IR 05000324/1992030
| ML20127G740 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/30/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127G733 | List: |
| References | |
| 50-324-92-30, 50-325-92-30, NUDOCS 9301220059 | |
| Download: ML20127G740 (26) | |
Text
~_ . . . . . _
-
-
.
,
- = . ,
.
..i ENCLOSURE INITIAL SALP REPORT U. S. NUCLEAR REGULATORY COMMISSION REGION 11 SYSTEMATIC ASSESSMENT OF-LICENSEE PERFORMANCE Inspection Report Number S0-325/92-30 AND 50-324/92-30 Carolina Power & Light Company BRUNSWICK UNITS 1 AND 2 NOVEMBER 3, 1991 - OCTOBER 31, 1992
.
'
,
.-
(
'
9301220059 921230 PDR: 'ADOCK 05000324'
+ G PDR _ _
_ _ _ _ _ - _ _ - - _ _ _ _ _ -
,,
=*
.
-
.
- .= .
.
SUMMARY OF RESULTS Overall performance-in _the area of Plant Operations was good.- Licensed ,
operators performed well when challenged by plant events, transients, and equipment failures. A slight decline in command, control and ,
communication was apparent; however, operators were generally considered professional and knowledgeable of plant systems and procedure Problems involving configuration control continued, and ineffective supervisory oversight contributed to a decline in plant housekeeping and material condition. Performance h this functional area during the second half of the assessment period decreased due to the lack of a recovery plan, weak supervisory oversight and operator lap _ses in attention to detail. There was a significant reduction in the number of operator work-arounds; and an adequate fire protection program was maintaine The improving trend exhibited in Radiological Controls last assessment period also continued during this period. The licensee's radiological control programs were effective in controlling personnel exposure and limiting effluent release Exposure reduction efforts (which also included initiatives to reduce future exposure) were successfully performed. Efforts to reduce the volume of shipped radioactive waste and to clean up the spent fuel pools were considered aggressiv However, an inadequate inventory and evaluation led to a startup source being breached dur_ing fuel pool cleanup activities--resulting in an uptake of americium by one worker and the spread of alpha contamination throughout the Unit 2 refueling floor. In addition, examples were identified where inoperable radiation monitors remained out-of-service for significant periods of tim Performance in the Maintenance / Surveillance area was acceptable, but was significantly challenged by a continuation of work control problem There was a significant improvement noted in emergency diesel generator maintenance and the Surveillance Test Scheduling System continued to be-an effective tool to assure timely conduct of testin However, poor overall maintenance practices, equipment failures and deferred maintenance adversely affected performance in the Operations, Security and Engineering / Technical Support areas. During the second half- of the assessment period, efforts were initiated to reduce the maintenance
,
backlog and correct work control program deficiencie Emergency Preparedness (EP) was maintained in 'a state of operational readiness. Good response capability was demonstrated during the annual EP exercise. Classificat.on of actual events was proper with offsite notifications being appropriately made. Licensee response to a toxic chlorine gas leak disclosed program response weaknesses with regard to non-radiological hazards. Additionally, training of EP response personnel continued to be an area of concern, as failures to conduct required first aid training were identifie ,
Over the assessment period, performance in the Security area was considered to be good. The site's contract security force typically
. _ _ _ . _ . _ _ .
.
.
performed well, reflecting management's support for an effective training program. However, : initial response effectiveness on two separate events was reduced as members of the security force were=not respirator trained and qualified. Also' identified by the NRC were several examples of failure to control vehicle access and inadequate escorting of visitor Additionally, maintenance of security barriers and alarms we: not timely or effective, resulting_ in considerable utilization of security officers for compensatory measures. During the latter part of the assessment period an increase in management support was seen through the completion of the protected area perimeter upgrade project and other equipment improvement Initially limited by equipment faiF/es and a large, poorly managed backlog of plant deficiencies, performance within the Engineering /
Technical Support area became more effective later in the assessment period as additional engineering resources were allocated and the backlog of engineering work was prioritized. System engineers were well qualified and knowledgeable of their assigned systems. Operator training improved since last assessment period as evidenced by the excellent results on requalification examinations. Due to previous inadequate engineering evaluations, long-standing structural deficiencies went uncorrected until' actions were prompted by NRC. The quality of design related work was inconsistent, with identified discrepancies resulting from inadequate contractor oversight and use of draft and/or inadequate procedure Performance within the area of Safety Assessment /Quali_ty Verification continued to be inconsistent. Significant management changes were made at the site and corporate level, and a Staff Assistance Team was
- implemented to assist site management in identification of procedural and process improvements. The previously established Site Incident Investigation Team process was effectively utilized, and the licensee's response to generic issues was well performed. However, despite improvements in problem identification, minimal corrective action followup and management support limitea the overall effectiveness of self-assessments and Quality Control. Midway through the period, structural verification programs were implemented (after prompting by NRC) to identify / correct long-standing deficiencies invol_ving safety _-
-
related wall anchorages and miscellancous structural steel. Following
,.
implementation, NRC identified a-number of quality assurance related L problems adversely impacting the miscellaneous structural steel verification progra y ye w - - - r y y w- - -^
_ ._
. ,
,
-
4 Functional- Area Ratina last-Period Ratina This Period i
Plant Operations 2 2 Radiological Controls 2 (improving) 2 (improving)
-
Maintenance / Surveillance 3 3
,
Emergency Preparedness 2 -2 Security 2 2 Engineering / Technical Support 2 2 Safety Assessment / Quality 3 3 Verification 111. CRITERIA The evaluation criteria which were used to assess each functional area are described in detail in NRC Manual Chapter 0516, which can be found in the Public Document Room. Therefore, these criteria are not repeated here, but will be presented in detail at the public meeting held with the licensee management on January 14, 199 I PERFORMANCE ANALYSIS Plant Operations Analysis This functional area addresses the control and performance of activities directly related to operating the facility, as-
.
well as fire protectio Power Operations (Pre-April 21.-1992)
The plant was generally operated in a safe and' conservative manner, with power operations being conducted until; an-extended dual unit outage began-on- April 21,-:1992. During-this first half _of the assessment. period, two automatic reactor trips- occurred on each unit .-- three attributable.t plant equipment failures and the other .a faulty test mete Unlike Unit 1 (which essentially _ conducted normal power operations), Unit'2 started the assessment period in a refueling outage. Excluding the reactor trips,-Unit 2 was subsequently forced to shutdown and/or reduce power nine times to-rework items that had been repaired or modified
-
during-that refueling outag The performance of licensed operators was considered good during the four reactor trips, as.'well as during the startups, shutdowns and power maneuver; that occurred in_the first half of the assessment period. Equipment problems 1 continued'to ~ provide significant challenges to plant operators, but were handled very wel _
sp --, -- =____-_m-_
,
, .
,
K 5 .
For the most part, control room shift turnovers and pre-job briefings continued to be detailed and thorough. Plant operators as a whole were professional; knowledgeable of plant systems, as well as general and emergency operating procedures; and were responsive to plant annunciators.._
Additionally, the operators continued to achieve excellent overall results on licensed operator _ requalification examination Problems involving configuration control continued during ,
this period. Several adverse condition reports (ACRs) were written between November 1991 and March 1992 covering mispositioned valves. The licensee's corrective actions were unable to prevent recurrence, as each case was treated as an isolated event with no common thread-to indicate performance breakdown. Also, aerformance in command, control, and communications (wlich was identified to have improved in the previous assessment period) declined somewhat. This decline was noted during simulator exams, and was apparent in the control room during routine operations and outages. In addition, log keeping was weak, having significant room for improvemen Staffing was adequate to support five shifts of routine watchstanding and required training. However, the licensee's long-range planning did not provide a sufficient number of personnel in licensed operator training to permit an orderly transfer of operations-experienced personnel to other sections. This was evident by the use of contractors as Shift Technical Advisors and training instructors,.as well as by unsuccessful attempts to meet management expectations. This problem was temporarily addressed through the short-term overstaffing of some. position Ineffective supervisory oversight contributed lto a decline in plant housekeeping.and material' condition.' Late in th assessment period, the assignment of a unit specific-management staff was made to provide added _ focus on
-
supervisory oversigh Although operators identified a considerable number of adverse conditions, a significant number of inoperable.-
and/or disabled annunciators, temporary and permanent--
caution tags, jumpers and-lifted leads, and:other operator-work-arounds continued to be tolerated. .Many of these-conditions had existed for several years and were common knowledge to operators and plant management. -After these-conditions were brought to the attention of licensee management by several NRC inspections conducted in early 1992, the licensee initiated actions in an attempt to address this problem.
l
- '
____:__________________-
-
. .- - - . . . . . - - . . - .
,
,
,
- . .
ft
Shutdown Doerations (Post-April 21. 1992)
On April 21.,1992, ~the-licensee shut down both units due to concerns with the seismic qualification of diesel. generator building interior wall The units remained shutdown for the remainder of the assessment perio After the dual unit shutdown, the licensee's staff struggled with known equipment problems, as well as c'onfusing and deficient schedules and priorities. During the first few months, no clear priorities were established and only items that could be rapidly returned to service were removed from service and worke No meaningful schedule existed. The-lack of a plan and schedule with established goals and standards, weak supervisory oversight, and operator lapses in attention to detail resulted in a decreased performance during the second half of the assessment period. One such example was the inadequately controlled Unit I reactor water level draining evolution which resulted in the inadvertent low level isolation of shutdown cooling on 0ctober 2,199 Licensee corrective action efforts during this period did lead to a reduction of operator work-arounds and temporary conditions by approximately 50 percent, viowever, ~other items such as long-standing Technical Specification Interpretations did not receive _the same degree of attentio Fire Protection Procram The licensee continued to maintain an adequate fire protection program. Positive features of the program were good adherence to fire prevention procedures and the conduct of comprehensive critical _-self-assessments and audit Corrective actions related-to-previously identified fire brigade communications difficulties during fire drills and an actual fire were on schedule for completion in 199 During.the assessment period five violations were cited.
' Performance Ratino Category: 2 Recommendations None.
l l
i
-
- <
. .
'
.
7 Radioloaical Controls Analysis This functional area addresses those activities-directly_
-
related to radiological controls, radioactive _ waste-management, environmental monitoring, water chemistry, and-transportation of radioactive materia The radiological control (RC) programs continued to be effective during the assessment period in' controlling the exposure of plant personnel to radioactive materials and limiting effluent releases to the environment. Typically, internal and external exposures were a relatively small percentage of regulatory limits with no exposures in excess of applicable limit The licensee continued to maintain a stable and well qualified RC organization supported by an adequate continuing training program. To further strengthen the 3 organization, several staff reassignments were implemented during the assessment period. Sufficient numbers of-qualified technicians were available to support both outage-and non-outage radi_ation protection activities. StaffingLin ,
this area was further enhanced by achieving a high return
-
rate for contractor technician support for the outag Collective dose for the previous assessment period was about 1660 person-rem as compared to 606 person-rem for the current assessment period. In general, the licensee was effective in controlling collective dose during-the assessment period for the work required to be don Supervisory control was generally adequate,.with the notable exception of several instances where workers were in areas-requiring radiological work permit- (RWP) authorization.who were not active on an RWP or weretactive on an incorrect RWP- >
for that particular are During this assessment period, the 1.icensee successfully-performed exposure reduction efforts which included: 1 chemical decontamination of the recirculation system piping, 4 increased use of- temporary shielding, nozzle _ flushes,- and increased use of video _ cameras.-Through-these efforts,-the-licensee estimated a-net savings of 555 person-rem. .Othe_r initiatives.by the licensee this period to reduce future exposure included: clean up of the UnitL1 and Unit 2 Spent Fuel Pools, aggressive use of. video cameras,_ addition of-a
-
surrogate tour system,- and hydro-lasing floor' drains .in the:
turbine building-to reduce the outiof-core source ter The licensee continued to effectively control contaminated surface area until the americium / beryllium event (discussed l
_- - - _ . - _ - _ - _ _ _ _ - - _ _ - - _ - _ _ - - - _ _ _ . _ _
=
- -
. . .
,
.
8- a below) in September 1992. Overall, the average contaminated surface area remained relatively high, but continued to trend downward with respect to previous usessment period Personnel contamination events for the previous assessment period were 327.as_ compared to 173 for the current assessment perio The licensee failed to maintain an adequate inventory and failed to perform an adequate evaluation, which resulted in a 5._4_ curie americium / beryllium startup source being breached during the Unit 2 fuel pool cleanup evolution. As a result, one worker received an uptake of_ americium, although it was below 10 CFR 20 limits. During this event, alpha contamination was spread throughout the Unit 2 refueling floor. Although initial licensee actions to control the spread of the contamination could have-been more aggressive, the licensee performed appropriate followup actions. Licensee offsite surveys and evaluations confirmed that environmental limits were not exceeded. At the end of the assessment period an extensive decontamination effort of the refueling floor was underway to reclaim the area and to eliminate the risk of alpha contamination to outside area Liquid and gaseous effluent control programs were effectiv The sum of all releases represented less than two percent of Technical Specification limits. Tne licensee's effluent monitoring program was enhanced by modifying the main stack isokinetic probe, as well as by the effort to maintain the-
-
turbine building at negative pressure; thereby reducing the probability of unmonitored releases, in the chemistry area, the licensee successfully analyzed NRC-supplied non-radioactive chemistry sample Control room logs contained numerous entries for inoperable monitors, including a drywell radiation monitor, offgas discharge radiation monitor, and. turbine building high range noble gas monito Such equipment was normally repaired.and returned to service within a reasonable. period of tim Exceptions included a liquid radwaste-flow totalizer that
' had been inoperable since 1984, and the Unit 2 reactor-I building roof ventilation monitor which had been inoperable for over a yea The Radiological Environmental Monitoring Program continue'd to be effective. There were no significant radiological l
consequences attributable to the operation of Brunswick due L to airborne, waterborne, aquatic, ingestion,.or direct l exposure pathway The results of the licensee's--
environmental analyses supporting this were in good agreement with the monitoring results of the State of North Carolina.
l l
l
, , - _ . _ . _ _ - ---
_ - _ - _ _ __ __ -
-
. .
,
.
Licensee assessments / audits were well-planned and documented, with_a clearly-defined scope. Showing considerable improvement over the previous period. !.iese assessments / audits identified programmatic weaknesses and made recommendations for corrective actio During the assessment period, the shipping of a feedwater-heater was observed and operations went well, reflecting-the competence, training, and experience of the-staff. _ Shipping documentation was thorough and well mamtained. The licensee's effort to reduce the volume of radioactive waste shipped to the disposal site, as well as cleanup the spent fuel pools, was aggressiv During the assessment period one violation was cite . Performance Ratina Category: 2 (improving) Recommendations Non Maintenance / Surveillance Analysis This functional area addresses those activities related-to equipment condition, maintenance, surveillance performance, and equipment testin ,
Performance in the maintenance / surveillance area was significantly challenged by a continuation of work control problems from the previous assessment perio For example, early in the period a diesel generator failed to start on demand due to inadequate work control (i.e., Maintenance-Operations interface) associated with engine cleanin Site management was not fully effective _in implementing corrective actions for recognized problems in the work control process. Programmatic maintenance planning and post maintenance testing deficiencies were not-corrected despite the existence of previous regulatory attention and adverse =:
condition report .
The predominant contributing cause of recurring work control events _ was related to inadequate- procedures or improper use of procedures. Maintenance work procedures contained deficiencies which contributed to weak procedural-adherenc Exacerbating this was _ the one year backlog of needed procedure revision . . . _ _ . - . - _ - -
_ _ __
-
- . .
i
,-,
High emergent-work volume ~and lack of-an effective- ..
scheduling mechanism disrupted work flow and inhibited the maintt Jea staff in performance of corrective maintenanc Maintenna supervisors were responsible for scheduling work. hus, and excessive administrative tasks, resulted in a limited amount of time available for field supervisory oversigh ,
Reflective of external industry inputs and assistance, initial licenses actions to correct work control program deficiencies were considered thoroug Program improvements taken or still in progress at the end of the period included: the addition of a minor maintenance program, streamlining of the corrective maintenance process, formulation of a centralized post maintenance testing program, initiatio'n of new supervisory and craft training-programs, and upgrading procedure The Unit 2 refueling outage in progress at the beginning of the period was deemed unsuccessful in that equipment failures, deferred maintenance, ad faulty maintenance prevented a return to normal operation upon outage completion. During the two months following outage completion, the unit experienced one reactor trip, four forced shutdowns and five cases of reduced power operations due to plant equipment problems. Examples of deficient maintenance included a main turbine bearing failure due to missed alignment checks and the failure of the high pressure coolant injection system steam admission valve due to an improperly reassembled limit-switc Maintenance backlog reduction was. emphasized during-the dual unit forced outage which-began midway through the assessment-period. The backlog consisted of both preventive and corrective maintenance that had accumulated over a long period. Added to this was an accumulation of previously-undocumented ' equipment deficiencies due largely to corrosion and other previously tolerated material deficiencie The-volume and nature of the needed maintenance illustrated-the poor material condition of the plant. The licensee's initial screening process for identified maintenance items was considered to be-appropriat A significant improvement was noted in the performance of '
emergency diesel generator (EOG) maintenance. Following the
-
poor EDG:3 outage near the end of the previous period, a
"
much improved EDG 4 outage was conducted at-the beginning'of-
-
this-assessment period. EDG maintenance during the dual
'
unitiforced outage demonstrated increased sensitivity to potential engine problems. Utilizing vendor and other-
-
external assistance, the licensee identified and corrected
.
.
- - - . .- ,.
-
,
.
-,-- , j
. *-
11-1 numerous long-standing problems that had previously gone ,
unrecognize l
.
With respect to periodic Te<hnical Specification surveil- :l lances, the licensee's Surveillance Test Scheduling System j continued to be an effective tool. -Two examples of missed ;
surveillances occurred, both related to fire protection system However, when performed, neither identified-inoperable equipmen Coordination of surveillance activities with control room personnel maintained the ,
improvement noted in the last assessment period. Although three of the four reactor trips occurred during surveillance testing, none were attributable to personnel erro During the assessment period three violations and one deviation were cite . Performance Ratina Category: 3 Recommendations l
.
Poor maintenance practices and deferred maintenance adversely affected performance in several functional area Notwithstanding current efforts to improve work control, significant management attention to the Maintenance area is-warranted.
, Emeraency Prenaredness Analysis This functional area addresses activities related to the implementation of the Emergency Plan and its procedures, the -
training of onsite and offsite emergency response -
organizations, licensee performance during emergency exercises and actual- events, and- the maintenance of
- - facilities and staffing for emergency respons Overall, the Emergency Preparedness (EP) program received sufficient management support to maintain the basic EP-elements needed to implement the Emergency Plan-and respective procedures in response to emergency' events. The-program was maintained in a state of. operational readines The licensee maintained an excellent working relationship-with State and local offsite agencie In general, the licensee continued to maintain adequate -
emergency response facilities and equipment, with- _
appropriate equipment surveillance and functional testin The licensee acknowledged the need for increased-EP staffing
..,
. ..- - . - . - - - - - . - . _ -
.
-
g .
9.'
j-
,.
by adding an EP specialist to the program at_the end of the assessment perio Training of EP response personnel continued to be an area of concern, as failures to conduct required first aid' training were identified. The licensee's corrective action to assure
'
EP related training is conducted included assigning the full time responsibility to an individual in the Brunswick Training Unit. In addition, consultant support was made available for assistance in developing a program that will also provide for performance-based instruction versus the self-study progra The licensee's audit program was found to be effective in identifying routine and exercise conditions requiring corrective action, as well as making recommendations for improvement. Conditions requiring corrective action were tracked via adverse condition reports until correcte During this assessment period, the licensee implemented its Emergency Plan in response to two events. Both events were properly classified as a Notification of Unusual Event (NOVE), and timely offsite notifications were made with the exception of one to Brunswick County when the county's 911 system was inoperable. The licensee's response to the NOVE involving a release of toxic chlorine gas disclosed weaknesses in the licensee's emergency response program for non-radioactive toxic materials. Areas of concern that were noted included training for the chlorine emergency response team and a lack of command and control in responding to a non-radiological hazar Brunswick demonstrated good response capability during their annual exercise in June 1992. During the exercise, the licensee demonstrated it could implement the Emergency Plan, as well as take suitable actions to mitigate the consequences of the accident scenario. Emergency classifications were timely as -the scenario prcgresse Exercise strengths included timely activation of emergency response facilities, control room command and control, and Health Physics support and response to the medical emergency. An exercise weakness was identified for failure to prioritize and dispatch repair teams to mitigate the plant accident conditions in the most effective manne During the assessment period one exercise weakness was identified and one violation was cite . Performance Ratina Category: 2 L
l-1 a - u
. .
,
13 Recommendations Non Security Analysis This functional area addresses those safeguard activities associated with the plant's safety-related vital equipment, the accountability of special nuclear material, and the-effectiveness of the licensee's Fitness-For-Duty Progra The site's centract security force was well staffed and typically performed security functions well. The licensee's security force was well managed, well supervised, had good procedures, and was subject to a self-assessment progra Overall, the security force was appropriately equipped to comply with NRC requirements and the !!censee's commitment The professionalism of the contract security force personnel-was noteworthy. Towards the end of this assessment period, the NRC did identify several examples of. performance weaknesses associated with failing to control access of vehicles and inadequate escorting of visitor Security training was coordinated, well planned, and met the requirements of the Security Training and Qualification Plan. Overall performance by security personnel reflected -
an effective training program. Management displayed support to the training program by the improvements at the range facility (i.e., improved target stands, new fifty yard firing lanes, and electrical power provided to the range).
Tactical response and weapons training continued to improve with the addition of a highly-qualif_ied trainer-to the-training staff during the last assessment period. .There-were two separate events in:which members of the security force who were responsible for access control .
accountability and evacuation of personnel were not-respirator trained and qualified. This reduced the effectiveness of-the initial response to both the chlorine release and the americium /ceryllium contamination event The' licensee filled vacant positions promptly and with qualified personnel.-_An Administrr' '<e Senior-Specialist:
position was filledito oversee th. ~ urity. regulatory compliance functions in order to improve assessment--
performance of the security operation. Isolated examples:
(identified.by the NRC) of failure to control safeg'uards-information and' key control were: corrected accordingl During the early portion of this period, there were examples where management support for the security program was weak.
. . _ --
, _ _=
.- - -- . . - - ... - . - .
. .. ,
,
.
.
I l
!
14-Forexample, maintenance _ofsecurityequipment-(i.e., .)
barriers, alarms,- and alarm stations) was not timely or effective. A need to enhance the licensee's preventive maintenance program for. security equipment and improve the 1 communications between plant-support and security also was ._ i ideatified;by the licensee during the annual corporate audi of the security program in June 1992. Problems with i equi) ment out of service caused the licensee to exceed their '
200 lour target for utilization of security officers for compensatory measures by 386 hour0.00447 days <br />0.107 hours <br />6.382275e-4 weeks <br />1.46873e-4 months <br /> Plant management support for the security program increased in the latter part of this assessment period. Equipment improvements consisted of increased protected area lighting, additional security radios, and new rifles for the tactical response force. -The licensee completed the protected area perimeter upgrade project whicn was. initiated at the end of the last assessment period. This.has decreased the safeguard events logged, false alarm rates, ;nd protected area perimeter deficiencie Other ongoing security improvements during this-period were directed, in part, at addressing problems with the video assessment capability that had been identified in the previous assessment perio Improvements included the addition of a video capture system to the closed circuit _
television (CCTV) assessment equipment and providing-alar stations and security shift supervisors with new television monitors. As a result, improved CCTV picture quality wa eviden ,
The licensee's Fitness-For-Duty Program was found effective- .[
at achieving a drug-free workplace while balancing the '
rights and privacy of the workforc During this assessment period three violations were cite . Performance Rating Category: 2 Recommendations Non ~ Enaineerina/ Technical-Support Analysis
- This functional area addresses activities ~ associated'with-the design of. plant modifications, and technical support for operations,-outages, maintenance, and licensed operator-training.
,. -_ , .
- _ - . - - - -- . .-- - . . ...
. .
,
,.
Early in the assessment period,_ most engineering and-technical _ support resources'were consumed in reacting t equipment failures. Little time was available for program developn.ent or long range planning, The corporate Nuclear Engineering Department was spending-about one half its resources in support of Brunswick. The ability of the engineering staff to be more effective was limited by ai large, poorly managed backlog of plant deficiencie Performance in this area improved later in~the period when the licensee allocated additional engineering resources and prioritized the backlog of engineering wor The quality of design related work was inconsisten Several modifications, such as addition of local switches for the Unit 2 station blackout 4kv bus crosstie and instrument rack replacements, were well designed. Other design related work was deficient. For example, errors were found in a contractor's design calculations for structural steel. Contractor oversight was incroa9ed to-resolve this problem. Still, other deficiencies occurred when enginents used draft and/or inadequate procedures to perform design activitie Unrealistic schedules contributed to these deficiencie Several discrepancies were identified between conditions:in the plant and those described in the FSAR and plant drawings. Examples included pipe supports and anchor bolts that did not meet the Finai Safety Analysis' Report (FSAR)
commitments, and structural steel that did not meet FSAR commitments and was not described in asJouilt drawing Further, the licensee did not have design calculations verifying that as-built steel supporting safety-related equipment met allowable stress values. The licensee initiated corrective actions for tnese examples and continued to implement a-design basis _documentat.on program to address this issue genericall Previous inadequate engineering evaluations contributed tm a-failure to correct long-standing deficiencies until acticas were prompted by NR For example, bolting in masonry walls was identified as deficient by the licensee as early as 1987 but was not corrected-until 1992 because lack of_a thorough-engineering evaluation had resulted in an underestimation _ of-the extent _of the problem. Similarly, the licensee had been aware of structural steel deficiencies-for several years; but tu full extent of the' problem was not recognized until a more thorough engineering evaluation of these deficiencies-was performed late in the assessment period. _The licensee
-
maintained' a short-term structural integrity (STSI)- program for evalu.ating the operability of equipment which did not'
meet the structural _ design criteria in the FSAR. Such'
equipment was considered short-term qualified if-the
_ .--
. .
,
.
16 ,
evaluation found it to'be operable. Though. subsequent-NRC review found the licensee's 3TSI. evaluation-criteria to be acceptable, a significant backlog of equipment was short-term qualified for several year System engineers were well qualified and had a good understanding of their assigned systems. They maintained-current knowledge of the material condition' and participated in the prioritization of maintenance for their_ assigned systems. The licensee maintained a rigorous program for qualifying system engir.eer .
The licensed operator requalification training program remains satisfactory and operator training improved since the last assessment pariod. This was evident by'the results-of the requalification examination administered by-the NRC-in April 1992, with 16 of 16 operators (100 percent) and 5-of 6 crews (84 percent) passing these examinations.- O area that did not improve since requalification examinations-administered in 1991 was the quality of the proposed static simulator examinations. Also, crew communications and command and control effectiveness declined since-the 1991 requalification examinations, contributing to the crew failure during the April 1992 examination. Strengths were noted in the simulator modeling capability, especially -for secondary containment and radiation release parameters -
Also, the training staff's ability to evaluate crew and individual operator performance was very good. Six of six (100 percent) operators passed the Octcber 1992, Generic ,
Fundamentals Examination Sectio During the assessment period seven violations and one deviation were cite . Performance Ratina Category: 2 Recommendations
'
Non Safety Assessment /0uality Verification Analysis This functional area addresses those activities related to-licensee implementation of safety policies-related_to license amendments, exemptions and relief requests; responses to Generic Letters, Bulletins and Information Notices; resolution of safety issues; reviews.of plant
~n-. ~ . .
. ,
,
.
-17
,
modifications performed under 10 CFR 50.59; safety committee-activities; and the use of feedback from self-assessment programs and activitie As revealed during NRC's Special Appraisal of' Brunswick Operations (conducted from February 17 through May 1, 1992),
the licensee's performance had not been fully effective and many of the problem areas observed in the 1989 Diagnostic Evaluation were still present. The Special Appraisal identified the fundamental root causes for the continued-poor performance to be: (1) management's failure to set high standards for the material condition of the plant; (2) a failure of management to provide the leadership and-support needed for improvement; and (3) a lack of critical self-assessment, which resulted in the failure to recognize problems and implement effective corrective actio Established under the Integrated Action Plan, a number of improvement programs were already being implemented at Brunswick. One such program, which is indicative of a number of others, is the corrective action program (CAP).
Both the NRC Special Appraisal and the licensee's own self-assessment.found the CAP to be ineffective. Although the CAP lowered the threshold for problem identification, management support was inadequate, resulting in an increasing number of identified but uncorrected deficiencie Since the dual unit shutdown in April 1992, the licensee recognized the need to strengthen the safety policies at Brunswic Licensee management also realized.that the ,
standards and expectationc of Brunswick personnel at every level had to be raised. In addition, the licensee made significant management changes, both at the Brunswick site and at the corporate level.
. Other initiatives include the implementation of.a Staff Assistance. Team'(SAT) to assist the site management in the identification of procedural and process improvements. The
,
SAT, whose 71 recommendations for improvements _were at various stages of implementation at the end of the assessment period, appeared to have relieved _ site managers of some administrative burdens. -The previously established Site Incident Investigation Team (SIIT) process was utilized for eight events during the assessment period.-'SIIT investigations were generally. thorough and root cause l
determinations were acceptable.
l Following NRC prompting, the licensee developed structural L . verification programs to identify / correct.long-standing deficiencies involving safety-related walls, wall L -anchorages, and miscellaneous structural steel. Several l '.
, -
. .
,
,.4
'18'
improvements were necessary to these structural verification programs before-they ~were found to be acceptable. - The NRC's _ Safety Evaluation concluded that the scope, criteria -
and methodoloay of those programs when fully implemented would provide the licensee with adequate assurance that the safety-related walls, wall anchorages, and miscellaneous structural steel are restored to their design-basis.. An
.
interim implementation inspection by NRC of the licensee's
-
miscellaneous structural steel verification program found a number of quality assurance related problems (i.e.,-a lack'
of adequate procedures and errors ~in calculations). -These problems were subsequently corrected; and -implementation of the miscellaneous structural steel verification program, as well as the licensee's other structural verification programs, was still in progress at the end of-the. assessment perio The quality of the licensee's self-assessments improved during the assessment period. As indicated _in Section.IV.A, the licensee's self-assessment of repetitive-valve mispositions in_ the first half' of the ' assessment period was ineffective. Similarly, after expression of NRC conceras, self-assessments or, the material condition of the plant changed from indicating conditions as acceptable to unacceptable. Self-assessments identified that there was inadequate management support for either the CAP or the preventive maintenance program to be effective. This condition remained uncorrected despite licensee senior management directives in 1991 to address these problems. As .
there was. insufficient management sensitivity towards correcting issues raised by the self-assessments, the overall effectiveness of the process was limite Likewise, the licensee's quality control-(QC) program suffered from the same problem. ' QC was effective _in
-
inspecting outage-management and modification work activities, identifying many weaknesses involving procedures, procedural compliance, and material storag However, in general, management did not followup on identified deficiencies and assure appropriate corrective-action The licensee performed well in response to generic. issue For example, the licensee provided _a timely and conservative initial response to the Thermo-Lag issue (NRC Bulletin 92-01), including areas'that-were subsequently requested in Supplement 1 to the Bulletin. Similarly, the licensee completed implementation of modifications and tests require for the Station Blackout rule a few months ahead of the committed schedule. The licensee also provided: a timely response to Generic Letter 88-20, Individual Plant -
Examinatio Concerning licensing activities, the licensee-
- . .
._ . _ . , __ . _
- -
,
.
,
-
.
19'
.
generally-performed wel_1 and was responsive and knowledgeabl During the assessment period, four violations were cite . Performance Ratina Category: 3 Recommendations Despite improvements in problem identification, minimal corrective action followup and management support has limited the overall effectiveness of self-assessment Increased management attention is needed to improve the corrective action progra SUPP0iTING DATA AND SUMMARIES Licensee Activities Unit I began the assessment period at full power. A scram from full power as a result of losing an uninterruptable power supply occurred on January 17, 1992. The unit was restarted on January 19 and operated at essentially full power except for a power reduction to 30 percent on February 4 to permit bypassing a feed water heater. Unit I scrammed on February 29, 1992 from 80 percent power during. main turbine stop valve testing and restarted on March 5. Power was reduced to 60 percent on March 18 for three days due to Reactor Feed Pump problems. Unit I was subsequently operated at 100 percent power until it was shutdown due to seismic concerns associated with the diesel generator building walls ~on April 21, 1992._ The unit renained in cold shutdown for the remainder of the assessment perio Unit 2 began the assessment period in a refueling outage that began on September 11, 1991, and was restarted on December 13, 1991. The unit tripped from approximately 5 percent on ,
December 17, 1991,- while performing surveillance-testing on the residual heat removal system, The unit was restarted on December 18, but was-shutdown on December 22, due to failure of
-
the No. 3 main turbine bearing. Unit 2 was again started on January-3, 1992. During startup testing, problems with the_-
electro-hydraulic control (EHC) system and a main generator-to-exciter coupling required:the unit to shutdown-for repairs on January _ 10, 1992. After restart on January 11, 1992, and attainment of full- power, additional problems were encountered
-
with EHC/ turbine control valve oscillations. This required a power _ reduction to less.than-85 percent on January 16, 1992. Full power operation was conducted between January 24 and 30, 1992, to obtain data on the control valve oscilletions; power was subsequently reduced to less than 85 percent, t- -
- _ _ _ __ _ _ _ . _ _ _ _ . _ .. . _ _.- _.. __
- -
. .
..
20-On February 2, 1992, a Unit 2 scram from 80 percent power occurred during main steam control valve testing. During the scram one-feed pump seize Startup commenced on February 6, 1992, utilizing only one feed pump, but was-aborted the next day following additional equipment problems, -Restart began again on February 11, but the unit was shutdown from 6 percent power the next day due to seismic concerns in instrumentation cabinets. The unit was restarted on February 13,'1992, but was limited to 82 ,
percent power due to continued control valve problems. A power reduction to 80 percent was required on February 17, 1992, due to excessive main turbine vibration. Further reduction to 77 percent power was required on February 21, due to resonant harmonic-frequencies in a feed pump. Unit 2 operated at 77 percent power until March 18,1992, ,4 hen a Technical Specification required shutdown was commenced due to inoperable primary containment hydrogen / oxygen monitors. Power was reduced to 23 percent before one of the monitors was restored. The subsequent power increase was limited to 60 percent due to feed pump speed control problem Following repairs, power was returned to 77 percent on March 23,
'
1992. Unit 2 remained near this power level until it was shutdown on April 21, for the same reason as Unit 1. The unit remained in cold shutdown for the remainder of the assessment perio Significant management changes were made at the site and. corporate offic In December 1991 the Brunswick Maintenance Manager was replaced by the former Manager of Projects, Outage Management and Modifications. In January 1992 the temporary Manager - Operations moved to the corporate Nuclear Assessment Department and was permanently replaced by the former Manager - Regulatory Compliance. The corporate Nuclear Licensing Manager became the Manager - Regulatory Compliance. The Site Vice President -
Brunswick Project became the Vice President - Nuclear Services on April 1,1992, and was replaced by the former Site Vice President - !!arris Projec On September 1,-1992, the new position of President and Chief Operating Officer (C00) of CP&L was filled with a senior executive from another utilit Reporting directly to CP&L's Chairman and Chief Executive Officer, the C00 directs CP&L's Nuclear Operations, including Nuclear Assessment. The Brunswic_k Plant General Manager departed on October 7, 1992. Subsequently, each Brunswick unit was-assigned a separate Plant Manager, Operations Manager, and Maintenance Manager, Thew changes were made in order to provide more focused management attintion_on operations and maintenance improvements necessary to rei. urn the units to service and-to sustain reliable performance. On-0ctober 12, 1992, the former Manager - INP0 Events Analysis Department was appointed to the new position of Manager - Technical and Regulatory Support, reporting to the Site Vice President. Reporting directly under=this new position are
- the managers of Technical Support and Regulatory Complianc Similar restructuring resulted in the Environmental and Radiation Control Manager-indirectly reporting to the Site Vice President via the Control and Administration Manager. _ . _ - . . . _ _ _ - _ _ - .
_ _ _ _ _
.. . . .
=.
- -
.
.
p ,-
21 Direct Inspection and Review Activities During the assessment period, 25 routine and 12 special inspections were performed at the Brunswick facility by the NRC staff. The special inspections were:
- February 17 - March 27, 1992; Assessment of Work Control Programs
- March 9-13, 1992; Assessment of Radiological Protection and Emergency Preparedness
,
- March 23-27, 1992; Assessment of Physical Security Program _
- March 16-27, 1992; Assessment of Operations Unit
- March 30 - April 20, 1992; Assessment of Engineering / Technical Support
- February 17 - May 1,1992; Appraisal of Brunswick Operations
- May 26-28, 1992; Inspection of Chlorine Gas Release
- September 14-18 and 24-25, 1992; Structural Issues Inspection
- September 14-18, 1992; Evaluation of Pre / Post-Startup Work Screening Methodology
- October 5-9 and 19-23,-1992; Structural Issues Inspection
- October 2-30, ?992; Inspection of Inadvertent Draining of Unit 1 Reactor Coolant Syste Escalahd a Enforcement Action Orders Non . Civil Penalties (CP)
Severity Level III violation (EA 91-158) concerning inadequate corrective actions for continuing problems related to work-control and independent verificatio ($125,000 CP - Issued on January 3, 1992, this problem was addressed in the previous SALP report.)
Severity level III violation (EA 92-024) for a work control
- - - - _ - _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ _ - _ - _ _ - _ _ _ - _ _ _ _ _ _ _ . _ _ _
'
.
,-.
,
issue involving cleaning activities which resulted in the January 6, 1992 failure of EDG 2 to start on deman ($100,000 CP - Issued on March 24,1992.)
D. Management Conferences During the assessment period there were 13 significant management conferences with the licensee. These were:
- December 3,1991; Enforcement conference te discuss recurrent problems in the areas of work control and independent verificatio _
- January 23, 1992; Management meeting to discuss SALP Cycle 10 assessmen * January 23, 1992; Management meeting to discuss corrective actions taken for enforcement issue * tiarch 3,1992; Enforcement conference to discuss the failure of the No. 2 diesel generator to start on deman * May 12, 1992; Enforcement conference to discuss inadequate corrective action for seismic and structural issues at Brunswic * May 12, 1992; Management meeting to discuss corrective actions for masonry wall seismic qualification deficiencie * May 15, 1992; Management meeting far CP&L to present corporate initiatives to achieve sustained levels of good performance from CP&L's nuclear plant * June 8, 1992; Management meeting to discuss structural deficiencies identified at Brunswic * June 25, 1992; Management meeting to discuss CP&L's plans to resolve structural steel issues at Brunswic * July 16, 1992; Management meeting to discuss restart issues at Brunswic * August 10, 1992; Management meeting to discuss rectart issues at Brunswic * September 25, 1992; Management meeting to discuss restart issues at Brunswic * October 23, 1992; Management meeting to discuss restart issues at Brunswick, b _ _____ _ _ . _ _ _ _ ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _
.- .- . - - . .
-- ~ .. . . ~ . . _ . _ . . _ _ - ..
. . . .
9 .
!
23 Confirmation of-Action Letters Non Reactor Trips Unit 1 Two automatic reactor trips occurred:
- January 17, 1992; Low level reactor trip (from 100 percent a power) when the uninterruptable power' supply failed.
.
- February 29, 1992; Reactor Trip (from 80 percent power) du q-to a failure in the turbine stop valve master /f, lave logic '
during stop valve testing, d Unit 2 Two automatic reactor trips occurred:
- December 17, 1991; High fiux/ low power reactor trip (from 5 percent power) during surveillance testing when a defective test meter-caused a high pressure coolant -injection system initiation / cold water injection,
- February 2,1992; Reactor trip (from 79 percent power)
during main turbine control valve testing due to an electro-hydraulic control system failur Review of Licensee Event Report _s JLERsj During the assessment period, 41- LERs were analyze Special reports were submitted during the period by the licensee, but are'
-
not included in the table. The distribution of these events by cause, as determined by the NRC staff,-was as follows:
Unit-1 Cause or Common _ Unit 2_ Total Component Failure 10 4 14 Design . _3 _3:
Construction / Fabrication 2 2 4 Installation Personnel Errors-Operating Activity -7 2 9-Maintenance' Activity l
~
-l _
-Testing / Calibration Activity _2 2 4-0ther 1 'l Other 4 1 5 Totals 30 - 11 41 i
'. , _ , ,
__ . . . . . _ _ _ _ . _ _ . - _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ - _ _ . _ _ _ _ . _ _ . _ _ _
,
< -
.
,
l
'
.
Note 1: With regard to the area of " Personnel Errors", the NRC considers lack of procedures, inadequate procedures, and erroneous procedures to be classified as personnel erro Note 2: The "Other" category is comprised of LERs where there was a spurious signal or a totally unknown caus ,
i Licensino Activities During this assessment period, 12 licensing issues were resolve This includes one license amendment, one exemption, six generic actions and four other licensing actions. The most significant completion of multiplant activities was the implementation of actions related to station blackout and meeting the requirements l of 10 CFR 50.63, Enforcement Activity
\
FUKUDNAT hTi~~DF V!0LATTUf87FTIVERITY LEVEE :
AREA i 11 111 IV V DEV :
i
'
Plant Operations 61
<
Radiological Controls 1 i
'
Maintenance / Surveillance 1 2 1 Emergency Preparedness 1 Security 3 Engineering / Technical 7 1 Support Safety Assessment / 1* 3 Quality Verification TUTAL 2 23 2-
Includes a violation which was related to an event that occurred in the previous assessment perio '
,
-
l
,
l
!
i r
-...,<.-_,,..._m-.,--,.._.,..S,._,._,.,.ew.,,,_,,...u
-
-
.,w.,,m%,,,%__y_,..,..mm_r,mmy,,. ,,,,,pm.g.y,..-, , ,-y.y.,, , , , , , , , ,