IR 05000324/1990016
| ML20043A016 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/02/1990 |
| From: | Jape F, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20043A015 | List: |
| References | |
| 50-324-90-16, 50-325-90-16, NUDOCS 9005170197 | |
| Download: ML20043A016 (8) | |
Text
'
.
..
-.
UNITED STCTES 4 Aleg'o O
e
,
NUCLEAR REGULATORY COMMIS$10N i
' gl'
REGION ll
g f
i
ATLANTA, GEORGI A 30323
%
/e
'
.....
!
Report Nos.: 50-325/90-16 and 50-324/90-16 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.:
50-325 and 50-324 License Nos.: DPR-71 and DPR-62 Facility Name: Brunswick ~1 and 2 l
Inspection Conducted: April 2 - 6,1990
67 t_
&c.
5~ N90
!
Inspector:
!
'
C. Smith Date Signed r
-
u
_6d2/fC Approved by:
Fl'K
- A_
!
F. Jape, Section Chief 4/
/
Date Signed
,
Quality Performance Section Operations Branch l
Division of Reactor Safety
'
(
'
SUMMARY Scope:
>
,
This routine, unannounced inspection was conducted in the areas of followup
for Diagnostic Evaluation Team Findings and evaluation of licensee's corrective actions delineated in the Integrated Action Plan.
' -
Results:
I In the areas inspected, violations _ or deviations were not identified.
The licensee response to NRC initiatives as demonstrated by implementing developed corrective action plans is less than is expected.
Corrective actions for
>
short lead time items have not been completed expeditiously.
Licensee target dates given in their monthly status report does not reflect any incurred slippage for the IAP Level 2 items reviewed. Some items that were past due at
>
the time of the inspection have not been completed. Additionally, the licensee
>
did not have readily available objective evidence to corroborate verbal statements that corrective actions had been completed.
,
9005170197 900302 FDR ADOCK 05000324 Q
FDC
'
,
e
f,
'
.
.
'
s t
.
REPORT DETAILS 1.
Persons Contacted Licensee Employees
- S. Callis, Licensing Onsite Representative
- K. Core, Control and Administration
- W. Dorman, Manager QA/QC
- J. Harness, Plant General Manager
- R. Helme, Manager - Technical 5upport
- J. Holder, Manager - Outage Management and Moditications
- T. Jones, Senior Specialist Invest. - Regulatory Compliance
- W. Link, Regulatory Compliance
- J. McKee, Manager QA
- D. Moore. Unit Manager - Nuclear Engineering Department
- J. Moyer, Technical Assistant to 01 ant General Manager
- J. O'Sullivan, Manager - Training
- R. Poulk Supervisor - Regulatory Compliance
- E. Scharff, Onsite Nuclear Safety
- W. Simpson, k nager - Control and Administration
- R. Starkey, Manager - BNP Other licensee employees contacted during this inspection incledeC engineers, and administrative personnel.
NRC Resident Inspector W. Ruland, Senior Resident Inspector
- Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph.
2.
ActiononPreviousInspectionFindings(92701)
(Closed) IFI 50-325,324/89-34-01, followup on DC Motor Operated Valve Review.
The DET report documented a deficiency related to a design guide which did not provide instructions concerning the effects of thermal overload heaters on available motor torque.
Design guide DG-V.69 Electrical Evaluation of D. C. Powered Motor-0perated Valves, was revised to require evaluation of the motor overload heaters in the calculation of available torque.
Additional corrective actions required to be taken by the licensee included completion of Units 1 and 2 D.C. motor calculations.
The inspecte mified that Unit 2 D.C. motor calculations had been completed by rev iew of the following objective evidence:
i
!
. i
_ _ _ _ _ _ _ _ _ _ _ _
_
..
.
-.
... _ _
-
-
L.-
.
-
(.
,.
j
Calculation ID: BNP-E-6.060 Verification Calculation for D.C.
MOV Computer Program, Revision 1.
-
Calculation 10: BNP-E-6.017, 2-E41-F041. HPCI Suppression Pool.
=
Outboard Valve, Revision 2.
_
List of Units 1 and 2 0.C. MOVs and associated calculation numbers.
}
The. inspector determined that 26 D.C..MOV calculations had been completed for Unit 2 in accordance with the list provided.
Additionally, the-calculations for Unit 1 D.C. MOVs were in progress and were scheduled for
_
completion April 16, 1990.
Upon completion of the D.C. MOV calculations for both units the pertinent action item in EER-88-0340.will be closed. '
r The licensee. committed to completing Unit 1 D.C. MOV calculations.by April 16, 1990 This item is closed based on the completion date committed to by the licensee for Unit 1 D.C. MOV calculations.
_
(0 pen) URI 50-325,324/89-34-05 Evaluate the Adequacy of Licensee's
-.
Actions to Investigt.te System Design Integrity Issues for Safety Systems Other Than HPCI and Service Water, Including Adequacy of Preoperational'
Test Results.
Level 2 IAP items associated with IAP No. D7 have long lead time completion dates.
However, an evaluation of the status of level 2 items was performed to
-
verify that corrective actions are completed in accordance with the established-schedule. The following objective evidence was-reviewed during this effort:
Project Plan PCN-B00b'A, Brunswick Nuclear Power Plant System Design Turnover, dated 3.M 4,
,
Detail Schedule for Design Bases Turnover Prohet B0019A.
Milestone Report for Project ID: B0019A, dated January 1, 1990.
Project Plan for UE&C Piping Design Turnover Program Phase II (PCN OB0018A) and Snubber Reduction Program (PCN 05477A), Revision 2.
,
Level 2 IAP items required to support IAP No. D7.a and c were verified as having been completed or in progress.
Additionally, review of PCN OB0018A verified th6t activities related to 1AP No. D7.b were on schedule.
No deficiencies were identified during the above reviews,
(Closed) IFI 50-325,324/89-34-07, Review Statistical Techniques used for Root Cause Analysis of Field Revisions and Technical Adequacy of Corrective Actions for PM-88-019 and PM-83-143.
...... _.............
..
..
.......
.
.....
.
....
..........
.
_
.... -.
.
. - - -.. -. -
O
.
'd
Corrective actions involving development and issuance of a standard design guide for performing instrument loop accuracy calculations. and development of administrative controls for 100 percent review of field revisions were scheduled for completion.
The inspector reviewed NED Guideline Number E-17, NED Performance Modification Quality Assessment, Revision 2, and verified that provision for 100 percent review of field revisions had been specified.
A draft copy of Design Guide Number DG-VIII.50 Instrument Setpoint, was presented to the inspector.-
Discussions with licensee management revealed that the document was in the review and coment phase of. development.
Licensee management comitted to -
having Design Guide Number DG-VIII.50, approved and issued for use by April 27,1990.
This date' is seven months later than the licensee's original date of September 30, 1989, for-issuance of the Design Guide.
Implementation of the licensee's corrective action plcn for this DET finding does_not appear to be timely.
However, item 50-325,324/89-34-07 is closed based on the above licensee commitment.
(Closed)IFI 50-325,324/89-34-12, Followup on Implementation and Effectiveness of Technical Support Improvements in IAP Item Bl.
IAP Itern Bl.a required the licensee to implement Technical Support g
improvements by clearly defining and communicating it's mission and functions.
The inspector verified completion of the above by reviewing procedure ENP-01, Technical Support Organization, Revision 5.
IAP ltem Bl.b addressed consolidation and streamlining of th'e organization structure.
Pursuant to review of licensee's procedure PLP-06, System Engineer Program, and ENP-01, Technical Support Organization, the inspector '
identified inconsistencies in the organization functional responsibilities, levels of authority, and lines of internal communication interfaces.
Licensee management concurred with the inspector's observation, and prompt corrective action was taken by revising procedure PLP-06.
In-office review of the revised procedure has verified correction of these program inconsistencies.
Additional tasks related to (1) IAP item Bl.c, determine long range human resource needs and (2) IAP item Bl.d, continue system engineering development efforts, were reviewed by the inspector.
The following ob s tive evidence was reviewed by the inspector during this effort:
<
technical Support System Matrix, last update February 15, 1990.
Procedure ENP-606, System Engineer Qualification, Revision 0.
Procedure ENP-02, Sys+em Trending Program, Revision 2.
Procedure ENP-02.1, System Assessment Program, Revision 0.
Procedure ENP-03.3, Performance Testing and Plant Modifications, Revision 0.
- - _ _
Q
.
l l
O JC
.
.
Review of the above documents and discussions with licensee management revealed a vacancy rate in excess of 10 percent for the Technical Support Staff. The inspector further determined that only three System Engineers are qualified for the systems assigned to them.
Five additional Nuclear-Engineers were listed as being qualified to procedure ENP-624.
Eighty five systems have engineers assigned who are not qualified, or a vacancy. is shown on the Technical Support System Matrix.
The potential safety significance of a large vacancy rate and apparent inadequate training / qualifications of System Engineers was discussed with licensee management.
In addition to ongoing efforts to fill the above vacancies, licensee management does not_ perceive inadeouate support to the operating units caused by either issue raised by the inspector.
The licensee's activities related to IFI 50-325,324/89-34-12 is shown.in the Brunswick Nuclear Project level 2 IAP schedule'as having been completed.
The inspector determined, however, that procedure PLP-06 had not been revised to reflect consolidation / streamlining of the organization structure.
Based on the licensee revising procedure PLP-06, and ongoing efforts to correct and/or improve the vacancy rate and system engineer training, this item is closed.
(0 pen)
IFI 50-325,324/89-34-15, Followup on Implementation and Effectiveness of Outage Management Modification Improvements in IAP Item BE.
IAP Item B6.a required reassignment and/or elimination of training activities performed by BCU.
Restructuring of the BNP Outage Organization resulted in the climination of BCU when the 'new Outage Management and Modification organization was established.
The inspector reviewed the following objective evidence to assess the status of the above action item:
CP&L Memorandum from J.
R. Kelly to J. R. Holder, Subject:
IntegratedActionPlar(ItemCRA38), dated _ November 19, 1989 CP&L Memorandum from J.
R.
Kelly to J. R. Holder, Subject:
Demobilization of BCU, dated April 13, 1989.
Listing of Proceaures for Certification /Qualifiestion/ Training for CP&L and Contract Flectrical Craft
CP&L and Contract Civil Craft
CP&L.and Contract Mechanical Craft Review of the above documents along with typical training modules, M3 and M10, revealed that some craft training had been retained by the new
,
!
organization.
The inspector requested information concerning the basis for retaining craft training which appeared to be contrary to the requirement of IAP Item B6.c.
Licensee management referred to CP&L's memorandum of April 13, 1989, where the decision was made to transfer i
training functions previously performed by BCU to 0MISS-Modification
'
csoninIANtemB6!a!
"
"
"
- - _ _ - - _
_ _ - - - -
.....
... _._
--
_
s
.
-
s g
,
.
'
IAP Item B6.b required the licensee to continue efforts to evaluate alternative methods for modification / outage support.
As objective evidence for completion of this task, the licensee presented the following documents:
Outage Management Section, Outage Management Program
._
Guidelines, Revision 3.
Outage Management / Modification Section Instruction Manual.
Revision I.
Outage Management and Modification Organization Chart, dated August 31, 1989.
Based on review of the above documents the inspector determined the BNP Outage Organization to be in a transition state.
Evaluation of the Outage Management guidelines and the new organization chart revealed that functional responsibilities, levels of authority, and-lines of internal and external communication interface were inconsistent among the program M
documents.
The root cause appeared to be failure to revise the q
guidelines to reflect the new organization structure and functional responsibilities.
This item remains open pending revision of the Outage Management Guidelines and other quality implementing procedures to correct the above deficiency.
(0 pen) IFI 50-325,324/89-34-18, Followup on Correction of TS Sampling
Plan Flaw in IAP Item D1-4 and Determine it's Effectiveness with Respect i
to Periodic Reviews of TS Requirements ISI/ App si and commitments.
IAP Item D1.d required the licensee to develop an improved sampling plan for QA surveillance of TS requirements.
The inspector verified the status of this item by review of the following objective evidence:
T.S. Sampling Plan, approved May 26, 1989.
'
File No.17510, Surveillance Report No.89-082, Document Sampling Selection.
CP&L Memorandum CQAD 89-1271, Subject: Sampling Plan for Technical Specification Documentation.
The inspector determined that the statistical procedure used for TS
~
sampling was technically correct, and the samples were selected in accordance with requirements of the procedure.
The inspector was-informed that completion of the surveillance and issuance of the report is expected by April 30, 1990. The-licensee further added that this date is consistent with their commitment which was to implement the plan by the 1st quarter,1990, i
a'
_ _ _ _....
..
.
,
e
.
+
-
g,
.
.
!
!
The first trial run for sampling of TS surveillances was approximately 75 percent complete at the time of the inspection. This item is left open
!
pending (1) completion of the trial run, (2) issuance of the report and'
(3) review of the results for effectiveness by the NRC.
!
'
(Closed) IFI 50-325,324/89-34-22 Followup on Implementation and Effectiveness of Design Related Procedures Update to Reflect Organizational i'
and Responsibility Changes in IAP Item D8.
'
IAP Item DS required the licensee to complete update of the corporate and site design procedures.-
Objective eridence for completion of this corrective action was presented in the form of a listing of M0I Number, t
Title, and disposition of the instructions.
The disposition involved
,
various forms including (1) revisions to NED procedures to incorporate requirements delineated in the MOI;- (2) development of a new NED procedure; and (3) no action required.
This information was provided to
.
the inspector at the end of the inspection as considerable time was i
required by the licensee site personnel assigned to retrieve the
.
information.
A sample of NED procedures identified on the list was reviewed by the Resident Inspector upon completion of the inspection.
This review verified that the licensee had met the commitment delineated in IAP Item x
08.
This item is closed.
(0 pen) IFI 50-325,324/89-34-25, follow up on-Implementation and Effectiveness of Improvements Made to 10CFR 50.59 Reviews in IAP D11.
IAP Item D11.a required the licensee to complete development of a corporate program to ensure consistent methods for performing safety
,
reviews.
The inspector verified completion of the above task by review i
of the following objective evidence:
l Carolina Power and Light Company 10CFR50.59 Program Manual Revision 1.
The inspector determined that the.10CFR50.59 Program Manual, Revision 0, i
had been developed and approved for use.
Revision 1, at the time of
,
the inspection, was in the review and approval cycle to incorporate changes delineated on page 11.
IAP Item D11.b further required development of procedures, training
-
program, and implementation of the program with a target date of June 15, 1990.
The status of associated tasks required to support
!
achievement of the target date was reviewed by the inspector.
Objective
~
evidence examined during this effort is listed below:
'
CP&L memorandum, File:
BTU 900313003, Subject:
10CFR50.59
-
Qualified Safety Reviewer Training, dated March 19, 1990.
Lesson Number GN6C23G, Qualified Safety Reviewer Program Training.
l
-
,
.
_............ _.
. _ _ _
it
~
o
%.
.
The inspector determined that training of adjunct instructors designated to provide 10CFR50.59 training for corporate office and nuclear site personnel was scheduled for April 4 and 5,1990.
The total-number of personnel requiring 10CFR50.59 training was listed as 1007.
However, completion of sub-tier activities.. e.g., development of written exams, answer keys, and practical exams, scheduled for completion March 15, 1990, was not completed at the time of the inspection.
Licens45 management anticipates a slippage of the projected target date of June 15, 1990 because of scheduling problems for training the licensed operations staff.
This item is left open pending implementation of the training program and review of the results for effectiveness by the NRC.
3.
Exit Interview The inspection scope and results were summarized on April 6,1990, with those persons indicated in paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Licensee management was informed at the exit interview that the following
' items were closed:
URI 50-325,324/89-34-07 and IFI 50-325,324/89-34-01.
The licensee was informed in a telephone conversation on April 16, 1990, that the following items were closed:
IFI 50-325,324/89-34-12 and IFI 50-325,324/89-34-22.
Acronyms and Initialisms BCU Brunswick Construction Unit BNP Brunswick Nuclear Plant DC Direct Current DET Diagnostic Evaluation Team HPCI High Pressure Coolant Injection IAP Integrated Action Plan IFI Inspector Followup Item MOI Manual of Instructions MOV Motor Operated Valve NED Nuclear Engineering Department OMISS Outage Management Integrated Scheduling Section TS Technical Specification URI Unresolved Item
.
.
...
..
.
.
.
_.