IR 05000324/1993044
| ML20058P660 | |
| Person / Time | |
|---|---|
| Site: | Brunswick |
| Issue date: | 12/06/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058P655 | List: |
| References | |
| 50-324-93-44, 50-325-93-44, NUDOCS 9312270221 | |
| Download: ML20058P660 (7) | |
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SALP REPORT - BRUNSWICK NUCLEAR PLANT
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i 50-325/93-44 AND 50-324/93-44
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NOVEMBER 1, 1992 - NOVEMBER 6. 1993 1.
BACKGROUND The SALP Board convened on November 18, 1993, to assess the nuclear safety performance of Brunswick Units 1 and 2 for the period of November 1, 1992, through November 6, 1993.
The Board was conducted pursuant to NRC Management Directive 8.6, " Systematic Assessment of Licensee Performance." Board members
were Jon R. Johnson (Chairperson), Deputy Directer, Division of Reactor Projects, Region II (RII); Albert F. Gibson, Director, Division of Reactor
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Safety, RII; J. Philip Stohr, Director, Division of Radiation Safety and
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Safeguards, RII; and Singh Bajwa, Acting Director, Project Directorate 11-1, i
Office of Nuclear Reactor Regulation.
The performance category ratings and the assessment functional areas used below are defined and described in NRC Management Directive 8.6, " Systematic Assessment of Licensee Performance (SALP)."
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II.
PERFORMANCE ANALYSIS - PLANT OPERATIONS
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In this functional area, Carolina Power and Light Company's (CP&L's)
management attention and involvement have been weil focused on plant safety and have resulted in superior Unit 2 performance since restart in April 1993, and an excellent level of Unit I shutdown safety performance.
Corporate and site communications were excellent. Key vacancies in site management positions were filled with experienced managers.
Direction and oversight of the two units was separated to focus attention on each unit individually. Under a separate plant manager, each unit also had a separate
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operations manager, and maintenance manager.
Goals were established for operational readiness such as the number of allowaL+1e control room instrumentation problems, and the number of temporary modifications or
" operator workarounds." These and other expectations (including the status of I
achievement) were clearly communicated to site staff.
Excellent teamwork was observed during daily plant status and planning meetings. A comprehensive
"Three-Year Plan" was used to focus and monitor long-term improvements in the area of plant operations.
This was well thought out and efftctively used by all functional organizations.
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Plant operators performed well in plant restart assessments, as well as in the
power ascension testing and power operations of Unit 2 since April 1993.
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Shift turnovers and project briefings were observed to be excellent,
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especiall; during five demanding weeks of power ascension testing in the middle of this assessment period.
Control and direction of evolutions by
senior reactor operators, as well as communication between senior reactor operators and reactor operators, was good.
Control room professionalism was very good. Site management provided excellent support to improve lighting, painting, and overall arrangement-of
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the shift supervisors' desk locations, carpeting, etc. A new work control center was established in an adjacent area outside the control room.
It was staffed on all shifts by a senior reactor operator who interfaced with plant
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maintenance staff. This resulted in a very quiet and controlled atmosphere in the control room. Administrative problems with tracking inactive license
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status, medical status and overtime approvals indicated a need for closer administrative oversight and independent assessment.
Weaknesses were noted in routine activities early in the period.
Events early in the assessment period (including two cases of untimely placement of certain instrumentation in the required trip condition, 3 delayed recognition of increased pressure in the residual heat removal system due to backleakage, and several configuration control events) indicated a knowledge weakness and a lack of a questioning attitude. However, CP&L' conducted a good assessment of causes of these events and implemented good corrective measures.
The trend in this type of performance was improved in the last half of the period.
The overall safety focus of plant operations was excellent. Notifications made to the NRC cf plant events were timely and conservative.
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standards were established for safety system readiness reviews. Tracking and management cf temporary modifications was consolidated to assist plant operators. Several long standing equipment deficiencies were corrected to enable more effective plant operations. Operations established conservative hold points during power ascension testing and met at each plateau to assure safety system performance was as expected. The safety focus was further demonstrated by management support to SR0 certification training for key plant managers.
Self-assessment programs by site line management were excellent.
CP&L implemented management backshift surveillance tours to monitor implementation of site programs and interface with shift operators. A comprehensive review
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process was implemented to assure correct prioritization of open work items.
Thorough self-assessments were conducted to assure Unit 2 readiness for.
restart in_ April 1993.
Shift supervisors conducted plant system walkdowns with the system engineers to assure that all significant deficiencies were corrected. Site organizations which could support plant operation conducted self-assessments to assure that their personnel and procedures were ready.
Furthermore, the station management conducted a detailed review of two years worth of Licensee Event Reports and Notices Of Violations to assure that
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previous corrective action had been effective.
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Operator response to plant transients was good.
Plant operations staff and plant support staff handled the' March 1993 storm and resulting loss of offsite-power extremely well. Overall operations and communications with offsite agencies was excellent. Operators were alert and handled a May 1993 turbine control valve transient very well. Although challenged by several issues such as control rod testing deficiencies, operators have safely controlled plant
operations without a trip or forced shutdown of Unit 2 since initial startup
in April 1993.
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p Excellent root cause assessments were made following several ncmalies in plant operations.
Examples include a reactor power and turbine control valve oscillation problem, switchyard salt buildup and insulation breakdown, and a control rod scram time problem.
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Operations coordination and centrcl of maintenance improved since the last assessment period. The primary rehcon,,as the new work control center,' and its effective use of preplanned daily work schedules approved by site managers.
Examples of where coordination and control were not adequate involved testing on a containment door during reactor'startup and switchyard activities involving the use of a forklift. These occurrences indicate a need for continued attention in the control of plant conditions as prerequisites for tests and maintenance.
The Plant Operations area is rated Category 1.
l III. PERFORMANCE ANALYSIS - MAINTENANCE j
Overall performance in the maintenance area improved during this assessment period. The condition of the plant was improved through effective a
identification and correction of deficiencies.
With few exceptions, the licensee maintained the low threshold for problem
identification-that was established late in the previous assessment period.
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Plant conditiont that had previously been considered as acceptable were identified as preblems. Many such problems were identified through a structured prograr. of plant walkdown inspections. An exception to this good j
performance was tSe licensee's failure to identify degradation of drywell-liners as a problem.
The licensee appropriately prioritized and substantially reduced the maintenance backlog during this assessment period. The administrative processes that were established (i.e., PN30, Integrated Recovery Methodology, and PN31, Line Management Self-Assessment Readiness for Restart of BNF Unit 2)
were effective in assuring that safety reviews and corrective actions were completed prior to restart.
The preventive maintenance program was generally effective in assuring reliability of plant equipment. An excaption was the failure to perform refurbishment of 4KV circuit breakers as recommended by the vendor. The licensee has developed a strategic plan for strengthening the preventive maintenance program over the next two years.
The licensee maintained effective testing programs. Surveillance test procedures were satisfactory and tests were performed on schedule. The inservice inspection program was strengthened. The quality of inservice inspection procedures and procedural compliance were good and examiners were well qualified.
The strength of this program was apparent in the development and implementation of procedures for examining the Unit I reactor vessel shroud. Additionally, an effective program was implemented for predicting erosion and corrosion in plant piping systems.
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Some improvement was evident in the area of work control, but problems in this i
area continued from the previous assessment period.
Problems included failure
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to follow procedures, procedural deficiencies, and inadequate coordination
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between Maintenance and Operations.
Performance was better on high priority
jobs, such as repairs of emergency diesel generators, than on jobs which
i received less management attention such as routine work in the transformer yard.
The licensee recognized the need for further improvements in the area of work controls and developed a Three-Year Plan initiative for achieving
these improvements.
j Performance in the area of maintenance planning improved over the assessment period. Early in the period, maintenance productivity was significantly
reduced by planning deficiencies.
Performance improved later in the period when staffing and training in the planning area were increased, the backlog of i
maintenance procedure changes was reduced, and a minor maintenance program was implemented which reduced the planning needed for simple jobs of low safety significance.
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Poor maintenance work practices, which were evident in the previous SALP period, continued to adversely effect the quality of maintenance. Overtorqued
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valves, improper gear adjustment, inadvertent grounding of a test lead, valve misalignment and welding deficiencies were attributed to such causes as weak i
procedures, lack of training and inadequate supervisory oversite. Most of
these deficiencies occurred early in the period. Corrective actions involving procedure improvements, as well as enhancements to maintenance craft and
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supervisory training, were effective in improving work practices later in the period. Continued work on reducing the backlog of maintenance procedure deficiencies is needed.
The Maintenance area is rated Category 2.
I IV.
PERFORMANCE ANALYSIS - ENGINEERING The overall performance in the Engineering area was good and improved-from the last assessment period.
Engineering performance and management initiatives demonstrated a proper-level of attention and resulted in a good level of safety performance.
Engineering staff was noted to be more involved in day-to-day plant activities.
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Management's efforts to focus engineering resources on safety-significant activities were well demonstrated by service water piping repair work and
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shroud repair analysis.
Late in the period CP&L initiated an organization change to move Engineering Support to the site. This will necessitate close
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oversight of the transition and the filling of key vacancies.
i The Brunswick Technical Support organization has been characterized by strengths in personnel training and performance.
Specifically, the actions i
by the System Engineers in readying assigned systems for turnover to the Operations organization was a significant contributor to the successful startup and operation of Unit 2.
This allowed for better prioritization and accomplishment of preventive and corrective maintenance, thereby minimizing the previous history of equipment malfunctions and temporary conditions. A
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well-established training and systems engineer qualification program, as well a
as the experience base of the personnel selected for this group, built a good foundation for the observed organizational performance.
During this assessment period the number of short-term structural integrity issues requiring engineering evaluations and the number' of outstanding
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engineering work requests have been reduced.
Recognizing the problems inherent in the design change process, a Configuration Change Management Steering Committee has been formed to resolve outstanding issues, simplify the
modification process, and obtain consistency between the nuclear sites.
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design workload for the Nuclear Engineering Department will remain heavy
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during this configuration change improvement program.
A number of significant modification projects have been completed during the assessment period. Work was completed on the digital feedwater controls,
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digital steam leak detection system and reactor water level instrumentation
for Unit 1, as well as installation of a hardened wet-well vent and the ongoing replacement of service water pumps and piping in both units. The engineering analyses to support T chnical Specification amendment applications l
were generally adequate. However, in some cases the scope of the submittals
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initially lacked the necessary details to support a review and had to be supplemented by additional information.
Self-assessment did not identify several design engineering errors. Design evaluation problems were observed, such as a failure to properly classify the compaction of backfill around buried service water piping as a safety-related i
activity. A more significant challenge occurred when a failure to adequately measure and evaluate the corrosion in the drywell ~ liner of Unit I was noted l
after other such corrosion in Unit 2 had been observed. The NRC staff had to'
prompt the licensee to recognize the full extent of the. Unit 1 problem. Also,
process control and personnel constraints may have led to the observed errors with engineering calculations for the Miscellaneous Steel Verification Program, the short-term qualification of the original service water pumps,- and the seismic design of the replacement service water pumps.
These deficiencies also indicated a weakness in CP&L's self-assessment of engineering.
The Design Basis Reconstitution Program has been continuing on the schedule described in the Brunswick Three-Year Plan.
Excellent progress was made in design basis reconstitution. This review effort has identified several issues during the SALP period.
Examples include identification of a single failure j
in the control logic for the control building emergency air filtration system,
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seismic deficiencies with containment atmospheric control monitors, and several problems that could have affected the operation of the standby gas.
treatment system.
I The Technical Support Group has generally provided good support for the maintenance of plant equipment. After a trend was identified in the failure j
rate of Westinghouse type MHCP and HFD molded case circuit breakers (MCCBs), a j
good root cause determination was made and prompt corrective action was taken to replace appropriate breakers.
Similarly, the stress analysis, torsiograph test data, and crankshaft inspection results were considered thorough and complete for the repair of emergency diesel generator number 1.
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engineering personnel failed to-recognize the.need to recalculate APRM Gain
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Unit 2 core thermal power limit) and also failed to determine the need-to l
' inspect recirculation pump shafts for cracking (as addressed in a 10 CFR Part 21 report).
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'I The. Engineering area is rated Category 2.
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Performance Analysis - Plant Support l
Overall, performance in the Plant Support area was superior. The performance-
-1 analysis of this new functional area included assessments of radiological _
j controls, chemistry, emergency preparedness, security, fire protection,. and.
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housekeeping.
]a A high level of performance was exhibited in the radiation exposure control.
J area.. This area was supported by an intensive, thorough self-assessment-program with good corrective. actions.
External and internal exposures were-effectively controlled. The person-rem / unit in 1992 was the lowest the plant i
has achieved since the first year of operations in 1976. The person-rem / unit
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for 1993 was projected-to exceed the plant's goal of 850 person-rem for the site, but is considered appropriate given the extensive emergent outage work.
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A number of excellent As Low As Reasonably Achievable-(ALARA)_ program.
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initiatives were completed to reduce person-rem totals. These. included: _the.
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hot spot reduction program, cleaning 'and ' flushing floor drains, chemical'-
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decontaminations, and improved shielding packages. : A good job was also done.
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in implementing the new 10 CFR Part 20 a year before' required.
~j An excellent job was done in contamination control of work areas. This.
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contributed'to the overall decreasing trend of personnel contamination events-
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with the preparation of floor surfaces for painting._ A notable success in the
area was the recovery of the reactor water clean up phase-separator tank ~ room.
- This area had spilled. rsin on. the' floor for years due to the' tank j
overflowing. Clean.up was successfully achieved 'via robotics which saved
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person-rem.
Decontamination efforts in response to.the-October 1992
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Americium-241 event were also completed in an effective manner during this j
assessment period.
Increased management. support contributed to housekeeping
improvements, with the'. establishment of new standards, model spaces, and increased management presence. However, housekeeping. improvements were still
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needed in some areas such as the drywell and'other low visibility areas.
Radiological effluents were controlled well within applicable limits. The
- environmental monitoring program confirmed that there was no-appreciable ~
environmental impact due to radiological effluents. The solid radwaste
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program and the associated transportation program were both effectively implemented during the period. The chemistry program was also effectively implemented, as reflected by the Unit' 2 reactor coolant system being
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maintained well within specified limits since startup.
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Performance in the area of physical security improved this period. There was strong management support provided at both the site and corporate level as evidenced in.part by new equipment and improved facilities. Most importantly, maintenance of security equipment improved.
Better maintenance of hardware reduced the-reliance on compensatory measures, thereby reducing the opportunity for personnel error. The self audit program continued to be a strength. Timely and effective action was taken for problems during the period, such as the one associated with an instance of failure to properly control access.
The newly implemented access authorization program was
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effective. There was, however, a problem associated with the program during -
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the middle of the period, but it was properly corrected. Training and-i qualification of staff for contingency response were good, showing continued improvement.
j The emergency preparedness program was effectively implemented with strong management support. Additional staffing was provided to facilitate maintenance of a high level of performance.
In general, self-assessments (including exercise critiques) were well done. An excellent hurricane readiness assessment (prompted by lessons learned from Hurricane Andrew) was conducted with substantial upgrading of communications capability and procedures as a result. Hurricane preparations were tested in a drill and later in preparation for Hurricane Emily, when it appeared it might impact the i
site.
In both cases performance was good.
Plant staff also responded well to events from an emergency preparedness perspective during this period. Three events were properly classified as Notification of Unusual Events with timely notifications. Interaction with and support for offsite emergency preparedness agencies was considered a strength. Also noteworthy in this general area is
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the upgrading of the offsite early warning notification system.
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period there were problems associated with maintaining emergency equipment and'
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maintaining procedures current at the Emergency Operations Facility. These
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problems were corrected without recurrence.
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The licensee continued to implement an adequate fire protection program during this assessment period.
Positive features of the program were fire brigade.
performance and the fire barrier reinspection programs. The fire brigade exhibited good command and control, good fireground tactics, and rescue operations during an observed drill. The fire barrier reinspection program was an example of good self-assessment and correction for identified deficiencies.
Fire watches were observed to be attentive during the period.
Ownership of the fire protection program was a concern early in the period.
This was adequately addressed by licensee management, and ownership is now well established.
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The Plant Support area is rated Category 1.
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