IR 05000324/1992010
| ML20034F075 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/10/1993 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Watson R CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML20034F077 | List: |
| References | |
| EA-92-075, EA-92-75, NUDOCS 9303020247 | |
| Download: ML20034F075 (7) | |
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FEB 101993
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Docket Nos.
50-325 and 50-324
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License Nos. DRP-71 and DRP-62 EA 92-075
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Carolina Pcwer and Light Company y
ATTN: Mr. R. A. Watson Senior Vice President
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Nuclear Generation
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Post Office Box 1551-Raleigh, North Carolina 27602
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Gentlemen:
SUBJECT:
NOTICE OF VIOLATION"AND PROPOSED IMPOSITION OF'
CIVIL PENALTY $225,000 (NRC INSPECTION REPORT NOS. 50-325/92-10 AND_50-324/92-10)
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'This refers to the special' inspection conducted by the Nuclear Regulatory Commission, Region II, at the Brunswick Steam Electric Plant (BSEP) on March 30 - April 10, 1992, to assess _BSEP performance in the areas.of
engineering, technical. support, and corrective actions.
The report documenting this inspection was sent to you by letter dated-April-29, 1992.
As a result:of this inspection, a violation of NRC requirements wasL
identified. An enforcement-conference was held on May 12, 1992, atENRC Headquarters, in-Rockville, Maryland, to discuss the violation, its cause,'and--
your corrective actions. This. enforcement action was deferred pending an investigation by the NRC Office of-Investigations. That investigation has
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recently been terminated. A summary of-the conference was sent to you by-letter dated June 5, 1992.
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The violation in the enclosed Notice of Violation and Proposed Impo'sition of -
Civil Penalty (Notice) involved-a significant breakdown in-your corrective action program as evidenced by significant deficiencies in masonry wall
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construction which were identified by your staff as early as 1987, but hots
corrected until after you were prompted by the NRC in 1992. The violatio_n_was-
of a continuing nature and extended 'over a five-year period.
Specifically, on.
k February 13, 1987, a licensee engineer identified and documented in _a memorandum that certain. bolts which are required for seismic adequacy of n:asonry walls in the emergency generator building, were inadequately installed.
It appears that two additional requests were made for technic'al
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support. regarding this deficiency. in April 1988 and September -1989.< t However,-
you did not perform calculations to:show that the walls met your criteria for; short-term structural-integrity until'1990. When these calculations were challenged by NRC inspectors in April 1992, you-found that they were incorrect'
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because the calculation assumed'that more bolts were installed than were actually present, t
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Carol'ina Power and-2-M 101993
, Light Company The identified deficiencies included modified bolts which had been cut off with only the head attached to the structure giving.the appearance of bolts where none actually existed. The purpose of these bolts was to support the walls in the event of an earthquake to prevent them from fallinq and damaging the emergency diesel generators and other safety-related equipment inside the building. Had a seismic event occurred, failure of the masonry walls could have rendered the emergency AC power system inoperable. This was a breakdown of the process b/ which a licensee evaluates identified deficiencies and provides reasonable assurance of verification of ar.alytical assumptions
against the actual plant condition. Thus, your untimeliness in analyzing an identified deficiency and your inadequate analysis in 1990 led to the continued operation of the plant in an unacceptable condition until April 1992.
When you concluded that the walls would not meet your design criteria, you declared the emergency diesel generators (EDG) inoperable and shut down both units.
Thorough walkdowns were performed in the EDG building, the control building and the reactor buildings, and all safety-related block and poured concrete walls were examined for structural integrity. A 100_ percent inspection and document review of anchor bolts installed during original EDG building construction was performed and subsequently expanded to the control building and both units' reactor buildings.
A sampling plan to walkdown a cross section of raceways, building steel, heating / ventilation / air conditioning, and equipment foundations for structural integrity was also implemented.
Reorganization and management changes were instituted, and a plant three-year improvement plan and a corporate improvement plan were implemented.
Both units remain shutdown pending completion of additional plant upgrades and improvements.
To emphasize the importance of ensuring that identified deficiencies:
(1) receive an adequate evaluation in a timely manner, (2) are corrected in a
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timely manner commensurate with the importance to safety, and (3) that appropriate levels of management are notified of significant conditions adverse to quality, I have been authorized after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear
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Reactor Regulation, Regional Operations and Research, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $225,000 for the Severity Level III violation. The base value of a civil penalty for a Severity Level III violation is $50,000.
The escalation and mitigation factors in the Enforcement Policy were considered. The civil penalty was escalated by 50 percent for identification because it was only after aggressive questioning by the NRC staff regarding the adequacy of your engineering evaluation that you performed additional evaluations which revealed the problems with the masonry walls.
i Because a significant aspect of the violation was the fact that you had a prior opportunity to identify the deficient condition during your 1990 engineering evaluation, but failed to do so, the civil penalty was escalated 100 percent. Another significant aspect of this violation was the duration
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y Carol'ina Power and-3-FEB 101993
. Light Company that it existed, from February 13, 1987 until April 1992. Therefore, escalation by another 100 percent was deemed appropriate for this factor.
Due to your past enforcement history, the civil penalty was escalated an additional 100 percent for this factor. On August 30, 1990, escalated enforcement action (EA 90-130) was issued with a proposed civil penalty of
$62,500 to emphasize the importance of proper work control and job planning
.i associated with activities related to the installation of a traversing incore probe on July 5, 1990.
On November 30, 1990, a Severity Level III violation (EA 90-154) was issued for the failure to follow procedures and the subsequent inaccurate completion of procedural requirements associated with a maintenance surveillance test.
On May 31, 1991, a Severity Level III violation-(EA 91-045) was issued with a proposed civil penalty o_f $87,500 for failure to follow procedures.
On January 3,1992, a Severity Level III. violation (EA'91-158)
was issued with a proposed civil penalty of $125,000 for inadequate corrective action related to work control and independent verification inadequacies. On March 24, 1992, a Severity Level III violation (EA 92-024) was issued with a proposed civil penalty of $100,000 for an inadequate maintenance procedure related to the EDGs.
The other adjustment factors in the Policy were considered, and no further adjustment to the base civil penalty is considered appropriate. Therefore, based on the above, the base civil penalty of $50,000 has been increased-350 percent to $225,000. While Section 234 of the Atomic Energy Act of 1954, as amended, limits the civil penalty for a-single violation to $100,000 per violation per day, a civil penalty may be assessed for each day of a continuing violation such as the one in this case. Accordingly, a civil penalty of $225,000 is being proposed for this violation.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this
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Notice, including your proposed corrective actions and the results of future-inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure ' compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter, and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required '
by the Paperwork Reduction Act of 1980, Pub. L. No. 96-51 t Carol.ina Power'and-4-R101993 i
Light Company
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Should you have any questions concerning this letter, please contact us.
Sincerely, Original Signed Dy:
Stewart D. Ebnetc*
Stewart D. Ebneter Regional' Administrator Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/ encl:
R. Anderson Vice President Brunswick Nuclear Project P. O. Box 10429 Southoort, NC 28461 R. Morgan
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Plant Manager, Unit 1 Brunswick Steam Electric Plant P. O. Box 10429
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Southport, NC 28461 M. Brown Plant Manager, Unit 2 Brunswick Steam Electric Plant P. O. Box 10429 Southport, NC 28461 H. Ray Starling Vice President - Legal Department Carolina Power and Light Co.
P.-0. Box 1551-Raleigh, NC 27602 F. Rabon Board of Commissioners
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P. O. Box 249-
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Bolivia, NC 28422
' Chrys Baggett
State Clearinghouse i
Budget'and Management 116 West Jones Street
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Raleigh, NC 27603
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cc w/ enc 1 con't: _ (see next page)
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Carol'ina Power and-5-U
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cc:w/ encl con't:
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Dayne H. Brown, Director
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Division of Radiation Protection N. C. Department of Environment, Health & Natural Resources
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P. O. Box 27687 Raleigh, NC 27611-7687
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H. A. Cole
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Special' Deputy Attorney General State of North Carolina P. O. Box 629 Raleigh, NC 27602 Robert P. Gruber Executive Director.
Public Staff - NCUC P. O. Box 29520 Raleigh, NC 27626-0520
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Ms. Gayle B. Nichols Staff Counsel SC Public Serv'ce Commission P. O. Box 11649 Columbia, SC 29211
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State of North Carolina
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Carol'ina Power and
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DISTRIBUTION:
PDR LPDR SECY CA JTaylor, EDO JSniezek, DEDR SEbneter, RII JLieberman, OE
~WTroskoski, OE JGoldberg, OGC JPartlow, NRR Enforcement Coordinators RI, RII, RIII, RIV, RV BHayes, 01 FIngram, PA DWilliams, OIG EJordan, AE0D Day File EA File DCS HChristensen, RII PMilano, NRR NRC Resident Inspector U.S. Nuclear Regulatory Commission Star Route 1, Box 208 Southport, NC 28461
- See previous page for concurrence OE*
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DWilliams, OIG
EJord an', AEOD Day File EA File Document-Control Desk
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H. Christensen, RII P. Milano,-NRR NRC Resident Inspector U.S. Nuclear Regulatory Commission j
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