IR 05000324/1990023
| ML20055H416 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/11/1990 |
| From: | Russell Gibbs, Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20055H412 | List: |
| References | |
| 50-324-90-23, 50-325-90-23, NUDOCS 9007260175 | |
| Download: ML20055H416 (9) | |
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NUCLEAR REGULATORY COMMisslON '
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. port Nos.: L50-3E5,324/90-23 4 Re s,
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M LLicensee:
Carolina l Power and Light Company
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W4 P.O. Box 1551
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Raleigh, NC ;27602:
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' Docket Nos.: 50-325 and 50-324 License Nos.: OPR-7.1 and DPR-62-
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' Facility Name: Brunswick 1 and 2
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ilnspection Conducted:. June 311-15, 1990-j
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Insp'ectors:Nert -)/ s
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. Ron Gibbs, Team Leader Da'te' Signed
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n%f Team Members:
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W-B.'Breslau.
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' Approved by:
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W Ope ograms ection, J
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SUMMARY
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3;it LThis: routine, announced ' inspection 3was conducted to review the status of-i
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. ther corrective action program ror problems ' identified-by site issued
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. Engineering 1 Work Requests -(EWRs).
The inspection.was' conducted.to provide-
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h Tan: in-depth. review of the area due to concerns raised ; by :the~ Diagnostic L.
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' Evaluation L Team - (DET):' Inspection - and' concerns! ~ identified; in, inspection W
report 50-325,324/90-21.
Additionally, the inspection reviewed the corrective Tt actiont' to L the violations? in the : area identified in inspection ' report
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'50-325/87-32,50-324/87-31'.
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7M In ? the iareas inspected. no-violations. or - deviations 1 were identified.
The
" inspection concluded that the/ licensee has adequate control' over EWRs. ' All
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3 commitments 1 for-corrective action to the: violations 'infinspection report
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50-325/87-32, 50-324/87-31 were met by the licensee. The backlog of open EWRs D
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e hast been' reduced to a: manageable -level.
The status of open deficiencies is creadily apparent, and corrective actions, although slow in some cases, appear to: be -progressing at an acceptable rate.. Administrative controls have been:
Lissued:to require operability and reportability-determinations be made in a
timely fashion; tand also to require' timely 'ei.gineering evaluations be made to 1 resolve:: deficiencies.-. These requirements are being followed.
Deficiencies
m are :being prioritized in.'accordanc'e with the new corporate prioritization
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" system, which appears to properly establish priorities based on the importance
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- of',each.1 tem to :nnclear safetv.
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9007260170 900711
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REPORT DETAILS a
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Persons Contacted Licensee Employees
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. K. Altman, Regulatory Compliance Manager
- S. Callis,;On-Site Licensing Representative
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- A..Cheatham, E&RC Manager
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- K.- Core, Control and Administration
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- W. Dorman, QA/QC Manager
- C. Gray, Control"and Administration
- J. Harness, Plant General Manager
- J. Harrell,' Outage Management & Modifications Project Manager
- W.: Hatcher,- Security Supervisor
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- A.:Hegler, Radwaste Supervisor
- R. Helme, Technical Support Manager
- J. Holder, Outage Management & Modifications Manager
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- T.' Jones, Regulatory. Compliance Senior Specialist
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- J.. Kelly, Outage Management & Modifications Support Manager
- L.' Martin, Brunswick' Training Unit
- *D.
Moore, Engineering Unit Manager (NED.*W. Martin,- Onsite' Nuclear Safety. Actin o
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. J. Moyer, Plant General Manager Technical Assistant
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^V. Wagner, Outage Management & Modifications
- R.' Warden, Maintenance Manager
- C, Willetts, Control and Administration-
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Otherflicensee employees contacted during this inspection. included
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engi_neers and administrative personnel.
q NRC Resident Inspectors
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- B. Levis, Resident inspector
.D. Nelson, Resident Inspector
- Attended exit interview
Acronyms used.throughout this report are listed in Appendix A.
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L2L EngineeringWor_kRequest(EWR) Review
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.a.
Background
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Inspection report 50-325/87-32,50-324/87-31 identified four Violations concerning corrective action for deficiencies identified by site EWRs.
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Similar concerns were identified by the DET in paragraph 2.1.6.6 of
.their. report.
Again, during inspection 50-325,324/90-21 additio W concerns were raised in the area. As a result, a separate inspection 7 /
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to review the EWR area was scheduled for the week of June 11, 1990.
This report provides the results of that inspection.
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h Viohtions three and-four of inspection report 50-325/87-32, 50-324/87-31 were previously closed in inspection report 50-325 -
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324/90-21... The first two violations remained open in' that inspection ~
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pending the results of this' inspection..
The-first violation
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-(50-325/87-32-01, 50-324/87-31-01) -reported.:a' programmatic problem
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concerning inadequate' and untimely corrective action for deficiencies m-identified by site EWRs.
The second violation (50-325/87-32-02, H
50-324/87-31-02). reported a programmatic problem concerning'. lack of l
. formal engineering evaluation, including evaluation for operability-f and -reportability, of ' deficiencies identified.by site EWRs; The licensee's corrective action for these violations (in-part) included i
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L(1) Revision-of the administrative procedure for EWRs (CNP-20,
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Engineering Work Requests (EWR)) to:
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(a) ~ Firmly' establish the EWR as a corrective action document j
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L corrective action.
l (b) Streamline the EWR program and eliminate items from the.
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program which were inappropriate for an EWR.
This actior
resulted in the development of the Technical Services
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of Technical Support Memorandums).
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.(c) Provide for an operability and reportability determination.
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for EWRs sithin five days, and to provide a written final
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(d)
Provide for prioritization of; EWRs based on:their safety-significance.
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(2)- Review of = the backlog of EWRs based on a Nuclear Safety Board Y
Index (NSBI), established by management, to determine the safety
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significance of each item in the backlog.
This review resulted in the conclucun that no immediate operability problems existed,.
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however. approximately 300 items in the backlog were categorized c
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as having some safety significance (the actual number was 224
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items).
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(3)- Disposition.of the EWRs with safety significance (NSBI index 4 -
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10) by September 12, 1988 and disposition of the remaining
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backlog by February 12, 1989,
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Inspection Scope The scope of this-inspection, therefore, was_ based on these corrective
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actions,'and. included a' detailed review of the status of approximately 1~
one hundred EWRs.. The inspection approach was designed'to-review the-backlog;of old EWRs,. as well as, to review current EWR practices.
Details oflthe inspection scope were as follows:
-(1)1The inspectort reviewed all EWRs, from the NSBI most safety -
significant listing of 224 items, which were still shown as open p.
on the licensee's current computer-listing _of open EWRs and PIDs.
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This review was conducted to determine what progress had been
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- made. in closing out of the deficiencies.
The review also i.
determined-.the status of funding approval for items which had not been physically. corrected in the plant.
The following-EWRs were reviewed:
L EWR-02219 EWR 02963 EWR 03351 EWR 03411
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_EWR 03778 EWR 03780 EWR 03811 EWR 03815
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i lEWR 04270 EWR'04320 EWR 04393 EWR 04688 E
EWR 04793-
-EWR 04805 EWR 04845 EWR 05413 L
EWR 05679?
EWR 05704 EWR:05806 EWR 05856 EWR 06078 EWR 79-559 EWR 80-154 EWR'80-203
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l EWR 83-153 EWR 83-783 EWR 84-149 EWR-84-254
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EWR 84-489:
EWR 84-595 EWR 84-648 EWR 84-849
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EWR-03729 EWR 03973
'EWR 04689
lEWR 05589 EWR-06001
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EWR 82-430-
~EWR 84-265 EWR 84-912
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'(2) The inspectors reviewed a sampling of EWRs, from the NSBI' most-safety significant listing of,224 items, which had been closed
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out and'were not shown on the^ listing of open EWRs or PIDs.
i This. review was conducted to determine how'the deficiencies-had
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EWR 80-308 EWR 82-117-EWR 83-421 EWR 83-620
EWR-83-784 EWR 83-1550 EWR 84-572 EWR 84-1024
'EWR 02300-EWR 03374 EWR 04443 EWR 05218 EWR 05400A-EWh 05869A EWR 05880A EWR 05904A i
EWR 83-670
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EWR 01230
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EWR 05265
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EWR 05961A ofs N,';
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e (3) All EWRs issued during February,1990 were reviewed to verify operability-and reportability evaluations,were being conducted, n
.and to verify that final disposition of-the items was: being -
provided as required. by the current site procedure (ENP-20,
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o Rev.11).
(4) - All TSMs. issued during February,199v i reviewed to verify that EWR type problems were not being reported on TSMs : and to:
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- verify. that any deficiencies being reported were receiving; appropriate corrective action.
c. Conclusion Overall, 'the-inspectors conciaJed that the. licensee had adequate control lover EWRs.
All commitments for corrective action to the?
violations were met by the licensee.
The backlog of open EWRs. has
- been reduced to a manageable level. The status of open-deficiencies is - readily. apparent, and corrective actions,1although slow in-some
= cases, appear to.be progressing at an acceptable rate.- - Administrative controls have Lbeen issued to-require operability. and reportability-determinations _ be.made in a. timely fashion, and tlso to require timely engineering evaluations be made tm. resolve deficiencies.
These.
requirements are being followed.
Deficiencies.are being prioritized u
in accordance with the new corporate prioritization system,-;which appears to properly establish priorities based on the importance of eachiitem to nuclear safety.. As a result, the violations and DET
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items which relate to this' area are closed.
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In spit ( of the-fact that the open items -are being closed, several-weaknesses were noted which require continued attention by the licensee:
(1) Action on several of the deficiencies reviewed had not been taken by the licensee for some period of' time until-the week just prior.
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to this inspection. This problem was discussed with the licensee
with emphasis on. independent action by. the-licensee without i
involvement of-the NRC.
The licensee stated that no action had been taken on those types of items'because the semi-annual reviews and reports to management on the status of EWRs, required by site-procedures and which were designed to detect that ty p of problem,.
had not been performed in 1989. The licensee-issued a deficiency m-report (Item of Concern) to document the lack of compliance with the site procedures L in this area, -ano stated that the reviews
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would be completed in the future.
(2) There were some items remaining open in the backlog, which could i
easily be corrected without significant funding, which had not been addressed because of a low priority assignment. With this
in mind, the inspectors alerted the licensee to the possibility
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-that lower priority items could change responsibility from group to group within the plant staff and not receive adequate attention due to p.riority assignments alone.
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"lP (3)' There'were-some items:that had. received an engineering evaluation e
which indicated' only that another_ engineering evaluation was :
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required to resolve the item. _ The licensee agreed that:this was T.w poor practice and was being done only to meet the 40 day evalua-
- tion requirement' of ENP-20.
The ? licensee and the inspectors
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agreed _-that proper way to handle. an item, which cannot be
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evaluated within the. 40 days, is to process an extension for
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plant manager approval.
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-(4)T After extensive review of the EWR backlog the inspectors concluded that there are many items in the~ backlog that individually do not.
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pose immediate operability concerns, but are, nevertheless.-very J
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important to the safe and reliable operation of the Brunswick
units. The. licensee' agreed with this assessment, and noted that
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many fof theLplant modifications currently budgeted' were to-correct'those deficiencies-
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ActionsonPreviousinspectionfindings.(92701,:92702)
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'(Closed)iViolation 50-325/87-32-01, 50-324/87-31-01, Inadequate corrective actions on EWRs.
This violation reported a programmatic problem concerning
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inadequate. and untimely corrective action for deficiencies identified by. site EWRs.
This item -is closed based on the
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discussion.in paragraph'2, above,
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-(C1osed) Violation 50-325/87-32-02, 50-324/87-31-02, Failure to document:EWR evaluations.
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This violation reported a programmatic problem concerning lack' of-formal engineering evaluation, including evaluation of-operability
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and reportability, for defic;encies identified by site EWRs.
This a
item is closed based on the discussion in paragraph 2, above.-
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Inspector Follow-up Item 50-325,324/89-34 31, Small
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projects budgeting-(DET paragraph 2.1.6.6 and-IAP item D.24)'.
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This item was reported by the DET as follows:
A large backlog of scheduled, but unbudgeted _ work existed in the form of EWRs and-
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PIDs.
. Approximately 50 percent of the open =(dispositioned)- EWRs
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were-due to material problems and obsolete parts, yet there' was no j
program at Brunswick to resolve the obsolete parts issue with= the exception :of direct replacement of small obsolete valves.
Also, the engineering support to complete effective corrective action of
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EWRs and PIDs was both untimely and inadequate in numerous
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instances.
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t The licensee's response _ to this-item discussed. the new nuclear.
.prioritization process, and -the new EWR _ program developed as 'a
.resulti of: the corrective actions to the violations in inspection -
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i report 50-325/87-32 and 50-324/87-31.
Follow-up-to the violations discussed in that inspection are discussed above.
.The licensee response icomitted to the establishment of-a' small project.
- budgetingEprocess, as a more responsive approach, toward working
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off.the engineering: backlog of EWRs and PIDs.
Inspector review of
thisD item determined that this commitment was met in the :1990
' budget by the authorization'of a small projects line item in the l
amount of-$401K.
Twelve small projects are. currently being worked under this authorization.
The licensee's response to this' itent
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denied :the' portion of the problem concerning Brunswick's' actions.
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on obsolete parts.
However, since the response the licensee has r
started an effort to streamline this process, and has ' developed a daaft procedure to outline this program. This item is closed.-
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(Closed)' Inspector Follow-up Item 50-325,324/89-34-42, Vendor.
j recomendations (DET; paragraph 2.1.6.7).
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The DET: reported thst; the licensee had not been aggressive in-identifying or - closing - out vendor recommendations.
Many' vendor J
recommendations :weres over 10 years old and were only _recently
dispositiened.-
Scheduling and implementation of corrective actions, once dispositioned, were also generally' delayed to the future.
Procedures ^ to control vendor recomendations were inadequate and had - not been revised to - reflect'~ current work
practices.
A previous NRC inspection, report 50-325,324/90-21, presents prior
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./n results: concerning the : adequacy of this subject area.
The? report'
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- noted that ithe' licensee was !still not aggressively processing j
vendor recommendaticns; examples of deficiencies were provided.
E SThe inspector verified, during this inspection,. that the licensee L
has incorporated ~ adequate current work practices, involving the-vendor recomendation. process, into procedure ENP-20, " Engineering
- Work Request"_,.Revislon 11.
Additional _ly, the inspector-verified j
- the adequacy of the licensee's closure acticns for nine recently.-_
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closed : EWRs.
-Closure of the remaining 19 open items is being L
- adecuttely pursued.
The licensee's actions are considered-to be i
satisfactory and this item is closed.
L 4.-
Exit 1 Interview-(30703)
i The inspection scope and' findings were summarized on June 15, 1990, with
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those persons indicated in paragraph 1.
The inspectors described the
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areas' inspected.and discussed in detail the inspection findings listed F.:
below and in the summary.. Dissenting coments were not received from
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thelicensee'. Proprietary information is not contained in this report.
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', Item. Number Status Description / Reference Paragraph =
f 50-325/87-32-01 Closed =
'VIO - Inadequate corrective actions
on EWRs paragraph,3;a.
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50-324/87-31-01
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' Inadequate' corrective actions
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on EWRs, paragraphc3.a.
50-325/87-32-02 Closed-VIO - Failure to document EWR
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evaluations, paragraph 13.b.
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50-324/87-31-02
. Closed VIO - Failure-to document EWR
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evaluations, paragraph.3.b.
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. Closed IFI Small projects. budgeting-(DET-q u
para raph 2.1.6.6 and IAP item
0.24, paragraph 3.c.
50-325,324/89-34-42 Closed IFI-Vendorrecommendations(DET
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paragraph 2.1.6.7), paragraph 3.d.
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APPENDIX B
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Acronyms and Abbreviations-r
- ,Je BSEP Brunswick Steav Electric Plant L
' DET Diagnostic Evaluation Team (
ENP Engineering Nuclear Procedure EWR Engineering Work Request IAP-Integrated Action Plan l
IFI.
Inspector Follow-up Item'
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NED Nuclear Engineering Division NRC Nuclear Regulatory Commission NSBI Nuclear. Safety Board Index PID'
Project Identifications
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QA/QC Quality Assurance / Quality Control E&RC Environment and Radiation Control TS
- Technical Specifications TSM Technical Services' Memorandum VIO Violation
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