IR 05000324/2005011
| ML060170002 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/13/2006 |
| From: | Fredrickson P NRC/RGN-II/DRP/RPB4 |
| To: | Scarola J Carolina Power & Light Co |
| References | |
| IR-05-011 | |
| Download: ML060170002 (16) | |
Text
January 13, 2006
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000325/2005011 AND 05000324/2005011
Dear Mr. Scarola:
On December 16, 2005, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at the Brunswick Steam Electric Plant. The enclosed report documents the inspection results, which were discussed on December 16, 2005, with you and other members of your staff.
This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel.
As an incentive to encourage licensee participation in the International Atomic Energy Agency Operational Safety Review Team (OSART) Missions, the NRC determined that, for those NRC baseline inspections that overlap, either in part or fully, with an OSART review, a one-time regulatory credit (reduction in baseline inspection program), would be granted. Based on a review of the inspection report from an OSART inspection conducted at Brunswick in May, 2005, the NRC determined that Brunswick qualified for a 50% reduction of the inspection effort for NRC Inspection Procedure 71152, Identification and Resolution of Problems. As such, the scope of this inspection was reduced by 50% from a two-week to a one-week inspection.
On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The inspectors concluded that problems were properly identified, evaluated, and resolved within the Problem Identification and Resolution Programs.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of NRCs document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Paul E. Fredrickson, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No.:
50-325, 50-324 License No.:
Enclosure:
NRC Inspection Report No. 05000324/2005011 and 05000325/2005011 w/Attachment: Supplemental Information
REGION II==
Docket No:
50-324, 50-325 License No:
05000324/2005011, 05000325/2005011 Licensee:
Carolina Power and Light Facility:
Brunswick Steam Electric Plant, Units 1 & 2 Location:
8470 River Road SE Southport, NC 28461 Dates:
December 12-16, 2005 Inspectors:
G. MacDonald, Senior Project Engineer (Lead Inspector)
J. Austin, Resident Inspector, Brunswick M. Maymi, Reactor Inspector, Division of Reactor Safety Approved by:
P. Fredrickson, Chief Reactor Projects Branch 4 Division of Reactor Projects
Enclosure
SUMMARY
OF ISSUES
IR 05000325/2005011, 05000324/2005011; 12/12/2005 - 12/16/2005; Brunswick Steam Electric Plant, Units 1 and 2; Biennial baseline inspection of the identification and resolution of problems.
The inspection was conducted by a Region II senior project engineer, resident inspector, and reactor inspector. No findings of significance were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
Identification and Resolution of Problems The inspectors determined that the licensee was effective in identifying problems and entering them into the Corrective Action Program (CAP). One example was noted where new action requests/nuclear condition reports (ARs/NCRs) were not written for current failures, instead the issue was tracked with an old NCR. Problem evaluation and corrective action implementation were generally effective with deficiencies noted in corrective action timeliness and in the quality and timeliness of investigations. The inspectors noted several examples where significant adverse conditions had recurred, indicating that all root/contributing causes had not been determined or that corrective actions had not provided timely resolution. Significant investigations were ongoing and recent CAP process changes were initiated by management to address these issues. The inspectors did not identify any new CAP problems not already being addressed by the licensee. The inspectors determined that the site staff felt free to raise issues and that management wanted issues placed into the CAP for resolution. Some engineering department staffing and CAP workload distribution concerns were noted in the employee concerns program (ECP). The ECP coordinator and management were already addressing the underlying issues related to these concerns and their potential affect on plant equipment. The inspectors did not identify any reluctance to report safety concerns.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
a.
Effectiveness of Problem Identification
- (1) Inspection Scope The inspectors reviewed Procedure CAP-NGGC-0200, Corrective Action Program, Revision (Rev.) 16, which describes the administrative process for initiating and resolving problems. A nuclear condition report (NCR) is initiated to document problems that are significant adverse conditions (Priority 1), adverse conditions apparent cause (Priority 2), adverse conditions correct and trend (Priority 3) or improvement items (Priority 5).
The inspectors reviewed 98 NCRs initiated by the licensee since November 2003 (coinciding with the last NRC baseline problem identification and resolution inspection)
(PI&R) to verify that problems were being properly identified, appropriately characterized, and entered into the Corrective Action Program (CAP). The reviews primarily focused on issues associated with three risk-significant systems: reactor core isolation cooling (RCIC), instrument air, and emergency diesel generator (EDG),ventilation. The inspectors scope also included select NCRs related to the findings included in the NRC inspection reports (IRs) and licensee event reports (LERs) issued since the last PI&R inspection. The sample also included several of the oldest open NCRs.
The inspectors conducted walkdowns of the RCIC, EDG ventilation, instrument air, service air, and backup nitrogen systems to verify that problems had been properly identified and characterized in the CAP. System performance was reviewed by discussion with system engineers and by review of system corrective and preventive maintenance (PM) history. The inspectors reviewed work requests (WRs) and completed maintenance work orders (WOs), selected completed PMs, maintenance rule data, and system health reports for these risk-significant systems to verify that equipment deficiencies were being appropriately entered into the CAP. Control room operator logs for the month of November 2005, were reviewed to verify that NCRs were initiated for deficiencies described in the logs. The daily WRs for December 13 and 14 were reviewed to determine if any WR issues had met the criteria for NCR generation, but an NCR had not been initiated.
The inspectors reviewed six selected industry operating experience items to verify that the items were appropriately evaluated for applicability and whether issues identified through these reviews were entered into the CAP. The inspectors reviewed licensee audits and self-assessments (focusing primarily on problem identification and resolution)to verify that findings were entered into the CAP and to verify that these findings were consistent with the NRCs assessment of the licensees CAP.
Documents reviewed are listed in the Attachment.
- (2) Assessment The inspectors determined that the licensee was effective in identifying problems and entering them into the CAP. Other than those already entered into the CAP by the licensee, no conditions adverse to quality were identified by the inspectors during walkdowns or WR/WO reviews. The site and department NCR generation rate remained relatively constant for 2004 and 2005. The inspectors determined that the Operational Safety Review Team (OSART) findings identified during a May 2005 inspection were input to the CAP. The licensee was effective in evaluating internal and external industry operating experience items for applicability and entering issues into the CAP. Department self-assessments and audits performed by the Nuclear Assessment Section were effective in identifying issues and entering these deficiencies into the CAP.
During the review of completed instrument air system preventive maintenance work orders, the inspectors identified calibration procedures that did not identify which instruments were being used to satisfy Technical Specification surveillance requirement 3.6.5.1. NCR 178856 was written and a five year maintenance history review of the instruments revealed no issues. During the RCIC system walkdown, the inspectors noted 2 danger tags laying on the floor of a contaminated area adjacent to the RCIC pump. The licensee subsequently determined that the danger tags had been properly removed from the components approximately six months ago, but not properly disposed of. This issue was entered into the CAP as AR 178993178993 During the EDG ventilation system walkdown, scaffolding and a ladder were noted to be stored in the EDG supply fan inlet plenum. The EDG 4 exhaust fan damper was noted to be open with the exhaust fan off. WR 220540 was written for resolution.
During the review of operator logs, it was noted that there had been eight control room recorder failures in November 2005, and WOs were utilized for repair rather than a trend NCR. The licensee had been relying on a previous AR to address the aging control room recorder issue. AR 23915 was generated September 21, 2000 to address the recorder issues.
b.
Prioritization and Evaluation of Issues
- (1) Inspection Scope The inspectors reviewed the same 98 NCRs discussed in Section 4OA2.a to verify that the licensee properly classified the problems in accordance with Procedures CAP-NGGC-0200 and CAP-NGGC-0205. The majority of NCRs reviewed were classified as Priority 2, with 16 classified as Priority 1. The inspectors review was also intended to verify that the licensee had determined the apparent cause of problems and adequately addressed operability, reportability, common cause, generic concerns, and extent of condition. For significant conditions adverse to quality, the review was also to verify that the licensee had adequately determined the root and contributing causes and to assess the thoroughness and timeliness of the investigations. The inspectors also reviewed a sample of cancelled NCRs to verify they were voided for appropriate reasons.
- (2) Assessment The inspectors did not note any examples of misclassified NCRs and determined that the licensee properly prioritized issues in accordance with Procedure CAP-NGGC-0200, when entering them into the CAP. Also, no examples were noted of inappropriately cancelled NCRs. The inspectors noted frequent investigation extensions in the sample of significant adverse condition investigations (SACI) reviewed and that several of the SACIs were performed by individuals not by teams.
In the sample reviewed, the inspectors noted several examples where the cause evaluations could have been more thorough. The examples included foreign material in the Unit 1 main condenser in the B115R1 refueling outage, the EDG ventilation supply fan main control room control switch and the EDG ventilation damper solenoid valves.
The inspectors noted examples where significant adverse conditions recurred which meant that either the problem evaluation was weak and did not identify all root and contributing causes or that corrective actions did not address all the root and contributing causes. The CAP self assessments had also identified weaknesses with investigations and a SACI had been initiated to improve the quality of investigations.
The examples noted by the inspectors were contained in the licensees SACI which is currently ongoing. The inspectors also noted several recent CAP process changes implemented by management including the daily AR reviews and the use of corrective action review board to review SACIs.
c.
Effectiveness of Corrective Actions
- (1) Inspection Scope The inspectors evaluated the same 98 NCRs discussed in Section 4OA2.a to verify that the licensee had identified and implemented timely and appropriate corrective actions to address problems. The inspectors reviewed the corrective actions to verify that they adequately addressed the described problem, the identified root/apparent causes and were properly documented, assigned, and tracked to ensure completion. Selected corrective actions were sampled for detailed review to independently verify that corrective actions were implemented as intended. The sample selected for verification included corrective actions associated with NRC findings, LERs, as well as other NCRs associated with the focus systems. Additionally, the inspectors reviewed a sampling of the oldest NCRs to verify that implementation delays were appropriately justified.
- (2) Assessment Overall, corrective actions developed and implemented for problems were generally appropriate to the problem, however the inspectors noted several examples where significant adverse conditions recurred. The inspectors concluded that this showed that some of the corrective actions were either not timely or did not address all potential root/contributing causes. Examples noted were condenser tube ruptures, switchyard power circuit breakers and instrument air/service air dryers. The licensee had already identified this concern and a SACI was open on this problem. In the sample reviewed, the inspectors noted several examples where corrective actions and corrective actions to prevent recurrence were not meeting CAP timeliness goals. This observation was consistent with a negative trend noted by the licensees CAP monitoring. There was a SACI addressing several improvement initiatives to address CAP timeliness.
In verifying corrective action implementation, the inspectors noted an unlabeled valve during the instrument air system walkdown. This condition had been previously identified by an NCR, and the valve had been added to the scope of an already existing engineering change to identify the valve, add it to drawings and procedures, and have it labeled in the field. The engineering change was closed with no label attached to the valve in the field. NCR 178715 was written to address the issue.
The inspectors noted examples where effectiveness reviews were not scheduled within CAP timeliness goals. Recently CAP process changes were implemented by management to improve corrective action implementation, including daily AR/NCR reviews and instituting a corrective action review board to review SACIs. The inspectors noted that the OSART report indicated a timeliness issue with corrective action for long term material condition issues. Self assessments identified that management attention should be focused on corrective action implementation.
d.
Assessment of Safety-Conscious Work Environment
- (1) Inspection Scope The inspectors conducted interviews with randomly selected members of the plant staff, including management, operations, maintenance, engineering, and CAP personnel, to develop a perspective of the safety-conscious work environment (SCWE) at the site and the willingness of personnel to use the CAP, and employee concerns program (ECP).
The interviews were also to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors interviewed the ECP Coordinator and reviewed a select number of ECP files completed since November 2003, to verify that concerns were being properly reviewed and that identified deficiencies were being resolved in accordance with Procedure REG-NGGC-0001, Employee Concerns Program.
- (2) Assessment The inspectors concluded that licensee management emphasized the need for all employees to identify and report problems using the CAP, ECP, and Work Order System. These methods were readily accessible to all employees. Licensee management encouraged employees to promptly identify nonconforming conditions.
Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that the site staff felt free to raise issues and
CP&L that management wanted issues placed into the CAP for resolution. None of the staff interviewed felt that valid issues had been cancelled. The inspectors noted that, for the ECP files they had reviewed, ARs were initiated in the CAP for any condition adverse to quality that had been identified in the file. Some SCWE concerns were noted in the ECP files reviewed related to the engineering department. The concern was primarily related to workload and the ECP coordinator and management were addressing the underlying issues of staffing and CAP workload distribution and its potential affect on plant equipment. The inspectors did not identify any reluctance to report safety concerns.
4OA6 Management Meetings
The inspectors presented the inspection results to Mr. Scarola and other members of licensee management at the conclusion of the inspection on December 16, 2005 The inspectors confirmed that proprietary information was not retained following the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. Scarola, Site Vice President
- T. Cleary, Director Site Operations
- B. Waldrep, Plant General Manager
- A. Pope, Manager-Operations
- E. ONeil, Manager-Support Services
- S. Rogers, Manager-Nuclear Assessment
- J. Ferguson, Manager-E&RC
- D. Griffith, Manager-Outage & Scheduling
- J. Gawron, Manager-Training
- P. Dubrouillett, Superintendent-System Engineering
- G. Johnson, Superintendent-Self Evaluation/Doc Srvcs
- L. Beller, Supervisor-Licensing/Regulatory Programs
- L. Grzeck, Sr. Engineer-Licensing
NRC Personnel
- G. DiPaolo, Senior Resident Inspector
- J. Austin, Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None