IR 05000324/1990023

Insp Repts 50-325/90-23 & 50-324/90-23 on 900611-15.No Violations or Deviations Noted.Major Areas Inspected:Status of Corrective Action Program for Problems Noted by Site Issued Engineering Work Requests

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: IR 05000324/1990023 ML20055H411
References
50-324-90-23, 50-325-90-23, NUDOCS 9007260175
Download: ML20055H416 (9)

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UNITED STATES i g't

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',: NUCLEAR REGULATORY COMMisslON ' '

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ATLANTA.GEORotA 3M23- -6

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%p( f,, . port Nos.: s, L50-3E5,324/90-23

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M LLicensee: Carolina l Power and Light Company 4 '

W4 , P.O. Box 1551 ~

fT y{, Raleigh, NC ;27602:

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, ' Docket Nos.: 50-325 and 50-324

License Nos.: OPR-7.1 and DPR-62-g . m ' Facility Name: Brunswick 1 and 2

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ilnspection Conducted: . June 311-15, 1990- j Insp'ectors:Nert -)/ s ~7h 40 m

M . Ron Gibbs, Team Leader

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Da'te' Signed

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n%f Team Members:

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' Approved by:

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DaffSipned  ;

W Ope ograms ection, J tiDivision of actor Safety ,

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M T SUMMARY

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,a Scope:

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> LThis: routine, announced ' inspection 3was conducted to review the status of-

. ther corrective actionsprogram ror problems ' identified- by site issued

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W* . Engineering 1 Work Requests -(EWRs). The inspection.was' conducted.to provide-hM,

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Tan: in-depth. review of the area due to concerns raised ; by :the~ Diagnostic ' 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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m w '50-325/87-32,50-324/87-31'. '

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In ? the iareas inspected. no- violations . or - deviations 1 were identified. The

" inspection concluded that the/ licensee has adequate control' over EWRs. ' All i

3 commitments 1 for- corrective action to the: violations 'infinspection report 1 y' , 50-325/87-32, 50-324/87-31 were met by the licensee. The backlog of open EWRs D 4 e hast been' reduced to a: manageable -level. The status of open deficiencies is I 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 m

1 resolve:: deficiencies.-. These requirements are being followe Deficiencies

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<1 are :being prioritized in.'accordanc'e with the new corporate prioritization l

" system, which appears to properly establish priorities based on the importance

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of',each .19007260170 tem to :nnclear safet ,

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REPORT DETAILS a Persons Contacted Licensee Employees  !

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.*K. Altman, Regulatory Compliance Manager

• S. Callis,;On-Site Licensing Representative  !

• A..Cheatham, E&RC Manager '

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Core, Control and Administration ,

• 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 .;

• A.:Hegler, Radwaste Supervisor  ;

-*R. Helme, Technical Support Manager

• J. Holder, Outage Management & Modifications Manager ,

• T.' Jones, Regulatory. Compliance Senior Specialist .i

• J. . Kelly, Outage Management & Modifications Support Manager 1

• L.' Martin, Brunswick' Training Unit

< o-Moore, Engineering Unit Manager (NED.*W. Martin,- Onsite' Nuclear Safety. Actin

, * . *J. Moyer, Plant General Manager Technical Assistant

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^V. Wagner, Outage Management & Modifications

• R.' Warden, Maintenance Manager

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• C, Willetts, Control and Administration-

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Otherflicensee employees contacted during this inspection. included engi_neers and administrative personne q NRC Resident Inspectors -

• B. Levis, Resident inspector

. Nelson, Resident Inspector

• Attended exit interview  ;

Acronyms used.throughout this report are listed in Appendix =

L2L EngineeringWor_kRequest(EWR) Review .)

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. Background Inspection report 50-325/87-32,50-324/87-31 identified four Violations 4 < concerning corrective action for deficiencies identified by site EWR Similar concerns were identified by the DET in paragraph 2.1.6.6 of

.their. repor Again, during inspection 50-325,324/90-21 additio W 7 concerns were raised in the area. As a result, a separate inspection

/ / to review the EWR area was scheduled for the week of June 11, 199 This report provides the results of that inspectio l

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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 - "

324/90-21... The first two violations remained open in' that inspection ~ u

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pending the results of this' inspection. . The- first violation-(50-325/87-32-01, 50-324/87-31-01) -reported.:a' programmatic problem m concerning inadequate' and untimely corrective action for deficiencies-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

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licensee's corrective action for these violations (in-part) included i l

the following:

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L(1) Revision- of the administrative procedure for EWRs (CNP-20,

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Engineering Work Requests (EWR)) to:

1 (a) ~ Firmly' establish the EWR as a corrective action document j . and to provide the controls to ensure adequate and timely 2 L corrective action.

l (b) Streamline the EWR program and eliminate items from the.

? program which were inappropriate for an EW This actior

resulted in the development of the Technical Services 1 L

Memorandum (TSM) to-process engineering questions and to provide engineering assistance to maintenance during the 1 performance of -' maintenance . work .(Reference ENP-12' 1, Use

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of Technical Support Memorandums). ,

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.(c) Provide for an operability and reportability determinatio "

L ,~ for EWRs sithin five days, and to provide a written final 'l engineering disposition within 40 days y (d) Provide for prioritization of; EWRs based on:their safety-significanc '

(2)- Review of = the backlog of EWRs based on a Nuclear Safety Board Y

., Index (NSBI), established by management, to determine the safety significance of each item in the backlog. This review resulted

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,- in the conclucun that no immediate operability problems existed,. I l=, c however. approximately 300 items in the backlog were categorized )

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 - l

! 10) by September 12, 1988 and disposition of the remaining backlog by February 12, 1989,

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b.- Inspection Scope The scope of this-inspection, therefore, was_ based on these corrective 1~

actions,'and. included a' detailed review of the status of approximately !

one hundred EWRs.. The inspection approach was designed'to-review the-backlog;of old EWRs,. as well as, to review current EWR practice 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 on the licensee's current computer-listing _of open EWRs and PID ,

This review was conducted to determine what progress had been

! - made. in closing out of the deficiencies. The review also 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 ,

j _EWR 03778 EWR 03780 EWR 03811 EWR 03815 ,

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

, EWR 84-489: EWR 84-595 EWR 84-648 EWR 84-849 lC + '

EWR-03729 EWR 03973

'EWR 04689  ;

lEWR 05589

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EWR-06001 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 PID i This. review was conducted to determine how'the deficiencies-had 1~

1. . been resolved and to verify proper closeout. The following EWR # were> reviewed: l EWR 80-308 EWR 82-117- EWR 83-421 EWR 83-620 1 EWR-83-784 EWR 83-1550 EWR 84-572 EWR 84-1024 4 '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

, EWR 05265 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 - "

o provided as required. by the current site procedure (ENP-20,

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: !

verify. that any deficiencies being reported were receiving; appropriate corrective actio 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 close ,

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 prio ,

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,.

m had not been performed in 1989. The licensee-issued a deficiency-report (Item of Concern) to document the lack of compliance with

,s , the site procedures L in this area, -ano stated that the reviews would be completed in the futur (2) There were some items remaining open in the backlog, which could i easily be corrected without significant funding, which had not 4 been addressed because of a low priority assignment. With this

. , in mind, the inspectors alerted the licensee to the possibility-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 alon m ,. ,

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e (3)' There'were-some items:that had. received an engineering evaluation

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which indicated' only that another_ engineering evaluation was : '

r required to resolve the item. _ The licensee agreed that:this was poor practice and was being done only to meet the 40 day evalua-

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tion requirement' of ENP-20. The ? licensee and the inspectors '

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 approva ,

<[ -(4)T After extensive review of the EWR backlog the inspectors concluded that there are many items in the~ backlog that individually do no ^

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pose immediate operability concerns, but are, nevertheless.-very J important to the safe and reliable operation of the Brunswick 6 units. The. licensee' agreed with this assessment, and noted that ,

many fof theLplant modifications currently budgeted' were to

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-correct'those deficiencies-7 ActionsonPreviousinspectionfindings.(92701,:92702) '(Closed)iViolation 50-325/87-32-01, 50-324/87-31-01, Inadequate corrective actions on EWRs.

- This violation reported a programmatic problem concerning inadequate. and untimely corrective action for deficiencies

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identified by . site EWRs. This item -is closed based on the

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discussion.in paragraph'2, above, (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 EWR This a item is closed based on the discussion in paragraph 2, above.-  !

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, (Closed) Inspector Follow-up Item 50-325,324/89-34 31, Small 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

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scheduled , but unbudgeted _ work existed in the form of EWRs and- ;

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PIDs. . Approximately 50 percent of the open =(dispositioned)- EWRs 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,

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the engineering support to complete effective corrective action of

, EWRs and PIDs was both untimely and inadequate in numerous '

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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 1 .resulti of: the corrective actions to the violations in inspection - .,

report 50-325/87-32 and 50-324/87-31. Follow-up- to the violations i discussed in that inspection are discussed above. .The licensee response icomitted to the establishment of- a' small projec *

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 ,

denied :the' portion of the problem concerning Brunswick's' action 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.- (Closed)' Inspector Follow-up Item 50-325,324/89-34-42, Vendo j recomendations (DET; paragraph 2.1.6.7). .

e The DET: reported thst; the licensee had not been aggressive in-  !

identifying or - closing - out vendor recommendation Many' vendor J recommendations :weres over 10 years old and were only _recently 1 dispositiened.- Scheduling and implementation of corrective actions, once dispositioned, were also generally' delayed to the futur Procedures ^ to control vendor recomendations were inadequate and had - not been revised to - reflect'~ current work 1 practice A previous NRC inspection, report 50-325,324/90-21, presents prior .

./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 provide ;

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 1 Additional _ly, the inspector- verified j

- the adequacy of the licensee's closure acticns for nine recently.-_ l L closed : EWR 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 close L 4.- Exit 1 Interview-(30703) i

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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 1 areas' inspected .and discussed in detail the inspection findings listed F.: below and in the summary. . Dissenting coments were not received from ,

thelicensee'. Proprietary information is not contained in this repor i

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D ', Item. Number Status Description / Reference Paragraph =

f 50-325/87-32-01 Closed = 'VIO - Inadequate corrective actions

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on EWRs paragraph,3; '

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, 50-324/87-31-01 . Closed VIO ' Inadequate' corrective actions on EWRs, paragraphc '

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50-325/87-32-02 Closed- VIO - Failure to document EWR

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evaluations, paragraph 1 .

50-324/87-31-02 . Closed VIO - Failure-to document EWR .;

, evaluations, paragraph. l l

u 50-325,324/89-34-31 . Closed IFI Small projects. budgeting-(DET- q para raph 2.1.6.6 and IAP item 4 0.24 , paragraph "

50-325,324/89-34-42 Closed IFI-Vendorrecommendations(DET ]

paragraph 2.1.6.7), paragraph .

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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

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IF Inspector Follow-up Item'  ?

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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