November 1988 Unit I reload outage, because of ~the need to complete a reactor vessel level indication modification was not adequately communicated within the engineering organization.
The licensee's program for design. change development was inadequate due to - a weak design base information resource, inadequate interface definition, outdated procedures, and unavailability of preoperational test data.
The problems of.
unavailable preoperational test data and deficient safety system design bases information which were identified during the
licensee's 1987 self assessment of the HPCI system, were i
similarly identified in the service water design review
!
performed by NRC in April 1989.
Due to insufficient or
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' fragmented design records, modification reviews and engineering
!
decisions were based on engineering judgements rather-than updated design documents.
Program procedures were not updated to correctly reference defunct and existing design groups and their responsibilities.
This programmatic deficiency to provide j
clearly defined interfaces contributed to the. communications weakness previously discussed.
A noted strength of the design program was the quality of the system descriptions.
While these system descriptions did not contain. complete design basis information, they provided good reference material to the licensee's staff.
Minor design change implementation deficiencies were also identified during this assessment period.
Administrative close out of modifications was untimely.
Following physical implementation, design packages were found which were not i
closed, pending procedure revisions.
On the average, these l
design change packages had been open for two years since being i
implemented in the plant.
Applicability screenings of design changes for 10 CFR 50.59 evaluations did not consistently identify if a modified system or component was addressed in the-Final Safety Analysis Report.
A modification implementation to residual heat removal (RHR) system pump room coolers deviated from the design change package functional test procedure and acceptance criteria without appropriate evaluations.
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The. engineering and technical support organizations have-demonstrated some progress in processing - the extensive
- engineering work request (EWR) backlog identified in the previous assessment period.
The initial review and disposition for the bulk of the backlog has been completed.
The result of
this disposition was that_-the content and safety. significance of the backlog has been identified.
Generally, the volume of the J.-
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EWR backlog has not decreased, but has been advanced one major step: on the process to completion.
This represents ~a significant effort-by the organization in eliminating the backlog.
The process to implement the dispositioned EWas was c
slow and lacked effective monitoring, indicating that the process requires additional management attention.
An additional weakness identified in the EWR backlog reduction program was the r
failure.to initiate activity to fully address the material
~
problems identified-by the disposition review.
Approximately 50 percent of EWRs were due to material problems and obsolete
,
parts.
To address this problem the licensee expanded their
'
obsolete equipment program and submitted a request at the end of the assessment period to budget completion of design EWRs by 1990.
Engineering support for several service water issues during=this assessment period was not_ aggressive, but was dependent on event'
visibility and-generally reactive in nature.
Specifically, the.
licensee had numerous opportunities-in the past to identify and correct existing service wai,er flow distribution and capacity inadequacies, as well as problems involving service water pump -
motor life time.
It was not until NRC raised questions in these
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' areas that-the licensee formulated a project team to resolve the deficiencies.
Another weakness in the ' technical support area involved vendor information not being reviewed and processed in a timely manner.
In contrast to the above, effective technical support by the onsite and corporate engineering staffs was demonstrated on a number of issues.
For example, resolution of technical issues such as crack indications identified in reactor vessel nozzles
'
and RHR valve erosion problems were indicative of effective '
inspection, good engineering participation, and management involvement.
The investigation activities associated with Rosemount 510 trip unit failures, the core spray pump motor failure, and the June 17, 1989 loss of offsite power event were also effective.
Significant modifications made to the DC motor operated valves and HPCI systems have improved their performance and reliability.
The frequent presence of corporate design engineering management onsite was a positive initiative resulting in improved real time awareness of plant operating and equipment problems.
During the assessment period, NRC reviewed the implementation of such requirements as the station blackout rule and the NUREG 0737 detailed control room design review and
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L safety parameter display system.
Although the audit reviews
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indicated that' further. system modifications were needed,-it was y
apparent that~ a considerable amount of-technical support was
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. utilized.
-During the first half of the' assessment period, the system-engineering program continued to be weak.
The. effectiveness of this program had been affected by high turnover rate, inadequate training, a large number of collateral duties,. and a lack of direction from management.
Additionally, system engineers'
familiarity with current and previous system problems was-limited due to responsibility changes.
In regard to these problems, the following_ improvements were in place during the-
"
latter. half -of the assessment period:
a reduction of system engineer collateral duties to permit greater focus on system responsibilities'(i.e., procurement and design activities were
'
assigned to corporate design engineering);- the establishment of a position description, duties, responsibilities, and necessary training for the system engineer; and the requirement for system L
engineers to review plant trouble tickets daily in on der to improve their knowledge of current system conditions.
. Additional actions to further improve the effectiveness of the -
system engineer are planned by the licensee.
As previously-indicated, improvements in system engineering investigation and root cause determination were seen during the last half of the l
assessment period through the resolution of such issues as the RHR valve erosion problem and the core spray pump motor failure.
During-this assessment ' period, no inspections were conducted of licensed operator training.
One operator licensing initial
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examination was administered by the NRC this period.
Nine reactor operator examinations - were administered with eight candidates passing.
All nine senior reactor operator
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replacement examination candidates were successful.
No
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'4 requalification' examinations were administered.
The quality and
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useability of facility reference material provided for the preparation of the November 1989 initial examinations was significantly improved over previous submittals.
,
Improvement efforts on the Brunswick simulator continued this L
assessment period.
Several simulation models have been
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extensively upgraded and progress continues towards resolving-deficiencies in thermal hydraulic (boiler) and core. models.
Acceptance testing of these upgraded models is scheduled during the next assessment period.
A large number of deficiencies have been corrected by the modifications which have been implemented since August 1988.
Further upgrading is planned in order to meet the certification standards.
There improvement efforts demonstrate manager,:ent's commitment to improve the plant specific simulator.
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e Two violations were identified.
2.
Performance Rating o
Category:
3.
Recommendations Based on. the mixed performance in this area, the Board had t
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difficulty in determining -the final performance rating.
' Management needs to continue the implementation of corrective
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action programs that improved performance in this area during
,
the latter part of the assessment period.
Inspection effort in this area should remain high.
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G.
Safety Assessment / Quality Verification
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1.
Analysis This functional area includes a review of licensee implementa-tion of safety policies, activities related to license amendments, exemption and relief requests; responses-to generic letters,: bulletins, and information notices; and resolution of
~TMI items and other regulatory initiatives.
Also included were reviews of licensee resolution of safety issues,10 CFR.50.59 reviews, 10~CFR 21 assessments, safety review committee and self assessment activities,. industry's operational experience, root
cause analysis of plant events, use of feedback from quality assurance, and self assessment programs.
In addition to routine inspections, the Diagnostic Evaluation team also assessed the area of quality programs.
Management involvement in safety reviews has improved since the last assessment' period.
This improvement is attributed to an increased management presence in the power block and a demonstrated willingness to make thel hard decisions.
Delaying the restart of Unit 1 until the necessary fire protection modifications could be made, rather than relying on compensatory mea *,ures, demonstrated the proper focus on plant safety.
The co'rective action program was also modified by plant management t6 more clearly dafine the program and-process for the identification and resolution of conditions adverse to quality.
This included identification of event or equipment failure root causes.
At the end of-the assessment period the licensee also appointed a technical assistant to the Plant General Manager responsible for coordinating the site corrective action process.
The licensee correctly categorized, evaluated, and dispositioned several safety issues during this period.
These included the erosion / corrosion problem identified on some RHR isolation valves and the issue involving deformed flow restrictir:
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-orifices.
In:both cases the specific problem was identified,
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the necessary repairs were made, the root cause established, and
.long term corrective action. put in place.
The licensee identified a software error in the motor actuator characterizer (MAC) software provided by Limitorque.
This-discovery was largely due to the licensee's exhaustive efforts to determine why the indicated MAC torque value to open the Unit 1 HPCI injection valve, was greater than that calculated by the valve p:
. manufacturer.
Their efforts included-using a valve diagnostic E
system provided by another manufacturer and sending the valve and its ' actuator to Limitorque for _ bench testing.
The
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performance of a HPCI full flow injection test, the evaluation of main steam isolation valve pit environmental qualification concerns, the 1A core spray pump motor failure assessment and the willingness to send failed components to their Harris E&E center for evaluation demonstrated a willingness by licensee management to_ determine the root cause of detected deficiencies.
In spite of these improvements in their ability to adequately.
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assess the safety significance of discrepant conditions and take the appropriate corrective action, weaknesses still existed
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during this assessment period.
On several occasions safety reviews lache'l the necessary rigorous questioning.
Safety reviews were also hampered by the licensee's failure to get the.
right people involved when issues emerged.
Previously identified concerns in the service water system,. involving motor
'
overheating and the failure to isolate a nonsafety flow-path
<
during LOCA conditions, were incorrectly evaluated by-the licensee's staff.
When questioned by the NRC, the licensee concluded that sufficient service water flow was not available to the RHR heat exchanger u'nder all design basis accident
,
conditions.
'
Once an. issue was properly categorized and the appropriate levels of plant management were aware of the discrepant l
condition, actions to resolve the issue were normally extensive.
The licensee's M0V task force and the service water lubricating water piping support corrosion deficiency illustrates this point.
The M0V task force reestablished the design basis for every safety'related MOV in the plant after they had experienced numerous DC MOV failures.
In the case of the corroded lubricating water supports, corroded areas were repaired and the as-found configuration was analyzed.
This included testing to
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verify the acceptability of the as-found configuration, once plant management recognized the extent of the problem.
However, a week passed and NRC involvement was required before the problea was adequately addressed.
The licensee's corrective action program was improved through the site wide implementation of a corrective action procedure.
This improvement included a site wide policy on root cause w
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determination.
These improvements addressed the historical problems of:
lack
? depth in root caust analysis; failure to p-operly elevate p vblems to the proper management level; and feilure to timely correct problems.
Examples of the above oroblems include inadequate standby qas treatment supports that were found, but not promptly corrected, and a low suction pressure trip on HDCI that was not by passed (or over one year in spite of a JPCI safety system functional inspection recommendation.
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The licensee's reporting program was fully functional.
LERs adequately described all major aspects of reported events,
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including all component or system failures that contributed to
the event and the significant corrective actions taken or
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planned to prevent recurrence.
Report detail was extensive and
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L multiple supplements were issued when necessary.
The licensee's
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program for reporting defects and noncompliances required by 10 CFR 21 was effective.
A minor problem was identified in the reportability assessment of engineering work requests, in that
the reviewers lacked appropriate training.
The Onsite Nuclear Safety (ONS) group's impact onsite had
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diminished during this assessment period due to reduced staffing.
In addition, some reviews of scram investigation
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reports conducted by ONS were not independent.
ONS did issue outage event reminders to help reduce personnel errors.
Some deficiencies were also identified in the reviews conducted by PN * C.
In particular, the Technical Specification interpretation of the minimum required of fsite tn onsite electrical circuits and the review of primary containment isolation valves were inadequate.
'
Onsite quality assurance QA activities were focused on activities which provided meaningful'information.
An increased
,
trend toward performance based surveillances was evident.
The
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QA group thoroughly inspected issues involving emergency diesel generator fuel oil shortly af ter the NRC Temporary Instruction
was issued, sho":ing responsiveness to NRC initiatives.
..
The licensee identified some significant problems through p
several internal reviews during the assessment period; L
demonstrating a willingness to find and correct weak areas.
The
'
l corporate QA audit focused on Appendix R compliance and found several significant problems which are discussed in section
,
IV.A.
The company also underwent an Organizational Analysis ano an assessment by an outside consultant to address overall plant
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performance.
The licensee's responses to Bulletins and Generic Letters have
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been timely and met staff requirements.
There was only one case in which the licensee's response was slow.
The response to
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Bulletin 88-07 concerning thermal i /dreulic instability was
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noted.
In general, licensee requests were provided in adequate
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time fcr the staff to resolve the issues and meet the licensee's p
needs.
A few requests were untimely.
Examples include:
the-l Code relief request regarding traversing incore probe shear l
valves which was submitted only a few days before Code required l
testing; and the exemption for. Type A testing which was submitted on a schedule too tight to permit adequate staff I
review.
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The ' licensee's licensing and engineering / technical support personnel worked closely with the staff to resolve a number of old amendment requests.
The licensee's response to staff
requests for additional information was prompt and technically
.
sound.
The licensee also demonstrated that their management was
)
actively involved in the management and control of Technical
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Specification change requests.
The submittal supporting a
request for changes to plant Technical Specifications to reflect a proposed modification to the fire detection instruments in the
diesel generator building was well prepared, allowing the staff i
to complete the review without an addit.ional request for
.
information.
i Despite the ongoing industry debate regarding the Alternate Rod L.
Injection diversity issue, the licensee was res90nsive to NRC
'
initiatives.
They committed to enhance the current. ATWS system l
design by replacing the existing-Rosemount trip units with
.
I compatible, fully qualified boards manufactured by a different vendor.
,
Six violations were identified.
2.
Performance Rating
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L Category:
'2
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j 3.
Recommendations I
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Performance in this area was not consistent.
Management I
attention was readily evident in some areas and not sufficient in others.
A high level of inspection effort should be
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maintained.
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V. SUPPORTING DATA
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A.
Escalated Enforcement Action
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1.
Civil Penalties L
Severity Level III violation i :;aed on December 30, 1988, for t
inadequate corrective actions and non-conservatism regarding l
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DC motors, silicon bronze bolts, and HPCI/RCIC instrumentation.-
l ($75,000 CP) - (This problem was addressed during the last assessment period.)
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Two Severity Level-III violations issued on March 16, 1989, for L.
secondary containment systems not being operable while sipping
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fuel during the Unit 1 outage.
($150,000 CP)
{l 2.
Orders None B.
Management Conferences Septemmber 7, 1988 Manages,ent meeting at NRC Headquarters to dis;;uss licensing actions needed for refueling of Unit 1.
September 8, 1988 Enforcement Conference at Region II to dis::uss corrective actions and non-conservatism regarding DC motors,. silicon bronze bolts and HPCI/RCIC-instrumentation.
November 21, 1988'
Management meeting at the Brunswick Media Center to discuss SALP Board Assessment.
November 22, 1988 Management meeting at NRC Headquarters to discuss activities undertaken at the Brunswick site to improve overall operation December 9, 1988 Management Meeting at NRC Headquarters to discuss identified cracks in the Unit I recirculation l-systcm safe ends.
January 10, 1989 Management Meeting at NRC Headquarters to discuss RHR valve degradation by erosion at Brunswick i
Nuclear Plant.
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January 13, 1989 Enforcement Conference at Region 11 to discuss i
two events on Unit 1 which resulted in an
!.
unrecognized loss of secondary containment integrity while irradiated fuel was being moved for sipping.
January 17, 1989 Management Meeting at Region II to discuss-progress of long-term corporate and plant appraisal program, as appraised by CRESAP.
February 22, 1989 Management Meeting at NRC Headquarters to discuss the characterization and imposed actions for cracks in the Unit I recirculation system safe ends, a::
_ - _ _ _ _ - _ _ _
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j March 10, 1989 Management meeting at Region II-to discuss-the
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progress of the Nuclear Management aM
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Operational Effectiveness Appraisal of Brunswick
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and CP&L in general.
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May 8, 1989 Management Meeting at the Brunswick Site to i
discuss the final. recommendations-from the.
l Nuclear Management and 0perational Effectiveness b,.
Appraisal of Brunswick Nuclear Plant and
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Headquarters Support Functions.
June 13,-1989-Management Meeting at NRC Headquarters to discuss
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Unit 2 Recirculation Pipe Replacement.
'
im July 11, 1989 Management Meeting at CP&L Corporate Office to
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discuss ongoing efforts to improve performance of
.;
the Brunswick facility.
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August 18, 1989 Management Meeting at NRC Headquarters to discuss the June 17, 1989 loss of off-site power event at Brunswick Unit 2.
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N.
.C-
-Confirmation of Action Letiers
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None t
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D.
Review of Licensee Event Reports (LERs)
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During the assessinent period, 53 LERs for Units.I and 2 were
!
analyzed.
The distribution of these events by cause, as determined by the NRC staff, was as follows:
i Cause Unit 1 Unit 2 Total Component Failure
6
.
Design
2
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Construction, Fabrication,
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or Installation
2
I Personnel
Operating Activity
1
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Maintenance Activity
1
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Test / Calibration Activity
6
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Other
0
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f Out of Calibration
0-0
Other
1
Total
19
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Licensino Activities In support of licensing activities, meetings were frequently held with the licensee to address licensing and other technical issues.
Significant licensing issues during this assessment period included:
Valve Body Thinning; PRA/PRA Fire Analysis; Nitrogen Pneumatic System; Second Ten Year ISI; Diesel Generator Block Loading and Building Cooling Supply Fans; ATWS; Service Water System Operability; IGSCC; and SAFER /GE STR.
' Thirty license amendment requests were issued, of which most significant were:
Unit 1 Reload; Deletion of Instrument Tag Numbers and TS Format tipgrading; Type A ILRT Method; Rosemount Trip Units; Elimination of ' Cycle Specific Variable; Control Rod Bank Position; Primary Containment Airlock;- Spent Fuel Storage; Main Stack Radiation Monitor.
!
'
F.
Enforcement Activity
!
NO. OF DEVIATIONS AND VIOLATIONS IN EACH
"
SEVERITY LEVEL FUNCTIONAL V
IV III II I
AREA i
.
Plant 0perations
7
0
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Radiological Controls
0
0
r Maintenance / Surveillance
4
0
0
0
,
Security-
0
0
,
Engineering / Technical 1.
0
0 Support Safety Assessment / Quality
4
0
.
Verification i
TOTAL
16
0
h G.
Reactor Trips Unit 1
.
Two automatic scrams with power greater than 15 percent occurred:
October 21, 1988 - The unit tripped from 27 percent power while reducing power to repair the RWCU inboard isolation valve.
Because
'
,
of a switch contact problem, a false low vessel level signal was
-
generated when shifting from three element to one element feedwater level contr '
~'ils resulted in a sensed steam flow / feed flow
mismatch,...uine trip on high vessel water level and reactor scram.
November 10, 1988 - The unit tripped from 71.6 percent power during the performance of the weekly power / load unbalance test.
The trip
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was attributed to electrical noise in the turbine control valve fast closure circuitry.
Five RPS actuations occurred with the unit subcritical and all
.
.
control rods inserted.
!
December 14, 1988 - The failure of a Scram Discharge Volume (SDV)
high level switch to reset caused a RPS actuation when the SDV high
,
water level bypass switch was taken to normal by the operator.
February 7, 8 and_ twice on 11, 1989 - Spurious electrical noise caused IRM upscale trips causing a full RPS trip since the shorting links were removed.
Unit 2 Onq automatic scram and one manual scram was initiated with power greater than 15 percent.
November 16, 1988 - The trip of topaz inverter, which supplies power to one channel of the feedwater level control system, resulted in an indicated steam flow / feed flow mismatch, turbine trip on high vessel level and reactor scram from 100 percent power.
During the trip, HPCI initiated, injected water into the vessel and tripped on low suction pressure.
. lune 17, 1989 - The unit was manually scrammed from 76 percent power in accordance with the requirements established by Bulletin 88-07 (Thermal Hydraulic Instability) when both recirculation pumps tripped following the loss of the unit's startup auxiliary transformer.
During the resultant loss of offsite power, all diesels started, diesels 3 and 4 loaded on their respective emergency buses, the licensee declared an unusual event and activated the TSC until offsite power was restored by backfeeding through the unit auxiliary
,
I transformer.
One RPS actuation occurred with the unit subcritical cod all control reds inserted.
November 16, 1988 While recovering from a scram, the unit
-
experienced another RPS actuation on low vessel water level due to problems encountered with the startup level control valve feeding the l
vessel.
A procedural inadequacy caused a high D/P across the valve, preventing valve motion.
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Activity Released (Curies /2 Units)
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1st half
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Liquid.
of 1989 1988 1987 1986-
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. Fission and Activation Products:
1.37E+00 8.32E-01 7.15E-01-1.26E-01l
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-Tritium 7.45.E+00 3.10+01 1.93E+01 5.78E+01 V
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Gaseous
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Fission and Activation
. 4.51E+04'
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Gases 6.52E+02 1.58E403 2.64E+04 h
2. -
8. 70E-03 2.27E-02 5.01E-02 1.46E-02 I
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Particulates 2. 29E-02.1. 54E-01 1.32E-01 3.23E-02 i
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Tritium 2.54E+00 5.55E+00 6.06E+00 7.07E+00 j.
b Abnormal Releases
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