IR 05000324/1990031

Insp Repts 50-324/90-31 & 50-325/90-31 on 900730-0803.No Violations or Deviations Noted.Major Areas Inspected: Diagnostic Evaluation Team Evaluation of Integrated Action Plan Corrective Action

ML20059K834
Person / Time
Site:	Brunswick
Issue date:	08/23/1990
From:	Jape F, Moore R, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059K833	List: IR 05000324/1990031 ML20059K829
References
50-324-90-31, 50-325-90-31, NUDOCS 9009240271
Download: ML20059K834 (18)

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as nao UNITE 3 STATES

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g 'o NUCLEAR REGULATORY COMMIS$10N -

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Report Nos.: 50-325/90-31 and 50-324/90-31

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Licensee: Carolina-Powef and Light Company .

O P. 0. Box 1551

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Raleigh, NC. 27602 '

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Docket Nos.: 50-325 and 50-324 License 'Nos.: DPR-71Tand DPR-62 a Facility Name: Brunswick 1 and 2 '

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. Inspection Conducted: July 30 August 3, 1990 Inspectors- '[ /M W 7- 7O

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Ts-/ 2.'s. / m Datb Sig(e Accompanying. Personnel:

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F, Jape on Au ust 1 and 2; 1990, o'

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>- F. Jape," Chief ' .

// 7 Date signe Quality Performance Section Operations Branch "

Division of Reactor Safety (

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SUMMARY  ;

i Scope:

This routine', announced inspection 'was conducted in the areas of ' followup for Diagnostic Evaluation Team findings and evaluation of licensee's corrective action delineated in the Integrated A: tion Plan. An evaluation of licensee's

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corrective actlon related to previoLsly identified inspection findings was -

W 'also performe Results:

In the areas inspected, violations or deviations were not identifie Licensee management' demonstrated a conscious effort to track and document IAP ,

Level 2 activitie Completion dates for IAP Level 2 activities were-  !

successfully met 'which is a positive indicator of CP&L management's support -

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for the IAP Progra .

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LALprogramjfdrl verifying;sustainedimprovementLinperformanceresultingifromVIAP- j p J' m4 iLevel 2Eactivities has not been developed by. the licensee; 7The10ET: items ( for:( '

'i f which LIAP1LeveF 2 Cactivities ; have- beeni completed weres lef tfopen: pendin j (M-

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, -: development and implementation 'of a 'progr, am- forgevaluating; their effectiveness.-  !

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o h REPORT DETAILS }

' ' Persons Contacted g Licensee Employees

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• K. Altman,-Manager, Regulatory Compliance

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• S. Callis, Licensing On-site Representative- "

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• K Core, Control and Administration

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• W. Dorman, Manager-QA/QC ,

• Foss, Regulatory Compliance .

• J. Harness, General Manager ,

-*R.' Helme,; Manager, Technical Support

"J.'Henderson, Manager, Radiation Control

• M.' Jones, Manager, On-site Nuclear Safety

• L, Jones, Control and Administration

• T.: Jones Senior Spec. - Invest, Regulatory Compliance

• J. Kelly, Manager,-Modification Support

• H. Moyer, Technical Assistant to PGM .

• L. Martin, Manager, Training

• G, Peeler, Manager, Planning and Scheduling

-* W. Simpson, Manager, Control and Administration 3

• R.'Starkey, Manager, BNP

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• J. Titrington, Manager, Operations Support i

• H.. Wall; Operation

• R. Warden, Manager, Maintenance

'Other. : licensee employees contacted during this insoection included

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engineers and administrative personne NRC Resident Inspector's

• Prevatte, Senior Resident Inspector

• Levis, Resident Inspector  :

~* Nelson, Resident Inspector

-* Attended exit interview

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Acronyms and Initialism used throughout this report are listed in:the last: I b paragrap . General The licensee preparation and interface with the NRC regarding the IAP was

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good. IAP information was collected for each IAP item which demonstreted a

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conscious effort'to track and document IAP scheduled actions. In addition '

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to documentation, knowledgeable contacts were provided on each issu ,

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It was apparent' that the licensee had placed considerable emphasis on meeting scheduled completion dates. The licensee was, .-successful in meeting these_ dates which provided a positive indicator regarding management's support of the IAP_ progra ,

It was noted that the licensee has not established plans for verifying or demonstrating the effectiveness of IAP items on improving. the related-program or process performance. Contact personnel were knowledgeable of

'the IAP issues and related activities, however,_they had not yet determined-what parameters _ or indicators ' would be used to indicatei performance

. effectiveness or improvements. The licensee indicated :that :it was too early in most cases to assess effectiveness, but they would be establishing parameters for measuring effectiveness in the near term. Licensee F management emphasized their intention to followup IAP issues to verify'

effectiveness. An internal memorandum from W. Simpson to R. Starkey dated July 31, 1990, supported this focus on monitoring implementation effectivenes ~i (Closed) URI 324/325/88-11-10 EDG No. 3 Operation with LowiJacket Water Temperature, A work request was written to' repair the jacket water temperature control valve. The- water temperature had decreased to 80 degrees F which did not satisfy the manufacture's recommendation. The licensee-had contacted Cooper Energy Services representative to- request: an assessment of operating with low jacket water temperatur CES'

stated that no damage resulted due to the short time of operations, but it 'is not good practice to run the EDG continuously with - low jacket water temperatur The temperature control valve was repaired June 20, 1988. The normal operability surveillance test has been performed, once every 31 days, since the repair and the

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problem has not recurre (Closed) IFI 324/325/88-11-11, Overspeed Testing of the:EDGi a

A new procedure, OPM-ENG-508, Instructions for- Removal,, Testing and Adjusting of the Woodward Overspeed Dump Valve was. developed on April'14,.

1988, to test and adjust the Woodward overspeed dump valves. The four ' EDGs were tested satisfactorily on August 26, 1988, August 4,

• 1988, June 23, 1988 and September 15, 1988. The _ test _ has been designated as a five year test, therefore, each EDG' has been-l-

scheduled for testing again in 199 (0 pen) URI' 50-325,324/89-34-05, Evaluate tfie Adequacy of Licensee's

..* Actions to Investigate Design . Integrity Issues for Safety Systems' i Other-Than HPCI and SW, Including Adequacy of Preop Test Results'. ;

Level 2 IAP' items associated with IAP No. D-7 have long lead time completion dates. However, an evaluation of .the status of- the Level 2 ' IAp items was performed to verify that corrective actions are = completed in accordance with the established schedul The

, following objective evidence was reviewed during this effort:

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Brunswick _ Nuclear - Power Plant, System Design Turnover, PCN-B0019A, Project Plan, dated March 21, 199 Detail Schedule for . Design Basis Turnov'er Project System, Projeu ID B0019A-DB Review Report - for the HPCI, SLC, and SW Safety System:

Functional Inspections, and the Service Water Modification Report, dated June 28, 1990.

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NUMARC Design Basis Issues Working Group,- Design Basis Program

,, Guidelines, dated June 29, 199 Brunswick Design Basis Oncument Topical Outline with- GE Cover Letter f, w Application Engineering to Nuclear Engineering Department, dated July 23, 199 Design Turnover Project Large Bore Oualification Schedule j folde Step 4,

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The System Design Turnover Project PCN-_B0019A, Phase 1, requires collecting NUMARC Guidelines and assessing its_ potential .j impact on the licensee's DBD effort The inspector verified I

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completion of this activit CP&L Management reviewed the NUMARC -

' Guidelines and prepared a draft report titled, " Comparison of; Design Basis Programs as Detailed by NUMARC, Robinson, Harrison, and'the current Brunswick Program." At the time of the inspection this- .

report was being reviewed and commented on by selected staff member Level 2 IAP Item D-7.a related to UE&C. and General Electric -1 activities -was verified to be on schedul The schedule for activities to be performed by UE&C has not yet been' completed -

_pending incorporation of NUMARC recommendations. -Auditionally, the ,

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. inspectors verified the status of 0-7.b by review'of_large and small W bore piping system milestone charts. .The' licensee satisfied the j requirement of . Level 2 IAP Item D-7.c by preparation .of ' objective g evidence No. 3. Management review and' development of implementation f schedule for the recommendations outlined in this report was ongoing j m ,

at the time ' of the -inspection.- The due date :for completion of .l A review by NED with 'a response to Nuclear Operations is 1 August 17, 199 l

'l The inspector concluded that Level 2 IAP items required to support j

'IAP Item D-7 is on schedule or completed as stated in the most recent (

r monthly repor I (0 pen) IFI 50-325,324/89-34-13, Followup on Implementation and l Effectiveness of Nuclear Engineering Improvements in IAP Item B- j i

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The DET report stated - that- the trans'ition to a CDD was poorly'

planned and-implemented. It further. adds that the process has been time -consuming,_ was still being implemented, and the licensee was expected to create additional organizational a.nd . programmatic-changes .as- various management studies and assessments wer finalize The inspectors reviewed objective evidence and conducted interviews with licensee management to verify the status of-corrective actinn plans developed to address the above . .

deficiencie The following activities associated with the listed Level 2 IAP items were reviewed:

B-2.a: Complete organization and staffing of Brunswick ~ site NED grou B-2.b: Determine long range human resource need !

B-2.c: Establish Brunswick Raleigh NED rotation program by developing a policy to include appropriate tasks and; '

skills, candidate performance, schedule - and temporar assignment The. inspectors. determined that the Brunswick site NED office had been organized and. fully staffed. The organization became effective ~

July 26, 199 At the time of the inspection a written charter .

describing functional responsibilities,. levels of authority, s an ,

-# . lines of internal and external communication interfaces had not been

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prepared for this group. Additionally, job position-descriptions had not been prepared for all supervisory personnel. Discussions with the

~ Unit Manager revealed that actions were ongoing to complete necessary program document changes required to fully support Level IAP-item B-2.a' .

Objective evidence presented by the licensee in this regard was..as follows:

Nuclear Engineering Department, Brunswick'_ Engineering . Support .c Section organizational

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chart approved by Kim Williamson July 26, 199 NED Guideline No. A-29, NED Unit Functions, Revision a Ct&L memorandum from K. Williamson to C. Garrison, Subject: '

NED Guideline A-29, "NED Unit Functions," dated July 9, 199 Position descriptions of selected supervisory and non-supervisory personnel assigned to the on-site uni *

Licensee management committed to -revising NED Geideline No. A-29 by u

September 28, 1990, to include the on-site unit function The. staff of the Brunswick site NED group consists of 71 percent -

, centractor The inspectors reviewed licensee management policy concerning the use of contractors. Additionally, the process by

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which contractors are selected, trained, and indoctrinated by the

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licensee was reviewed and discussed with CP&L management. No-deficiencies were noted during this effor .

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Licensee's - actions' taken in regard to Level 2 IAP items B2.b and B2.c were next evaluated by the inspectors. -Objective evidence reviewed during this effort were as follows:

CP&L Company Nuclear Engineering Department 1990-1994 Business Pla HED Guideline No. A-31, Personnel Rotation and Training, Revision List of individual, who have participated -in the BNP-Raleigh Rotation Progra The 1990-1994 Business Plan contains a Resource Summary which covers the time period from 1989 to 199 A breakdown of personnel in three categories, i.e. , CP&L API, Temporary FTE, and Contractor FTE is provided. It is NED intent to increase the number of personnel directly employed by CP&L with concurrent reduction of contractor staffin The staffing levels shown reflect this management-objective and is consistent with the written policy concerning the use of contractors. To date two personnei have participated in the rotation program established by NED A-31. Full implementation of this .-program is presently constrained by the large number of contractors on staff who are not participant The status _ of activities related to the following Level 2 IAP items were reviewed by the inspecto B-2.d: Develop detailed. and plant specific ' implementation plans for standardized site NED procurement function B-2.e: Transfer Brunswick EDBS function and. personnel to NE The inspector verified that upon elimination of the Brunswick-Engineering -and Construction Section, the EDBS function ='an personnel were transferred to NE This action satisfied the requirement of Level 2 IAP item B- Pursuant to recommendations

, made by the BNP Site Procurement Task Force, however, the EDBS organization was transferred from NED to the BNP Procurement Engineering Unit. This change, which became ef fective July'31,1989, is intended to support activities related to Level 2 IAP Item B-2.d; specifically implementation of the new Commercial Grade Procurement program. The EDBS functica and personnel will be retransferred"to NED,- This retransfer will occur after licensee. management has-y separated administrative and design-engineering functions related to procurement action Level 2 IAP Item B-2.d has been met by the licensee with

' establishment of the Procure. ment Engineering Group. A memorandum of Understanding for Design-engineering activities has been signed by the Manager, BNP, on February 1, 1990, and the Manager, NED, on February 8, 1990. This document specifies those design-engineering g

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activities, related to procurement actions, that falls within the

. scope of_ Procurement Engineering responsibilities. It'also empowers-Procurement Engineering- to perform these design-engineering activities in accordance with the requirements of specified approved NED procedures. The BNP/NED Interface Document-will be revised- on October 29, 1990, to reflect the above arrangement The ' inspector verified' that .other quality implementing procedures have been. developed to provide guidance to Procurement Engineering-during performance of nondesign-engineering function ,

The staff consists of contractors for the most part. In April 1990, the then existing staff was reclassified in accordance with new job classifications developed by the license Contractors hired af ter this - date have been selected in accordance with the requirements imposed by the new job classification The inspector concluded' that the licensee has completed activities j described - by the Level 2 IAP items. Additionally, Business Plans have been prepared .which defines management's goal ~concerning-

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staffing levels; 'and management's expectations concerning <!

l performance of organizational units. A methodology. for evaluating

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the effectiveness of the Level 2 IAP items has not been developed by the ' license .Thi s issue is left 'open pending licensee' i i

development and implementation- of a program for: evaluating the .

-- effectiveness of all activities related to-Level 1 IAP Item B- ]:

(0 pen) IFI 50-325,324/89-34-15, Followup on . Implementation l and Effectiveness of Outage Management / Modification Improvements, IAP Item B- This Level 1. IAP item tracked the implementation of OM/M organization -improvements. This organization assumed activities _!

previously ' performed by the. Brunswick Construction . Uni t . I

'* Organizational transition was occurring during the DET inspection time frame. The Level 2 items supporting- accomplishment of' the '

Level-1 IAP item B-6 are:

a) Reassign and/or elimin' ate training activities performed by BC b) Continue ' efforts to evaluate alternative methods for  !

modification / outage suppor i

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Training responsibilities for craft were assumed by OM/M. This was l documented by an in plant memorandum dated April 13, 1989, from the' .j Manager, Modifkations Support to the Manager, OM/M. The BCU was i

' demobilized ir Aarch 1989. Review of training rosters for various specialized ci af t training completed in 1989 and 1990 demonstrated l CM/M was administrating the previous BCU training responsibilitie l a

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i The- OM/M- has . completed a Unit 2 refueling outage in 1989 through 199 Unit I refueling outage is scheduled for September 199 Review of the Final -Outage Report for the Unit 2 outage dated April:11, 1990, demonstrated the organization was assessing performance- and evaluating methods to improve outage suppor Additional improvements included approval of a procedure for pre-outage planning, BSP-35, Revision 0, dated November 27, 198 ' This procedure outlines pre-outage activity up to 36 months prior to scheduled outage start dat This IFI was reviewed in NRC Inspection Report No. 50-325,324/90-16 in April 199 This report noted deficiencies in designation of responsibilities, interf aces, and the approval of Outage Management Guidelines. These deficiencies have been resolve In conclusion, the Level 2 items for IAP item B-6 have been completed as scheduled. The Post-outage Critique and Report for the previous Unit 2 outage demonstrate the OM/M organization was monitoring performanc This item remains open; pending a licensee effectiveness evaluation of the implementation of these IAP items, (0 pen) IFI 50-325,324/89-34-16, Followup on Implementation and Effectiveness of Nuclear Prioritization Process IAP: Item C- This Level 1 IAP item addressed the implementation of a corporate nuclear prioritzation proces The following Level 2 IAP items represented milestones for completion of this Level 1 item:

a) Develop guidelines /procedues for use of the prioritization process, b) Develop guidelines / procedures for linkage between priority ranking and budget inclusio c) Finalize Total Quality Team efforts to develop corporate prioritizatio d) Adapt corporate process of prioritization of work at Brunswic e) Apply prioritization process to new work and existing backlog .

The Level 2 items were completed as sch'eduled. Brunswick. site procedure, BSP-36, Nuclear Prioritization ' Process, Revision 0 incorporated the corporate guideline NGGM 305-5. This site procedure-was approved on November 3, 1989. The Nuclear Prioritization Process is to be applied to EWRs, PIDs, WR/J0s, plant modifications, NCRs, LERs, procurement and .INP0 items. The elements considered in the NPP are; nuclear safety, regulatory ' requirements, unit capacity / efficiency, ALARA, personnel /public safety, unit availability / reliability, management standards, and cost reductio ,

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Review- of .BSP-36 indicated the program contained a- level of, complexity and subjectivity which mandates implementing future verification activities to. assure consistent prioritization, value

- assignment by the plant organizations._ Based on values obtained f rom a work item category list, probability analysis table, and a cost benefit analysis table, a prioritization:value of 1 to 51 is obtaine The methodology was- simplifie6 for WR/J0s (trouble tickets) to facilitate this process by line level per'sonnel for this specific item. No - verification activity had yet been . performed which reviewed assignment of prioritization values to items within the

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program scop NPP ~ program training was provided to plant personne Management and technical staff, approximately 280 personnel, received 'a four hour seminar. Review of the seminar handout demonstrated the process was adequately encompassed. Approximately 150 operations and maintenance personnel received reading. requirements and discussions at safety meeting Review of WR/J0s, NCRs, and EWRs demonstrated that backlogged itemi had been assigned prioritization numbers and the process was being

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applied as new items were identified. EWRs initiated in April and May 1990 were reviewed to verify application of the NPP. WR/J0s for April 14-20, 1990, and.NCRs open as of July 31, 1990, were reviewe A . specific item related to prioritization which was identified by the DET related to control room _ instr _umentation availability and reliabilit The licensee has established goals to minimize control

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room instrumentation deficiencies and-tracks this daily. .The result has been a substantial' reduction _in control board trouble tickets, contributing to the reliability and availability of control room instrumentatio The scheduled post implementation review for this Level 1 item was

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_ completed on ' July 31, 199 It was an independent review by a corporate organization which evaluated - the documentation of

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Level'2 items and supporting actions to accomplish - the Level 1 D item. The review provided - an important function by evaluating completed actions with respect to proposed action and problem identificatio lais review was not an evaluation of :the effectiveness of the IAP item in resolving identified problems or

effectiveness of the process at Brunswic In conclusion, the Level 2 items for Level 1 IAP Item C-1 have been

completed as schedule The licensee has developed and implemented an ambitious, comprehensive prioritization process at Brunswic Primarily this process provides management a tool for a more efficient and uniform decision making process regarding work items and resources. This IFI remains open pending actions . of the licensee to assess the effectiveness of program implementatio ,

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[ Review of BSP-36 indicated the program contained a -level of' complexity and subjectivity which mandates implementing future-verification activities to. assure consistent prioritization value assignment by the plant organizations. Based on values obtained from a work item category list, ~ probability analysis table, and a cost benefit analysis table, a prioritization value of 1 to 51 is obtaine The methodology was simplified for WR/Jos (trouble tickets) to facilitate this process by line level personnel for this specific ite No verification activity had yet been performed which reviewed assignment of prioritization values to items within the program scop NPP program training was provided to plant personnel. Management 'I and technical staf f, approximately 280 personnel, received a four hour seminar. Review of the seminar handout demonstrated th process was adequately encompassed. Approximately 150 operations and maintenance personnel received reading requirements and discussions at safety meeting Review of WR/J0s, NCRs, and EWRs demonstrated that. backlogged items had been assigned prioritization numbers and the process was being applied as new items were identified. EWRs initiated in April and May 1990 were reviewed to verify application of the NPP. WR/J0s for - April 14-20, 1990, and NCRs open as of July 31, 1990, were reviewe l A specific item related to prioritization which was identified by .j the DET related to control- room instrumentation availability- and ' ' reliability. The licensee has established goals to minimize control-room instrumentation deficiencies and tracks-this daily. The result has been a substantial reduction in control board trouble tickets, -r

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contributing to the reliability tand availability of control room instrumentatio The scheduled post implementation review 'for this Level 1 item was 'i p completed on July 31, 199 It was an independent review by l L a corporate organization which evaluated the documentation. of- i " Level 2 items and supporting actions to accomplish the Level 1 l item. The - review provided < an important function by evaluating completed actions with respect to proposed action and problem ; identificatio This review was not an evaluation of--the ] effectiveness of the IAP item in resolving identified problems or , effectiveness of the process at Brunswick, j In conclusion, the Level 2 items for Level 1 I AP Item C-1 have .been- - a completed as schedule The' licensee has developed and implemented 4 L an ambitious, comprehensive prioritization process at Brunswic Primarily this process provides management a tool for a more efficient and uniform der.ision making process regarding work items and resources. This IFI remains open pending actions of the licensee to assess the effectiveness of program implementatio , q

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       -i (0 pen) IFI 50-32E,324/89-34-18, Followup on Correction of TS Sampling-Plan Flaw in IAP Item 01-4 and Determine its Effectiveness with Respect to. Periodic Reviews of TS Requirements, ISI/ Appendix J and Commitment Verification,
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IAP Item.01.d required the licensee to develop an improved sampling ; plan for QA surveillance of T5 requirement Surveillance' Report ; No. 89-082 documents the results of the first trial run for sampling ' TS surveillances. -The. sampling plan implemented during the period -

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January 3 through April 30, 1990, is intended to verify that tests are performed at specified frequencies for a representative - semple of TS requirements. The results indicate that TS surve,illance testing intervals are being met. One item of concern was M cten, however, concerning various inconsistencies with the Surveillance Test Tracking System, (STTS) data base from which the samples were draw ' Another item of concern was also written as a result of STSS listin survellance requirement T4.3.7.1-12 as T4.3.7.1-18. Thi s _ deficiency' . is similiar to tease identified in the first concer It is listed ~ separately, however, because this requirement was included in the random sampl Discussions with licensee management revealed 'that a second' trial . run of the sampling ple was being prepared. At the time of the inspection the representatica samples of TS requirements were being drawn from the STTS database. It is licensee's management's intention to evaluate the results of both trial runs and then decide on the frequency with which the sampling plan will be implemented.

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This _ issue is left open pending completion of (1)_ the - secondary

 . trial run of the sampling plan; (2) licensee's determination of how-of ten the sampling plan will be . implemented and - (3)(licensee's
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evaluation of the results of the sampling plan for effectivenes o

,       a (0 pen) IFI 50-325,324/89-34-23, Followup .on Implementation  !

and Effectiveness of Corrective Action Program. Improvements

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i This IFI is addressed by Level 1 I?J item D-9, Implementation of Corrective Action Program Improvcaent This Level 1 item provided' improvements in the site corrective action program which 'were

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interim measures prior to development and implementation of a corporate corrective action program (IAP Item D-10) scheduled - for-- December 31, 199 The following Level 2 items support- the , accomplishment of the Level 1 IAP Item 0-9:

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a) Develop a Brunswick non-conformance policy statement , < b) Establish incentives for self-identification of non-conformances i t

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10-V c) Issue revision to PLP-04 to provide: Lower threshold ~1evel for identification. of' significant condition Improve: trending

' Improve training l
 'd) Provide training on PLP-04, Corrective Action Procedure
. e) Identify a Brunswick Corrective Action Coordinator l  f) Identify an-HPES Coordinator   l
,  .g) Issue PLP-06, System Engineer Program Procedure The Level 2 items as' stated were completed in accordance ~ with the LIAP schedule. Licensee documentation-provided objective evidence of completion. Review of the items provided no indication .of actual-performance -improvement in this are The items providing the potential for improvement were; (a) and (b), the management promotion ,

of problem identification by plant personnel, and .(c), lowering the i threshold for significance identificatio These initiatives have not yet yielded changes indicative of program improvemen j i PLP-04 change to " improve trending" established a requirement for ; trending, but provided no detail as to what.will be trended or who is :; responsible for the trending. ^ Adverse conditions are processed. at

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BNP via 'an NCR program, Incident . Report Program and . numerous corrective action subprograms. There is no documented designation l of the corrective . action subprogram Discussion with the Corrective Action Loordinator identified approximately 31 corrective - action subprograms which process : adverse conditions. Regulator Compliance Instruction RCI 06.8, Corrective Action Program . Trending,- l Revision 0 dated April 18, 1990, provided: more structured guidanc l L for trendin This instruction did not designate the . corrective 'F action .subprograms to be trended. Trending performance at the date i of this inspection.was the same as during the DET. The new trending I l

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activity has not yet developed the database to provide useful I ' trending informatio Therefore, there is no objective evidence to' indicate; any. changes in trending activity have contributed to corrective action program improvements at this tim The Brunswick Corrective Action Program ' Coordinator and HPES l coordinator have been identified. One individual has assumed both j

 . position responsibilitie While a position description was in draft for the HPES coordinator, there 'was n , position- description for the Corrective Action Coordinator. No r rocedure references the C.AC position or provides a responsibility descriptio ,
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The identification of a CAC coordinator as the Level ' ~AP item states, without a description of functional responsibilit,es- is an-ineffective improvement initiativ Discussion intS the HPES/CAC . indicated the individual was generally knowledgeable of the subject areas. . Although the establishment of this position (s) provides potential program improvements, no objective evidence indicated any ' program performance, improvements have yet been realize There was documentation verifying a considerable portion of the' plant staff have received corrective action program trainin Increased knowledge level of the staff provides a r easonable potential for program improvemen Level 2 Item (g), Issue PLP-06, System Engineer Program was complete,

  .however, it was unclear what contribution this provided toward corrective action program improvemen There was. no direct responsibility for CAP activity indicated in. the procedur Discussion with licensee personnel provided no reasonable connection between this itert and its support of the Level 1 IAP Item D-9,
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Corrective Action Drogram Improvement In conclusion, .the Level 2 action items were completed as scheduled, however, this did not indicate the corrective action performance had improved. The majority of the Level 2 items provide a' potential for improvement which was not yet demonstrable. There was no apparent

 -  focus to verify implementation effectiveness of these items or establish parameters by which improvement could be- measured. It appeared - that these D-9 items were . bringing the site CAP into alignment with the 1mpending corporate cap implementation (IAP 0-10), (0 pen)- IFI 325,324.'89-34-25, Followup on Implementation and Effectiveness of Improvemen made to the 10 CFR 50.59 Review in IAP Item D1 The inspector-verified that the licensee has in place a corporate program and has examined the following objective evidence:
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Carolina Power and Light Company 10 CFR 50 Program Manual-Revisio This' manual was issued as Revision 0 and has been revised to Revision'1, and approved by the company Senior Vice President for Nuclear, dated April 6,199 This verified the licensee-completion of IAP Item D1 IAP Item 011.b required the licensee to develop

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  , procedures, training program, and implementation of the progra The inspector examined the following objective evidence:
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Memorandum f rom K. B. Altman to R. E. Helme, et al dated May 4, 1990, on the subject " Nuclear Safety Reviewer ' Training" g

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Memorandum 'from C. W. Chavis, ' Jr. , to George F. Cameron

   ' dated May 21,-. 1990, on the. subject "50.59 Qualified Safety Review Training"
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Lesson Plan Revision Transmittal Form, dated July 23, 1990, J which contains Lesson Plan GN626N and GN6C23G Test Bank . m >

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d i - Samples of nine test situations- (which were developed for

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testing purpose)

Based on the review and discussion with the licensee, the inspector

. has determined that the training for adjunct instructors was comp 19ted <

on April 4-5, 1990. . Among these instructors, five were from Brunswick site' and four were from Nuclear Engineering Design Organization. At the time of-this. inspection, the licensee has provided1 training on the new 10 CFR 50.59 manual review requirements to approximately 200 of its Brunswick 350 personnel who are being assigned the responsibility for-

  ' nuclear safety reviews. The licensee has stated that the _ remaining personnel responsible for 10 CFR 50.59 related review will be trained and the ' new '10 CFR' 50.59 Program Manual will be . implemented by August 20, 199 This verifies licensee activities required by IAP
  ' Item'D1 This item remains open pending an ' evaluation for effectiveness of the implemented changes by licensee managemen . (0 pen) IFI 50-325,324/89-34-37, Followup on Implementation and Effectiveness of Independent Performance Assessments.

. This. IFI is addressed by IAP Item E-5, Analyze Methods of

  ' Independent Assessments for Performance Evaluation. This Level 1 action item encompassed a licensee commitment to analyze the CP&L LNuclear Program evaluation functions and propose recommendations for changes 1 to' achieve a more proactive, focused and effective independent assessment function. The following Level 2 IAP items support the accomplishment of the Level.1 IAP Item E-5 scheduled for-completion December 31,-1990:

a) Select members for Project Quality Team to analyze nuclear

  . evaluation and oversight function ,

b) Gather data on industry evaluations and programs to incorporateL best practices into company program c) Identify desired changes in nuclear evaluation and oversight functions and attendant organizational structure ' d) Implement desired changes in nuclear evaluation and oversight functions and attendant organizational structures, i

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i The Level 2 action items a, b and :._ have been met 'as- scheduled. The inspector reviewed in plant memorandums which demonstrated the Project Quality Team Members were appointed in October 198 Further plant memorandums listed industry contacts established by the.PQT to gather informatio The report produced by the PQT was completed and undergoing a management review process. The report was not released to the inspector for review, therefore, the content of the report and evaluation of this effort ' by the NRC was not accomplished during this inspectio The licensee stated ~a presentation of the report to the Regional Administrator, Region II . was scheduled for August 23, 199 , Based. on the objective evidence provided, it was - concluded the licensee had met their -scheduled objectives for this issue. This IFI remains open. Actions to complete tne Level 1 item were not-complet There was no objective evidence- to indicate any licensee actions taken have resulted in i n roved performance in this are j. -(0 pen) IFI- 50-325,324/89-34-4; Followup on Implementation and Effectiveness of " Ownership initiatives, Including Procedura Adherence and Attention to Detai This IFI is ' addressed by IAP Item G-3, Personnel Ownership Initiative This Level 1 IAP item addressed DET identified weaknesses in two functional areas; Operations adherence to i procedures and Design Engineering in' attention to detai The Level 2 items implementing this Level -1 item addressed only the Operations procedural adherence issue. -The following Level 2 items ' support IAP Item G-3: a) Survey. Operator's attitudes, (regarding procedural adherence) Initiate Contract request for procedure writers

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b) . c) Approve funds and contract for procedure writer !

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d) Organizo review and schedule '01-28 backlog reduction,,(OI-28 is the process for operators to recommend procedure changes) e) Monitor backlog reduction f) Perform second operator survey g) Compare results of survey and provide recommendations h) Complete reduction in backlog, (due December 30,1990) { The Level 2 items clearly support . the Level. l' goal to improve

 " ownership" of operators with respect to procedures. The surveys involve operators in the improvement process and the 01-28 items incorporate operators' input to improve procedure '

item (a) through (g) were completed as scheduled. Iter M *ns incomplet The Level 2 items of this IAP provide a good examp1~ ans which implement the intent of a Level 1 IAP item as to meeting the specific stated wording of an IAP item. It .i t , within this Level 1 IAP item, there were no Level 2 items addressing Design Engineering's attention to detail (OET issue).

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I* w g ~ n 14 t fi Licensee personnel provided documer,tation of an Engineering statistical review of field revisions performed by Design Engineering, to address the 4 issue of inattention to detail. The licensee stated ~ the DET finding was based on the large volume of field revisiors generated for- installed modifications. The survey findings were'that less than 39 percent of the 1 , field revisions were attributable to Design Engineering responsibilit . The implied conclusion was that inattention to detail was not a problem in ' Design Engineering. This conclusion was not documented, i.e., connection established between the survey and the DET issue in this IA The attention _ to detail portion of this IAP item should be specifically addressed within the IAP item or deleted and verified 'to be inclVded

,  within another IAP item. If the survey ~1s intended to be the singular basis for invalidating the inattention to detail issue, this should be documented and approved rather than implied in-discussio In conclusion, the Level 2 IAP items have been completed as  '

scheduled. The Level 2. items do not encompass' the full . scope of th .* Level 1 item. 'The Level I completion date is December 30, 199 ^ Licensee action is required to address the apparent scope deficiency between the Level 2 and Level 1 IAP-item .,

       , Exit Interview
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The- inspection scope and results were summarized on August 3,1990, with those persons indicated in paragraph 1. The inspectors described the areas inspected and discussed in detail the inspection results listed belo Proprietary inforina tion is not contained in this - repor Dissenting comments were not received from the license Licensee Management was informed that the following items were closed: l UNR 50-324,325/88-11-10, EDG No. 3 Operation with Low' Jacket Water .i Temperature

IFI 50-324,325/88-11-11, Overspeed Testing of the ED ' The -inspector stated that a program for verifying sustained improvement in performance caused by the Level 2 IAP activities has not been developed by the licensee. The DET items were left open pending licensee inanagement development and implementation of a methodology ~.for evaluating the effectiveness of completed Level 2 IAP item (

 ' Acronyms and Intialisms ALARA As Low As Reasonably Achievable API Authorized Personnel Inventory BCU Brunswick Construction Unit
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BNP Brunswick Nuclear Plant 5 BNP' . Brunswick Nuclear Project-

 -BSP Brunswick. Site Procedure CAC Corrective Action Coordinator CA Corrective Action Program CD0 Central Design Office CP&L Carolina Power and Light  '

DBD Design Basis Document 1~ DET Diagnostic Evaluation Team (inspection)

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,  EDBS Equipment Data Base System  ;

EWR Engineering Work-Request E FTE Full Time Equivalent HPE Human Performance Enhancement Program IAP' Integrated Action Plan IFI Inspector Followup Itam-ISI Inservice Inspection < NCR Non-conformance Report NED Nuclear Engineering Department , NGGM Nuclear Generation Group Manual

 .NPP Nuclear Prioritization Process NUMARC . Nuclear Management and Resource Council
 .PID Project Identification-PQT Project-Quality Team STTS Survie11ance Test Tracking Syste .TS Technical Specification
 .Uc&C' United Engineers and Constructors URI Unresolved Item WR/J0 Work Request / Job Order
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