ML19270H107
| ML19270H107 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/10/1979 |
| From: | Reis E NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7906230024 | |
| Download: ML19270H107 (81) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
' Docket Nos. 50-400 CAROLINA POWER AND LIGHT COMPANY
)
50-401
)
50-402 (Shearon Harris Nuclear Power Plant, )
50-403 Units 1, 2, 3 and 4)
)
STAFF'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM 0F A SUPPLEMENTAL INITIAL DECISION (CONSTRUCTION PERMITS)
May 10, 1979 22147 096 Edwir J. Reis Counsol for NRC Staff 4
7 9 623 00 R.4 0
i INDEX Page I.
Preliminary Statement and Description of the Record....
1 II.
CP&L's Quality Control and Training Structure.......
4 III. NRR's Review of CP&L's Quality Control and Management Ca pa b i l i ty...
9 IV.
Office of Inspection and Enforcement Functions.......
18
~
V.
I&E Experience With the Construction of CP&L Nuclear Facilities.....................
22 VI.
'I&E Experience With the Operation of CP&L Nuclea r Fa ci l i ti es.....................
35 VII.
Views of Individual I&E Inspectors.............
57 VIII. Ranking Utilities Having Nuclear Power Facilities.....
74 IX.
Concl us i ons o f Law.....................
75 X.
Order...........................
76 Note: The record citation to testimony are given to transcript pages by the notation Tr., or to the pages of prefiled testimony by the notation p. or pp.
This prefiled testimony appears after the following transcript pages:
Licensee's witness -
22L47 097 Jones
- Tr. 3494 Utley and Banks - Tr. 3502 McDuffie
- Tr. 3505 McMannus
- Tr. 3769
ii NRC Staff Witnesses -
Staff Panel I (Long, Murphy, Dance
- Tr. 2198 and Brownlee)
Staff Panel II (Murphy, Bryant, Herdt,
- Tr. 2539 Brownlee and McFarland)
Staff Panel III (Long and Dance)
- Tr. 2937 Staff Panel IV) (Miner, Haass, Schwencer - Tr. 3260 and Allenspack)
Wilber
- Tr. 2836 Cantrell
- Tr. 3_347 2247 098
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMi1ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-400 CAROLIflA POWER & LIGHT COMPANY
)
50-401
)
50-402 (Shearon Harris Nuclear Power
)
50-403 Plant, Units 1, 2, 3 and 4)
)
STAFF'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A SUPPLEMENTAL INITIAL DECISION (CONSTRUCTION PERMITS)
I.
PRELIMINARY STATEMENT AND DESCRITPION OF THE RECORD 1.
On January 23, 1978, the Atomic Safety and Licensing Board in this proceeding ("the Board") issued an initial decision authorizing construction permits for the Shearon Harris Nuclear Power Plant, Units 1, 2, 3 and 4,
(" Harris" or "the Harris Plant").
7 NRC 92 (1978).
Construction Permits (CPPR-158,159,160 and 161) were thereafter issued to Carolina Power &
Light Company ("CP&L" or " Applicant") on January 27, 1978.
43 Fed. Reg. 4465 (February 2, 1978).
On August 23, 1978, the initial decision was affirmed by the Atomic Safety and Licensing Appeal Board ("the Appeal Board")inALAB-490.S 8 NRC 234 (1978).
N e Appeal Board deferred decision with respect to the environmental Th impacts of the release of radon-222, and its effect on the Board's cost-benefit balance. The Appeal Board noted that it anticipates reaching the radon issue after disposing of the issue in one or more of the cases in which it is contested.
8 NRC at 242.
2247 099
2.
In the course of former proceedings before the Lice' sing Board, the n
Licensing Board had addressed a series of questions on January 23, 1975 and August 30, 1977, to the NRC Staff and CP&L.
The questions asked the Staff were:
1.
What is the Staff's evaluation of the management capa-bilities of CP&L which have been observed during con-struction and operation of CP&L's other nuclear plants?
How does CP&L compare with other. licensees?
2.
What particular experiences, both good and bad, have CP&t had with management of nuclear plants? How nave these experiences been utilized to improve the management capabilities of CP&L?
3.
Have sufficient additional personnel been added to CP&L to adequately manage the Harris plant?
4.
(Directed to CP&L).
5.
Are written procedures available and personnel trained to follow these procedures if a safety-related incident occurs? Who reviews these procedures? How are the results audited? How does CP&L discover incipient problems before the incipient problems become an incident? Do employees who report incipient problems receive rewards in some manner? How?
6.
Whether the delay in this proceeding has had a significant effect upon the Shearon Harris Nuclear Power Materials stored therein.
Testimony was presented by Hugh Dance and James Brownlee of the Region II Office of Inspection and Enforcement of NRC in answer to these questions (Tr. 2074-2079).
On this basis and material in the Preliminary Safety Analysis Report and the Safety Evaluation, the Licensing Board found the 2247 100
.. Applicant technically qualified and indicated it was satisfied with the responses to its questions regarding management and quality control (Fdgs. 47-55, 7 NRC 106-109).
3.
On April 18, 1978, Staff counsel advised the Appeal Board, before whom the Licensing Board's determination was pending for review that "It has come to our attention that one of the inspectors at Applicant's Brunswick facility felt his views on the management capability of Applicant to staff and operate the Harris facility had not adequately been presented to the Licensing Board." 8 NRC at 242.
NRC Staff counsel forwarded to the Appeal Board the line inspector's handwritten notes dated September 16, 1977 (which the line inspector had furnished to his supervisors to assist them in preparation of testimony).
Staff counsel stated in the April 18, 1978 letter that he had reviewed both the notes and the testimony and had concluded that the testimony " adequately reflected the factual content" of the notes. While the Appeal Board found the testimony in the context of the line inspector's notes to be " troublesome," it affirmed the Board's initial decision, noting both its concern that the Licensing Board had not inquired into the matter at the hearings and its expectation that the Commission's Office of Inspection a..d Enforcement ("I&E") will undertake and maintain surveillance of the construction and operation of the Shearon Harris facility to insure that remedial measures are adopted by Applicant to rectify the problems identified in the testimony.
3 NRC at 244.
2247 101
4-11.
The NRC Staff adopts the Licensee's proposed findings 3 through 10.
12.
In support of its direct case the Staff presented as witnesses the inspectors and their supervisors who inspected the Applicant's Robinson and Brunswick nuclear generating units from their inception and Harris as so far con-structed as well as Washington based NRR personnel who dealt with these units.
Computer printouts summarizing all inspection and all Licensee Event Reports of the Carolina Power and Light Company's (CP&L) nuclear facilities were introduced as evidence.
The Applicant offered as witnesses its personnel familiar with the nuclear units from its Executive Vice President to its manager, corporate nuclear safety and quality assurance audit section.
Floyd S. Cantrell the I&E inspector who previously felt his views were not adequately set forth was a witness.
All witnesses were extensively questioned by the Board, all parties, and the North Carolina Attorney General's Office.
II. CP&L'S QUALITY CONTROL AND TRAINING STRUCTURE 13.
Carolina Power & Light Company (CP&L) has divided its corporate organization into two main areas, administration and operations.
J. A. Jones is Executive Vice President and Chief Operating Officer for CP&L.
(Jones following Tr. 3494, pp. 9-11, 26-29).
Reporting to Mr. Jones are three Senior Vice Presidents (M. A. McDuffie, Engineering & Construction Group; 2247 102
.. E. E. Utley, Power Supply Group; and W. J. Ridout, Customer & Operating Services Group) and a Department Head (W. W. Morgan, Systems Planning
& Coordination Department).
(Jones,pp.13-15).
Mr. Utley described the Power Supply Group and its organization and funct. ions, particularly with respect to management of the Company's nuclear program. (Utley-Banks following Tr. 3502, pp. 5-8). Mr. Harold R. Banks, CP&L's Manager -
Nuclear Generation, described the organizational structure of CP&L's two operating nuclear power plants, H. B. Robinson Plant (" Robinson Plant" or " Robinson") and brunswick Steam Electric Plant (" Brunswick Plant" or
" Brunswick").
Utley-Banks, pp.11-15. Mr. McDuffie described the major functions and the basic organization of the Engineering & Construction Group as it relates to the nuclear program, and in particular to con';truction of the Harris Plant. (McDuffie following Tr. 3505, pp. 3-8).
14.
Quality Assurance (QA) and quality control activities in the CP&L are conducted at three levels - the corporate level, the senior Vice-President level and the plant or construction site level.
On the corporate level by a Manager for Corporate Nuclear Safety and Quality Assurance who reviews and audits all of CP&L's other quality assurance activities, its nuclear facility construction and operations, and reports to CP&L's President and Executive Vice President for Operations through the CP&L Vice-President for Administration, independently of the Senior Vice-President for Construction and Engineering and the Vice-President for Power Supply (McMannus following Tr. 3769: Jones followino Tr. 3404, pp. 17-20).
2247 103
15.
Under the Senior Vice-President for Power Supply, who oversees the operating plants, there is an Operations Quality Assurance Section which conducts surveillance of plant operations independent of the plant managers and provides technical advice on operating and regulatory matters (Utley and Banks, following Tr. 3502, pp. 70-72; Staff Panel III (Long & Dance) following Tr. 2937, pp. 3-11).
It has 5 of the 424 employees directly under this Senior Vice-President (Utley & Banks, p. 9).
At each operating plant there are also quality assurance organizations independent of other activities to see that quality is maintained and nuclear safety codes are followed (Utley & Banks, p. 70-72).
At the Robinson plant this group has five of approximately 200 employees at the plant and at Brunswick.
it has 7 employees of the 348 employees at the plant (Ibid., pp. 27, 28, 102, 105, Tr. 3652; Long & Dance, p. 4-5).
At Harris when the 4 projected units are operated it is projected that the quality assurance staff will consist of 16 out of 755 employees (Utley, Tr. 3707).
16.
Under the senior Vice-President for Construction and Engineering, who oversees the construction of Harris there is also a quality assurance unit 17 of whose employees spend some time being concerned with the Harris project (McDuffie following Tr. 3505, pp. 23-30, 47; Staff Panel II (Murphy, Bryant, Herdt, Brownlee and McFarland, following Tr. 2539, pp. 9-13). At the Harris site there is a separate quality assurance group of 40 employees (McDuffie, pp. 27,47-48).
2247 104
- 17.
CP&L is engaged in active training programs to train people both to construct and operate the Harris facility (Utley & Banks following Tr. 3502, pp. 73-76; McDuffie following Tr. 3505, pp. 38-36.
Further, Applicant is engaged in substantial efforts to recruit an adequate staff to operate Harris (Utley & Banks, pp. 84-97).
18.
CP&L has made substantial improvements in its training programs and facilities.
(Utley-Banks, pp. 73-76, F. Tr. 3492).
In anticipation of the large numbers of' technical and craft persons which will be required by CP&L for the Harris Plant and other plants in the future, CP&L has established a centralized training facility at the Harris Energy &
Environmental Center located near the Harris Plant site (Utley-Banks,
- p. 91).
CP&L submitted a synopsis of the long-range training plans for the Generation Department and the schedule of implementation of its training program.
(CP&L Exhibit HH).
A PWR simulator has been installed at the Harris Energy & Environmental Center.
Operations personnel from the Robinson Plant are presently receiving " hot" license training and retraining on the PWR simulator; this simulator will be used extensively in training personnel for the Harris Plant.
(Utley-Banks, p. 75).
Staff witnesses testified that inspectors who have seen the Harris training facilities are favorably impressed.
(long,Tr. 2947,3218).
2247 105
19.
At the Harris site CP&L has provided a craft training coordinator whose full-time assignment is to coordinate and monitor the on-site training programs.
At the time of the hearing 468 craftsmen had completed training and 165 more were enrolled. With CP&L's approval and encouragement, Daniel International has also established training in several craft areas.
CP&L's direct participation in craft training is an improvement over the situation at the Brunswick Plant where formal training was limited to welding, which was under contractor control.
(McDuffie,
- p. 38-39, Appendix 6, Tr. 3492). The Staff has reviewed Applicant's proposed training program and has found it adequate to assure that a qualified and capable operating staff will be available.
(Staff Panel IV, p.19).
20.
CP&L management testified that it is committed to quality control and that it was the duty of all its senior personnel to see that all NRC require-ments were followed and we believe them (Jones, p. 20, Utley, Tr. 3627, 3702).
Senior management of CP&L were and are concerned with safety and quality control, and follow-up to see action is taken toward these goals (Utley, Tr. 3736, 3737; McMannus, Tr. 3771,3776).
However, the CP&L's concern with safety is not the same as the NRC's (Utley, Tr. 3627, 3637; Staff Panel III, following Tr. 2937, p.11; Dance, Tr. 2930; Long, Tr.
3015-3016,3050-51). For example; although the Senior Vice President for Power Supply receives power generation reports each day and im-mediate reports on units put out of service all of which create pressure 2247 106
, to operate, he does not receive all licensee event reports sent to the f1RC but only monthly LER tread reports with which he is not particularly familiar (Utley & Banks, p.16-17; Utley, Tr. 3652-3,3698).
The attitude of CP&L toward the resolution of problem and taking corrective action can be characterized as " conservative," not in a safety but in a financial sense.
(Long,Tr. 3008-3012).
It will strongly insist that any f1RC pressure on them to change operations in a way that might increase costs without clear indication that there was a positive contribution to safety or a regulatory base for the change (Long & Dance, Tr. 2971-2976; 3015-3016).
Once convinced the matter is necessary for safety or required by regulations, CP&L does take the required action (Ibid.).
However, none of thest. matters affect the conclusion that CP&L should be licensed, and that there is ao need to condition that license (see, e.g., Long, Tr. 2478, 2479, 2487-2439; Staff Panel III, pp. 70-72).
III. flRR'S REVIEW 0F CP&L'S QUALITY CONTROL AND MAf!AGEf1Ef4T CAPABILITY 21.
Under 10 CFR 550.40(b) the Staff is required to determine whether an applicant for a construction permit is technically qualified to engage in the proposed activities which, at this stage, are the design and construction of the proposed facility.
The technical and managerial capability of an applicant needs to have within his own organization varies over a broad range depending upon several factors.
These are the utilization of previous designs, the development of new or unique design 2247 107
_ features, and the degree to which the utility eithe'r retains internally or contracts for design, engineering and construction services and specialized consultants to undertake the details of the design and construction of the proposed facility.
(Staff Panel IV (Miner, Schwencer, Haass & Allenspack following Tr. 3260, p. 6)). A review of these matters is done through the Office of fluclear Reactor Regulation (fiRR) (Ibid).
- 22. Accordingly, the Staff must evaluate each utility individually and make a determination regarding the technical qualifications of that utility to undartake the activities that would be authorized by a construction permit.
A finding by the Staff on this subject is subjective and judgmental in nature, and no specific quantitative guidelines are avail-able for making this determination.
However, the Staff has identified and defined the factors that provide the basis for making the overall judgment regarding the applicant's technical qualifications (Staff Panel IV, pp. 1-7).
The specific items which were considered by flRR in evaluating CP&L's technical capability are:
1.
the applicants organizational structure to design and construct the facility; 2.
the experience and capability of the applicant's technical staff; 3.
the applicant's performance during the licensing process in resolving problems and meeting f1RC requirements; 4.
the applicant's quality assurance program; 2247 108
~
- 5.
the applicant's past experience in the design and construction of nuclear plants or in activities of similar scope and complexity; 6.
the past experience of the applicant's principal contractors; and 7.
the applicant's organizational structure to operate the plant once it is built.
(Staff Panel IV, p. 9).
23.
NRR belie','s CP&L's structure provides clear lines of authority and divisions of responsibility for the Shearon Harris project and is thus acceptable in this regard.
The CP&L Engineering and Construction Group, under a Senior Vice-President, has the primary responsibility for the design and construction of the Shearon Harris facility.
The functions of the Engineering and Construction Group are implemented through several departments as shown. The Power Plant Engineering Department implements CP&L's responsibility for the design of the Shearon Harris facility.
The Power Plant Construction Department, implements CP&L's responsibility for the construction of the Shearon Harris facility.
The Technical Services Department implements CP&L's responsibility for nuclear licensing and quality assurance activities for engineering, design and construction activities for the Shearon Harris facility.
(Staff Panel IV, p. 10).
2247 109
. 24.
flRR has reviewed the personnel qualifications of key personnel associated with the Shearon Harris project.
f1RR finds these persons have extensive experience in their fields, including experience in nuclear power plant projects.
It concluded in its judgment, that the manpower levels currently assigned, the availability of additional personnel, and the experience levels of key personnel are adequate for CP&L to carry out its responsibility for the Shearon Harris project.
At the time of the flRR survey of CP&L the Power Plant Engineering Department had a current roster of approximately 62 professionals of which about 13 are currently assigned to the Shearon Harris project.
Approximately 31 additional professionals are assigned to the project on an as needed basis.
The Technical Services Department had a current roster of approximately 94 professionals of which about 38 are currently assigned to the Shearon Harris project. Approximately 46 other professionals are assigned to the project on an as needed basis.
The Power Plant Construction Department had a current roster of approximately 112 professionals of which about 56 are currently assigned to the Shearon Harris project.
Approximately 21 other professionals are assigned to the project on an as needed basis.
(Staff Panel IV, pp. 8-11).
25.
CP&L, in the view of fiRR, also showed capability in the licensing process.
There have been two specific indications that flRR has observed during review of the Shearon Harris application that demonstrate that CP&L takes 2247 110
_ 13 -
an active role in its relationships with its principal contractors.
The first is the degree to which CP&L handles the discussions during its technical meetings with the Staff.
CP&L personnel led and participated fully in all technical meetings with the Staff, except those dealing with the most specialized technical areas.
As a result, flRR believes that the CP&L personnel involved had a full understanding of the technical issues that were being discussed.
(Staff Panel IV, p.12).
26.
A second indication of CP&L's active role with its principal contractors is the manner in which CP&L personnel approached technical issues with the Staff.
During review of an application, situations arise in which the Staff requires that an applicant conform to, or propose acceptable alternatives to numerous technical positions on various aspects of the design that affect the safety of the plant.
CP&L personnel have actively pursued the bases and background of the Staff positions in order to obtain a clear understar. ding of the Staff concerns so that they could respond appropriately.
In a number of cases CP&L disagreed with the Staff technical positions and proposed alternatives to the positions for Staff consideration.
These actions were for the most part taken in a timely manner such that resolution was reached in a manner acceptable to the Staff on almost all such issues.
This positive attitude and approach to the understanding and resolution of safety issues displayed by CP&L personnel during review of the 2247 111
. application are an important indication of the overall CP&L capability.
In addition, it is reasonable to assume that CP&L personnel have and will continue to have this same attitude and approach in their reviews and audits of the design i.nd construction activities of their principal contractors.
(Staff Panel IV, p.13).
27.
The Applicant's quality assurance (QA) program for the design and con-struction of the plant must meet the provisions of Appendix B to 10 CFR 50 and should satisfy the guidance given in pertinent Regulatory Guides and endorsed standards.
The NRR staff has reviewed and approved the Applicant's QA program.
A description of the Staff's evaluation of this program is presented in Section 15.0 of the Safety Evaluation Report and Supplement No. 2.
Since the issuance of these documents, CP&L has further strengthened its program by making commitments in later PSAR amendments to numerous Regulatory Guides on QA that were subsequently published.
A further strengthening of the QA commitment over and above those which appeared earlier in the PSAR have been the commitments made by Ebasco and Westinghouse to implement the QA provisions of their topical reports on QA; namely, Report Nos. ETR-001 titled "Ebasco Nuclear Quality Assurance Manual" and WCAP-8370 titled " Westinghouse Water Reactor Division Quality Assurance Plan." These reports include commitments relative to more recent Regulatory Guides in the QA area.
(Staff Panel IV, pp. 14-15).
2247 112
' i_ -
28.
By letter dated October 23, 1978, CP&L stated that they intend to make minor changes in their corporate QA program.
The functional responsibility for performance of QA audits of Westinghouse and its vendors, Ebasco and its vendors and other outside contractors will be shifted from the Corporate Nuclear Safety and Quality Assurance Audit Section to the Engineering and Construction Quality Assurance Section.
NRR has reviewed this change and finds that it satisfies Staff requirements and is therefore
~
acceptable. To summarize, NRR has found and continues to find CP&L's commitments on QA in'Section 1.8 of the PSAR to be acceptable.
(Staff Panel IV, pp. 9-15).
29.
NRR considers a utility's past experience ir. the design and construction of nuclear power plants and its past experience in activities of similar scope and complexity.
CP&L has been active in the nuclear field since 1956 when the company, in conjunction with several other utilities, formed the Carolina-Virginia Nuclear Power Associates, and built and operated the Parr Nuclear Plant which was a prototype of a commercial size plant.
In 1966, CP&L began work on the H. B. Robinson Nuclear Plant that went into commercial operation in 1971.
In 1968 CP&L began work on the Brunswick Steam Electric Station.
The two-unit Brunswick Steam Electric Station went inte commercial operation in 1975 and 1976.
As a result of its experience with these plants CP&L has strengthened their management and QA control for 2247 113
. the Shearon Harris Project.
NRR considers CP&L to be a utility with considerable experience in the design and construction of nuclear power plants.
(Staff Panel IV, p. 16).
30.
Applicant's principal subcontractors, Westinghouse, Ebasco and Daniels similarly have wide experience in the design, fabrication and construction of nuclear facilities.
The past experience of these principal contractors should indicate a capability to undertake a project of this magnitude
~
and complexity.
(Staff Panel IV, pp.17-18).
31.
In NRR's view, CPT.L's organizational structure to operate the nuclear facility, at the construction permit stage should indicate that adequate plans have been developed to assure that a qualified and capable operating staff will be available.
The Staff reviewed CP&L's proposed plans for selection and training of the personnel for the Shearon Harris facility.
NRR conclusions are reported in Sections 12.1 and 12.2 of the Safety Evaluation Report and Section 12.2.1 of Supplement No. 3 to the Safety Evaluation Report.
At the construction permit stage NRR reviewed the applicant's proposed plant staff organization, the qualification require-ments for those plant staff positions, and the proposed training program for the plant staff members.
At the cperating license stage the NRR staff 2247 114
17 -
will review the CP&L organizational structure and in particular the plant staff organization to assure that it will provide an adequate organizational arrangement and operating staff.
This review will include the organizational structure for the plant staff, the on-going training program, qualification requirements, and qualifications for key plant staff personnel.
Adequacy of staffing for initial operation is a responsibility of ilRR.
I&E, of course, verifies that the staffing is being carried out in accord with requirements.
(Staff Panel IV, p. 19).
32.
At the operating license stage flRR will also review CP&L's QA program for operations to assure that the program provides for a comprehensive system of planned and systematic controls such that quality-related activities for operations will be conducted in accordance without require-ments.
flRR has concluded that the CP&L has developed plans at the con-struction permit stage of review that provide reasonable assurance that a qualified and capable staff will be available for the operation of the Shearon Harris facility.
During the operating license review, flRR will evaluate the applicant's technical qualifications to operate the facility (Staff Panel IV, p.19).
33.
Based on flRR's evaluation as previously described, it is their conclusion that CP&L possesses the technical qualification to carry out its responsibilities with regard to the design and construction of the Shearon
- 1 M tt in:or:a t.ica regarding the performance Harri-iaciiity.
2247 115
. of CP&L on the Shearon Harris and other CP&L projects as described in Shearon Harris testimony prepared by the Region II staff of the Office of Inspection and Enforcement and NRR's conclusions with regard to CP&L's technical qualifications remain the same.
(Staff Panel IV, pp.16-20).
34.
Based on the substantial, probative and uncontradicted evidence of NRR personnel, the Board affirms the conclusions of the Office of Nuclear Reactor Regulation as expressed above.
IV.
OFFICE OF INSPECTION AND ENFORCEMENT FUNCTIONS 35.
The Commission's basic information regarding the actual construction and operation of a nuclear power plant is derived from inspection of the facility conducted by NRC's Office of Inspection and Enforcement (I&E).
These inspections in the case of CP&L are conducted by the Atlanta, Georgia, I&E regional office (Region II), which also reviews all Licensee Event Reports prepared by Licensees (Staff Panel I (Long, Murphy, Dance and Brownice) following Tr. 2198, pp. 4-5).
36.
Appendix B to 10 CFR 50 - Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, describes a management control system, or Quality Assurance Program (QAP), which each licensee must develop and implement.
The aim of this program is a pyramid control system which, 2247 116
_ 19 -
at the bottom assures through detailed inspection and test programs, that all safety significant actions are properly accomplished by craf tsmen using approved procedures.
These detailed verification programs require up to 100% inspection by the licensee's quality control personnel of a multitude of individual quality verifications.
I&E's inspection of an applicant's or licensee's QAP is a majnr function of the NRC's inspection program.
(Staff Panel I, p. 6).
37.
I&E seeks to assure that the licensee's programs meet NRC requirements, including those in 10 CFR, and any license, amendment, or technical specification.
In doing this, I&E performs selective inspection, but. does not attempt to perform a 100 % verification of all phases of the licensee's program.
This inspection of hardware, observation of testing, review of organization, procedures, records and all other inspection activities are not aimed at approval of individual components, actions, or procedures, but rather, at evaluating whether or not the licensee's management control systems are working.
(Staff Penel I, p. 6).
38.
The Headquarters' staff of I&E has the responsibility for the overall management and direction of the organization including the establishment of inspection and enforcement policies, programs and guidance.
Headquarters also has the responsibility for implementing escalated enforcement actions.
There are five Regional Offices which have the responsibility for implementing 2247 117
. the inspection and enforcement programs.
These responsibilities include the conduct of routine inspections, investigations and inquiries and taking enforcement actions as appropriate (Staff Panel I, p. 6).
39.
In Region II, where CP&L operates, the operational branches most concerned with CP&L are the Reactor Construction and Engineering Support Branch (RC&ESB), and the Reactor Operations and Nuclear Support Branch (RONS).
There are also a Security and Safeguards Branch, and a Fuels Facilities and Materials Safety Branch.
The RC&ES Branch inspects all the licensee's activities associated with the construction of the facility including design controls, procurement, vendor audits, site construction, the functioning of the management control systems and the QAP of facilities within Region II.
The Construction Branch follows up on problems identifed by the licensee and which by regulation are reported to the NRC.
The Branch also participates in investigations of allegations and inquiries into licensee's activities. The responsibilities of the RONS Branch are similar to those of RC&ESB except that they relate to the preoperational testing, startup testing and operation of nuclear reactor facilities (Staff Panel I, pp. 7-8).
40.
During all phases of inspections, whenever deficiencies are identified, I&E requires licensee action to prevent recurrence as well as to correct the specific deficiencies.
If the results of a single inspection, or a 2247 118
,. sequence of inspections, indicate a deterioration in the performance of the licensee's program, in-depth inspection will be conducted to upgrade the degree of control exercised at the highest level of the control system pyramid to assure that deterioration is checked and the program as a whole returned to a satisfactory level of quality (Panel I, p. 8).
41.
I&E conducts a sampling inspection program, but it is not a statistically random sample. The specific areas reviewed in detail are selected from those considered to be the most important from a nuclear safety standpoint.
By a specific spot checking and sampling review of QC actions I&E tests whether a licensee's QA program is really working.
Review of the overall program gives considerable confidence that spot checking and sampling reivew provides an accurate assessment of the licensee's performance in meeting regulatory requirements (Staff Panel I, p. 9).
42.
Inspection of the implementation of the licensee's Quality Assurance Program is a key element in the determination of its adequacy.
This inspection activity, still a non-random sample, involves checking whether actual work activities are in accordance with procedures, license requirements, technical specifications, plant and code requirements.
I&E inspectors question craftsmen and operators to determine if they understand, and are adhering to applicable limit and requirements.
The inspectors observe operating instruments and recorder charts to determine what operations are being 2247 119
. conducted within regulatory requirements.
They observe instruments being calibrated.
Observations are made as equipment is started up, shut down, or otherwise changed in operating mode.
These observations and individual discussions with, and questioning of, people actually doing the work provide a basis for determining how well the licensee is actually implementing its Quality Assurance Program (Staff Panel I, p. 9).
43.
I&E does not determine the requirements which licensees are to meet.
NRR reviews licensee's plans (Preliminary Safety Analysis Report and Final Safety Analysis Report (SAR)) and determines that these plans meet current require-ments.
I&E then inspects to determine that the licensees are confonning to the conmitments and/or requirements as described in the SAR.
Inspectors do not have authority to impose requirements on licensees.
Stated somewhat differently, if the licensee is not meeting requirements I&E takes enforcement action; if the requirements have not been properly defined, I&E refers the problem to Headquarters for resolution or clarification (Staff Panel I,
- p. 27).
V.
I&E EXPERIENCE WITH THE CONSTRUCTION OF CP&L NUCLEAR FACILITIES 44.
The Staff presented witnesses who inspected the construction of the CP&L nuclear facilities and their supervisors as well as summaries of all 2247 120
. inspections of all CP&L nuclear facilities (Staff Panel II (Murphy, Brownlee, McFarland, Herdt and Bryant), followi~ng Tr; 2539).
Inspection of the Quality Assurance Program has not revealed major examples of repetitive or systematic problems.
Such failures would be indicative that the management control system was not functioning properly and would be cause for escalated actions on the part of I&E. Although ISE has discovered individual failures to perform as identified by the licensee or by the NRC, though indicating a need for corrective actions, they do not indicate failu.es in management.
The Atlanta Regional' Office of I&E has concluded that CP&L manage-ment has been effective in controlling the quality of construction at their facili ties.
The Quality Assurance Program in effect at Harris meets requirements that are significantly more stringent than were in effect during the construction of Brunswick and Robinson and our inspections to date indicate that this program has been satisfactorily supplemented.
Region II of I&E felt that CP&L management is capable of constructing the Shearon Harris facility in full compliance with NRC requirements (Staff Panel II, p. 5).
There being no evidence to the contrary, this Board affirms this conclusion.
45.
Based on a revir.w of the findings by Region II of I&E construction inspections of the licensee's QA/QC programs and the implementation of those programs; the licensee's response to enforcement matters; the licensee's response to reportable construction deficiencies; and 2247 121
_ 24 -
discussions with Region II I&E construction management and inspector personnel, the Staff concludes that the licensee's management capabilities have been adequate to implement the QA/QC programs and management control systems to give reasonable assurance of quality during construction; and there is no basis for the Staff to believe that CP&L will not con-tinue to provide adequate management capability during future construction phase activities at Shearon Harris.
Region II of I&E has reviewed CP&L's current overall construction QA/QC program and procedures, the corporate audits and the engineering and construction QA surveillance reports of activities by CP&L engineering, the nuclear steam system suppliers, the architect engineers and the CP&L contractors for services and hardware.
Routinely the inspectors have observed work related to the above construction activities and records (including nonconformance reports and deficiency and disposition reports), periodic management reports by both CP&L and the constructors.
The Staff concludes that CP&L has maintained an adequate managerial ability during construction phase activities at its nuclear sites (Staff Panel II, pp. 4-6; Tr. 2542).
46.
CP&L constructed three nuclear facilities before Harris-Robinson (Unit 2) and Brunswick (Units 1 and 2).
Construction Permit fio. CPPR-26 was issued to H. B. Robinson-2 on April 13, 1967 and Operating License flo. DPR-23 was issued on July 13, 1970, and during the construction period the NRC 2247 122
,. spent 325 mandays performing thirty-six site, corporate and vendor inspections of construction related activities.
The main deficiencies were:
a.
Corrosion of containment building tendon test bars.
b.
Cracks discovered in the welds of the containment penetration frame after installation.
c.
Non-separation of redundant electrical cables.
Each of these items were corrected by the licensee or its contractors in a timely manner, and none considering the magnitude and complexities of problems and their solutions and the fact that the project was being built as a turnkey project by Westinghouse for CP&L, reflect adversely on CP&L (Staff Panel II, pp. 30-36).
47.
During construction of Robinson the term "non-compliance" was not used.
Items were entered into reports as " construction deficiencies" or "non-conformances" with the PSAR or the codes.
There were 16 items which were identified as non-conformances or construction deficiencies in Robinson inspection reports.
By current standards several of these would not have been cited as non-compliances.
Further, also some of these were listed when there was insufficient evidence to determine compliance or non-compliance.
By current standards they would not have progressed beyond the " unresolved item" category.
Conversely, there may be items within the docket file for Robinson which were not cited, but which would be cited by today's : 2 d et.
!? < ver, all :
I-r iJ mti: imi c
2247 123
. were satisfactorily resolved prior to the issuance of the operating license.
The noncompliances were random in nature and are not indicative of failures in CP&L's management.
The safety significance of these items was individually analyzed by CP&L and, in turn, by the NRC.
In each case it was CP&L that identified the corrective actions.and measures taken to preclude recurrence.
The correctiva actions were confirmed through NRC inspections (Staff Panel II, p. 38).
48.
The construction permits for Brunswick were applied for on July 31, 1968 with the Construction Permit Nos. CPPR-67 and CPPR-68 issued on February 7, 1970.
Commencing on May 29, 1969, there were forty-nine inspections of construction related activities at the site, corporate offices and vendors performed on Unit I and forth-six inspections of construction related activities at the site, corporate offices and vendors performed on Unit 2.
To accomplish this program, 27 I&E inspectors spent approximately 480 mandays at the construction site, contractor offices and vendor manu-facturing facilities (Staff Panel II, p.40 ).
- 49. A major problem during the construction of Brunsiwck was the high turnover of welders.
During the year 1972, the welder turnover rate was 197%.
Welders must be qualified in accordance with ASME specifications.
The licensee dis-covered that a majority of the welders did not maintain the requirements to continue welding in accordance with these specifications.
In addition, welders are a travellino craft and will work where the salary includina 2247 124
, overtime is the greatest, all things being equal.
The licensee's corrective actions were to retain a welding consultant, improve the welding school since some welding involved " newer" materials that the average welder was not familiar with or may have never welded before, and increase the welding quality contmi staff.
Trend analysis was also instituted so that welders having problems with certain material or weld configurations could be identified and more' training initiated (Staff Panel II, p. 40).
50.
Another problem at Brunswick involved voids between the Unit 2 steel torus liner and the concrete placed around the liner.
Voids were subsequently found under the Unit 1 torus liner also.
The void areas were mapped and repaired by pressure grouting with epoxy resin.
Grout holes drilled through the torus liner were later veld repaired and leak tested.
On June 1, 1974, CP&L reported that some epoxy grout under the Unit 1 torus had failed to harden.
This was indicated by mixing pot samples taken during the grouting process.
Tests were performed to detennine the effects of these voids on the structural integrity of the torus.
NRC has conducted numerous inspections of procedures, repair work, QA/QC activities and test operations.
NRC has examined the engineering analysis and CP&L's final report and has no further concerns (Staff Panel II, p. 40).
51.
Other deficiencies at Brunswick, identified in the Staff testimony were discussed in full (Staff Panel II, pp. 12,41-44).
The Staff concludes n ant
'O that thoso o'ficienci+1 th not ino m Board concurs.
47
- _ ~
52.
Using present classification terminology, there were 20 infractions and 6 deficiencies during the construction of Brunswick.
The Staff is satisfied that proper remedial action was taken by CP&L and their randomness is indicative of no systematic weakness in CP&L management.
Using its " lessons learned," CP&L during the latter part of construction at Brunswick 2, increased their on-site participation in on-site construction and QA meetings.
CP&L management also provided increased QA/QC manpower and contracted for special consultants for on-site work as needed (Staff Panel II, pp. 46-47).
53.
Carolina Power and Light Company (CP&L) filed an application for authorization to construct and operate four pressurized water nuclear reactors known as the Shearon Harris Nuclear Power Station, Units No.1 through 4 in North Carolina on September 7, 1971.
The construction permit exemptions which authorized limited work at the site was issued on January 14, 1974.
NRC inspectors began inspection of construction activities on February ll,1972.
On May 7,1975, CPSL informed NRC of the extended construction delay.
On January 27, 1978, Construction Permit No. CPPR-158,159,160 and 161 were issued (Staff Panel II, p. 49).
54.
CP&L has developed and is implementing a new site QA/QC program and pro-cedures for Harris.
The procedures are being written and reviewed by 2247 126
. QA personnel who have Brunswick or other nuclear plant construction experience.
The procedures are written to implement and verify Ebasco specifications and PSAR commitments.
These changes have proven to be effective for that work completed and the work tnat is presently in process.
I&E inspection reports reflect that procedural control for that work completed, and that the work in process at Harris is acceptable.
(Staff Panel II, p. 48).
55.
Region II has verified that at the Harris facility,CP&L is managing site construction and QA/QC surveillance survey functions.
CP&L site QA Unit and Engineering Units performs the acceptance inspection functions at Harris.
CP&L's manager of engineering and construction QA (Raleigh Offices) performs site QA surveillance functions.
CP&L corporate QA audit section performs site audits.
Ebasco provides architect-engineering services.
Daniel Construction Company provides labor and direct labor supervision.
Permanent facilities are constructed in accordance with the A-E's engineering documents (Staff Panel II, p. 10; McDuffie, p. 8-12, 24, 46-47).
- 56. I&E inspection further shows that in order to assure QA/QC compliance at Harris, the manager, Corporate QA Audit Group, who reports to the Vice President of System Planning and Coordinating Department, who in turn reports to the Executive Vice President and Chief Operating Officer, is responsible for auditino of all 0A procram activities within CP&L (Engineering, Con-s trucuan, Qi) ono t arnai tivitie3 of the nrcu i tect-Engineer, Nuclear 2247 127
Steam Systein Supplier and the vendors.
Upper level management reviews these reports and has obtained timely actions where required.
This program meets f1RC requirements (Staff Panel II, pp.10-12, Murphy, Tr. -2543).
57.
CP&L presently has a program to identify safei.y-related problems and it is an integral part of their QA program.
It conducts corporate level au< lits, eagineering and construction QA surveys, site QA unit surveys, trend analysis of nonconformance reports, and QC inspection. Additionally, CP&L routinely performs an engineering review of matters _ described in the f1RC Inspection and Enforcement Bulletins and Circulars, project design changes and construction work. All the CP&L construction engineers, inspectors and site QA examination, inspection and test personnel have authority or access to stop work authority or to reject work or materials, and in fact they have done so.
Region II inspection personnel have reviewed reports, verified actions and witnesses specific cases where work was stopped or rejected and corrective actions taken (Staff Panel II, p. 21).
58.
To check and determine that these problems are dealt with, CP&L has adopted nonconforming report system and audit or survey system which requires identification, corrective action and verification of corrective action.
They employ nonconformance reports (f1CR's) to handle routine and minor problems.
Deficiency and Disposition Reports (DDR's) are used to document major problems or engineering document deviations requiring 2247 128
.. engineering evaluations.
CP&L employees are trained to consider generic implications of related problems.
The system works and provides a mechanism for identifying, documenting and correcting the specific problems and make necessary changes to the QA program procedures to minimize future recurrence (Staff Panel II, p. 22).
59.
In the past CP&L has had scme problems in obtaining and retaining site workers, but this has not adversely affected the construction schedules nor compromised the quality of work.
CP&L has established an active recruitment unit and should be able to continue to employ adequate personnel (Staff Panel II, p. 21).
60.
During the period February 11, 1972 through October, 1978, Region II conducted 24 inspections related to Harris construction activities both at the site and corporate offices.
Included are seven inspections, from July 1,1975 through September 1,1977, related to the extended construction delay, which includes site storage facilities, facilities maintenance, equipment storage and records.
The 24 construction inspections 2247 129
have employed 21 inspectors for approximately 150 mandays at the con-struction site, corporate offices and vendor manufacturing facilities.
Major components including reactor vessels ar.d steam generators for the construction of these units are in storage at the site.
Current activities have consisted of the placement of the containment buildings concrete base mats for Unit 1 and the erection of the containment liner (Staff Panel II,
- p. 49).
61.
Three items of noncompliance have been identified through inspection of the Harris work. One item involves the placement of concrete for the power block structure.
This item related to sampling inspection of concrete during placement when pumps and other conveyances are being used.
A second item of noncompliance involves a site contractor's con-tainment welding program and it related to documentation for electrode control. The third item of noncompliance involves the QA program per-taining to control of documentation.
This item involved control of revised drawings with outstanding field change requests.
(Staff Panel II,
- p. 51).
62.
An analysis of the three items of noncompliance identified during con-struction of this four unit facility indicates that two items were identified as infractions.
That is, if they had remained uncorrected, they could have resulted in the failure of a Seismic Category I system 2247 130
- _ or structure in such a manner that the safety function or integrity would be impaired.
These noncompliances are randon in nature and are not indicative of failures in CP&L's management, nor inadequacies in the QA program. The safety significance of these items was individually analyzed by CP&L and, in turn, by the NRC.
In each case, CP&L has identified the corrective actions and initiated measures to preclude recurrence.
The
~
corrective actions were confirmed through NRC inspections (Staff Panel II,
- p. 52).
63.
Region II's construction inspection and enforcement history with CP&L does not indicate a lack of managerial capability to construct the facil i ties.
The inspections have disclosed no facts indicating present need for CP&L to improve its QA/QC programs in the construction of Shearon Harris. The specifications, QA Manuals and procedures are current with work being done and Region II of I&E inspection reports reflect that CP&L is implementing the overall QA/QC program commitments of the PSAR.
Region II's construction inspection and enforcement history does not indicate a lack of control of the QA/QC programs for construction.
CP&L is implementing the overall QA/QC program commitment of the PSAR.
CP&L has developed, implemented and manned a construction QA/QC program that encompasses corporate, engineering and design and construction activities which are commensurate with the status of project (Staff Panel II, pp. 14-17).
2247 131
~
. 64. As this Board was previously informed, a " minor geo' logic fault" was found during excavations at the site. flRR concluded this fault was not capable within the meaning of Appendix A to Part 100 of 10 CFR.
f1RC Staff in-spection of Applicant's geologic map and discussions with the Applicant's architect-engineers have not shown any adverse condition significant to nuclear safety. A possible foundation anomaly was also discovered in excavation for the spillway of the main dam. Although this is not a Category I safety structure, a safety study is being made by the fiRC Staff geologists and the Applicant has been requested to do further mapping (Staff Panel II, p. 51).
~
65.
It is the I&E's view that CP&L has demonstrated no lack of technical quali-fication or ability to construct Harris.
Moreover, CP&L has supplemented their own in-house capabilities with the capabilities of their consultants, an architect-engineer, a nuclear steam system supplier and a construction supervisor, who have had previous experience on several nuclear plants.
Additionally, CP&L has hired experienced personnel to manage site con-struction and engineering and construction QA activities.
Engineering support, drawings, specifications and QA/QC programs and procedures have been developing for an extended period of time.
CP&L has demonstrated effective capability for meeting quality requirements for work already completed and that work which is in process at Shearon Harris.
For problems outside the scope of expertise of CP&L, Ebasco, and Daniel, CP&L can hire consultants (Staff Panel II, pp.11, 25).
2247 132
66.
The Staff believes that CP&L and its constructor have and will continue to have, sufficient, properly trained management and QA/QC people in the construction of Shearon Harris.
Appropriate NRC enforcement action will be taken to assure this level is maintained.
(Staff Panel II, pp. 21, 54).
- 67. There is reasonable assurance that CP&L can construct and the equipment can be installed in accordance with PSAR comnitments and the regulations, the license and the technical specifications.
The licensee has previously demonstrated his commitment to construction QA at the Robinson and Brunswick Nuclear Stations by expanding his involvement in the construction program.
This includes taking corrective actions on identified deficiencies and by staffing construction engineers and QA/QC inspectors at the construction site. (Staff Panel II, pp. 49-57).
VI.
I&E EXPERIENCE WITH THE OPERATION OF CP&L NUCLEAR FACILITIES 68.
I&E has verified that CP&L QA activities for their operating nuclear plants is governed by three QA organizations, each with independent missions but all charged with providing QA services.
These organizations are the plant QA organization, the Operations QA Section (based in the corporate office and reporting to Department Manager, Generation), and the Corporate QA Audit Section (Staff Panel III (Long & Dance) following Tr. 2937, p. 4).
2247 133
. 69.
The Corporate QA Audit Section performs audits of activities at the corporate office and at the Brunswick and Robinson facilities.
Audit findings and resolutions thereto are reported to the CP&L chief operating officer.
The Operations QA Section performs audits at the Robinson and Brunswick facilities approximately twelve times yearly at each facility.
Audit findings are identified to the Department Manager, Generation and to the plant manager.
Personnel in.this section are assigned to specialty areas of audit responsibility (such as maintenance, health physics, or operations),
and they conduct pre-planned audits in accordance with established CP&L plans and procedures.
The Operational QA section also reviews flRC cor-respondence to further identify problem areas and track NRC-unresolved items (Staff Panel III, pp. 4-5).
70.
The plant QA organizations at Robinson and Brunswick are similar.
They perform both QA and QC functions in accordance with policies established in the Plant Quality Assurance Manual.
The plant QA supervisor reports to the plant manager and has a communications link to the Manager, Operations QA Section.
The Brunswick plant QA staff has a supervisor of six personnel assigned; the Robinson plant QA staff has a supervisor of four personnel assigned.
In addition to the routine QA/QC functions in areas such as maintenance activities, procurement, and design modification; the Plant QA group performs audits at the request of plant supervision or management.
It provides monthly reports of all outstanding items (e.g., NRC, corporate 2247 134
. or plant identified) to the plant manager.
The Plant QA group is audited by both the Operations QA Section and the Corporate QA Audit Section (Staff Panel III, p. 5).
71.
I&E inspections related to plant operations and in the QA/QC areas at Brunswick and Robinson date from September 1974.
The initial inspection revealed 20 discrepancies at the first Brunswick unit to be licensed (1974) and the initial inspection of operations QA on the second Brunswick unit to be licensed revealed only 2 discrepancies.
The initial inspection of Robinson QA for operations (1975) revealed 13 discrepancies.
Recent inspections of on-going QA activities revealed one discrepancy at Robinson and 11 items of noncompliance at Brunswick (Staff Panel III, pp. 8,11; Staff Exh.15; Dance, Tr. 2931 ).
72.
CP&L management ability in nuclear QA activities has steadily improved over the years.
CP&L was slow, as were most licensees, in implementing the QA program for operations at their first facility.
We are aware of the early determination by CP&L to get involved in QA.
They were very active in ArtSI work groups who developed the principal QA standards for QA program duditing and qualifications of QA personnel.
They have been tough in dealing with the issues that tend to create an expansion of manpower requirements, such as quality assurance.
tievertheless, significant increases in staffing of vital positions and realignment of key management personnel r: : 4
'^ ""
' " ' ' " ~'
i+ '
- "'is partialh i:
cv me -
opinion (Staff Panel III, p. 9).
2247 135
. 73. Operating License No. DPR-23 was issued for Robinson on July 31, 1970.
Overall some 150 inspections pertaining to operations of Robinson have been conducted. This includes 30 inspections and one corporate meeting since September 1,1977 when the testimony for the 1977 Harris Construction Permit Hearing was written.
The initial management inspection of administrative controls affecting quality and operations at Robinson was made in 1971. The'first in-depth inspection of the CP&L QA program supporting plant operations was in July 1975.
This was subsequent to the issuance of the CP&L QA program
,ical report (The CP&L Corporate Quality Assurance Program - Part 2 and Si dated December 19, 1974.
This inspection revealed 13 discrepancies, rcost of which were linked to program weaknesses.
CP&L was responsive to these findings and most were resolved within three months.
In December 1972 and again in December 1974 meetings with CP!L management were held pertaining to improving the management of Robinson.
The AEC was critical of the slowness in developing a QA program and repetition of similar items of noncompliance.
Subsequently, management performance continually strengthened.
(Staff Panel III (Long & Dance) following Tr. 2937, pp. 12-13, App. B.2, C.2).
74.
QA activities at Robinson are inspected several times a year.
On-going inspections have revealed that most discrepancies are centered in the areas of maintenance, training, design changes and modifications, and document /
2247 136
~.
~
records control.
In the three years that QA activities have been followed, no evidence of overall programmatic weakness has been pinpointed for Robinson.
The management staff at Robinson is experienced, and responsive to NRC concerns as evidenced by the December 1977 boron injection tank thermo-couple failure investigation and the current upgrading of facility procedures and administrative controls (Staff Panel III, pp.12-13).
75.
Operating License No. DPR-62 was issued for Brunswick 2 on December 27, 1974 and Operating License No. DPR-71 was issued for Brunswick 1 on September 8, 1976.
Overall about 110 inspections pertaining to operation, including preoperational testing, of Unit 2 and about 80 inspections' pertaining to operations of Unit I have been conducted.
This includes 31 joint inspections and one corporate neeting since September 1, 1977 when the testimony for the 1977 Harris Construction Permit Hearing was written.
Since September 1976 all but two inspections have pertained to activities of both units.
(Staff Panel III, p. 13).
76.
I&E conducted the first comprehensive inspection of the CP&L QA program necessary to support operation several months prior to the operating license issue for Unit 2 (the first of the Brunswick units to be licensed).
This inspection was in September 1974.
This inspection identified 20 unresolved items with at least one item in each area inspected. The pro-gram was found to be " fragmented" and failing to fully meet FSAR commit-
,,,nn vtors "rii<f ne't see a
o.,.
o.,
yj-
, x.
2247 137
_ 40 -
those management controls that are necessary to assure... that the plant will be operated safely and in compliance with license requirements."
A reinspection was held in December 1974, which confirmed numerous program-matic changes to the Brunswick program and resolved most of the initial NRC findings in QA. The program was found to be acceptable by the time the Unit 2 license was issued. A similar in-depth inspection of QA in June 1976, prior to licensing of Brunswick Unit 1, identified one item of noncompliance and five discrepancies.
As stated, a thorough inspection of the Brunswick QA program in January 1979, identified eleven items of noncompliance (Staff Panel III, p.14; Dance, Tr. 2932).
- 77. Brunswick management in the years from late 1974 to early 1977 had numerous operating problems and issues. The significant upgrading of the QA program in late 1974, the starting up of two units in 1974 and 1976, the many repetitive reportable occurrences and noncompliances, and the loss of four senior plant management personnel due to resignations are examples.
As we later detail, in February 1976 following an off-gas explosion, NRC management met with CP&L management to discuss our concerns of their operation including the time-liness, the quality, and history of reportable occurrence reports and to reemphasize requirements to follow emergency instructions.
Shortly thereafter management moves were made at the corporate and plant levels.
In the fall of 1976, recognizing the need for additional training of supervisors, a short training course on BWR operations was conducted on-
- site, in January 1977 Region II confirmed management qualification met 2247 138
~_ ~
AflSI fil8.7 and technical specification requirements although it met with CP&L in March 1977 to discuss maintenance controls and turnover of supervisory personnel.
Continued upgrading of personnel training, qualifications, and responsiveness to flRC concerns has been demonstrated.
Today the Staff considers the management staff at Brunswick to be qualified and continually being strengthened by the inhouse SR0 training.
Supervisory staff turnover has been minimal since January 1977.
One superintendent was transferred to Robinson as Plant Manager in flovember,1977.
In sum, although no significant QA progr'am weaknesses have been identified by the Staff in the on-going inspection of QA at Brunswick, the QA inspection of January 1979 did identify 27 programmatic matters requiring correction. Additionally, implementation of maintenance administrative controls has been an area of weakness, as evidenced by continued I&E findings of noncompliance in this area (Staff Panel III, pp.14-15, Attachments B.1, C.1; Dance, Tr. 2933-2934).
78.
I&E also looks at how CP&L handled problems involving radiation protection, security and inservice inspections and also examines CP&L's Licensee Event Reports, and their noncompliance record.
From January 1975 through October 6, 1978, 14 insoections by the I&E Radiation Support Section were made at Robinson, resulting in 21 noncompliance items being cited.
Other program weaknesses in this area have been identified and classified as open or unresolved items.
The problen areas found that were considered significant becanco nf rn"ntition or notential imnact enen:
rarliation exnnsure control.
internal expo o.e cena vi. :.a c.a iua tion, e ; lucnt moni tor testing, heal th 2247 139
'L
' _ ' physics controls and continuing problems involving the posting, labeling and control of high radiation areas.
Additional problems in this area have been identified from the licensee's license event reports (Staff Panel III, pp.16-19).
79.
From mid-1975 through October 6, 1978, 13 radiation support inspections were made at Brunswick resulting in 14 items of noncompliance. Additional problems have been identified as the result of LER's from the licensee and unresolved items or open items identified by the inspectors.
In addition to these problems, a major problem area is presently being negotiated between CP&L and flRR regarding the operability of the Off-Gas System.
Major areas identified which could adversely influence the radiation protection program are:
A.
Posting Labeling and Control _
Failure to post and contiol high radiation areas per the Technical Specifications were twice cited in 1976. The failure to control high radiation areas was cited again in 1978. The licensee's response to this item was received in flovember 1978.
The action proposed by CP&L to control the high radiation areas appears reasonable.
- However, the fact that additional examples were identified approximately two months after the latest citation seems to indicate that adequate corrective actions were not immediately taken.
B.
Testing of Effluent Monitors In 1975 three citations were made concerning the failure to perform tests of effluent monitors as required by the Environmental Technical Sepctifications.
In 1978 it also was noted that the corporate quality
~lwnt
. 1
- ots 01
- n.
monitors had not been performed as required.
Actions taken will be O
reviewed during continuing ISE inspections.
~-
C.
Off-Gas Systems The Off-Gas system is presently not operable due to hydrogen ignition problems.
Discussions and corraspondence have been taking place between CP&L and flRR cencerning corrective actions and the time frame for such actions.
CP&L has projected that apprcximately 8 years will be required to make the system operable.
flRR is presently considering Technical Specification revisions until such time as the system is operable. This is on-going.
In the interim, the inoperability of the system could have an adverse effect on radioactive gaseous re-leases depending on fuel integrity. See Proposed Finding 123.
D.
Control of Abnormal Situations A traveling incore probe was retracted through the shield, resulting in an unidentified and uncontrolled high radiation area.
This single event resulted in four citations in 1976 involving failure to follow procedures, failure to perform surveys and failure to maintain survey records.
Subsequently, a deviation was cited because the licensee did not take all corrective actions as stated in his reply. Additionally, a management meeting was held with CP&L on this matter.
This was a significant problem area at that time (Staff Panel III, pp.19-20).
80.
Based on the operating history of the Brunswick facility the principal concern of the Staff with CP&L's ability to construct and operate the
" u i ' t i n wn'oction and radin,ctive Har i c ^i' ' > " -
2247 141 waste management is the ability to maintain an adequate staff in the Environmental and Radiation Control group (E&RC).
Under the organization at Brunswick and H. B. Robinson, the E&RC group is responsible for radiation protection (dosimetry, contamination and exposure control, respiratory protection program, survey instrument calibration, etc.),
chemistry, radiochemistry, radioactive effluent control and records and radiological and nonradiological environmental monitoring (sample collection, some sample analysis, etc.).
The work of the E&RC group is carried out by Radiation Control and Test technicians (RC&T technicians).
(Staff Panel III, p. 21).
81.
Since the startup of the Brunswick facility, there has been an attrition of both RC&T technicians and foremen.
While some of these people have gone to other offices in CP&L, others have left the utility.
Foremen generally have been promoted from the technician level.
Replacements for the technician positions have been hired but generally as trainees whereas losses of technicians are occurring at the journeyman level.
The net effect has been to lower the overall capability of the technicians, both in training and experience (Staff Panel III, pp. 21-22).
82.
The E&RC group formerly had two professionals on the staff (one health physicist, one chemist). The two individuals who filled these positions have left; one was reassigned to the corporate office, the other left 2247 142
- the company.
The only professional presently in the E&RC group (other than the E&RC supervisor) is a recent college graduate employed at the Junior Engineer level.
Again, this has resulted in a decrease in the level of training and experience at the plant level (Staff Panel Ill, pp. 22).
83.
In considering the capability of CP&L to operate the Harris facility it is necessary to consider the ability adequately to staff Harris without further reducing the ability to perform the responsibilities at Brunswick and H. B. Robinson.
The E&RC group responsibilities at Harris will begin with the preoperational test program with chemistry control and system flushing and testing and will continue on through preoperational testing and startup with increasing responsibilities for chemistry, radiochemistry, health physics and environmental monitoring.
As the responsibilities grow with one unit, they will begin on subs _quent units.
This will impose an increasing workload with expanding responsibilities.
The E&RC group will need to be staffed to cover this workload over a period of years; the use of overtime to provide coverage will solve short-term problems but cannot be looked upon as an alternative for adequate staffing, both in terms of number of people and experience, for a situation which will cover a period of years.
At the present time both Brunswick and Robinson are adequately staffed in the area of radiation protection (Staff Panel III, p.16 & 22).
2247 143
. 84.
A potential weakness in managementh implementation of the requirements in the radiation control area has been identified due to the fact that there have been eleven noncompliances in the radiation control area during the past twelve months.
fiRC inspection efforts have been modified to focus attention on the radiological controls areas in order to identify and correct specific weaknesses (Staff Panel III, p. 29).
However, based on the results of radiation protection inspections at both the H. 8. Robinson and Brunswick Steam Electric Plants, the Staff remains of the view that Carolina Power and Light Company is capable of operating an additional nuclear generating station in accordance with the regulations and without creating a hazard to the public health and safety. This matter will be reviewed again at tne operating license stage where flRR headquarters personnel will review the Staff's requirements prior to issuance of any operating licenses (Staff Panel III, p. 23).
85.
From April 1976 through June 1978, four security inspections have been conducted at Robinson.
These inspections resulted in three items of noncompliance (two infractions and one deficiency). There were no repeat items of noncompliance. The most recent inspections have indicated significant improvements.
Based on the inspections and in the opinion of security inspectors, Robinson is considered an average plant when m asured against all other Region II facilities and the ISE Inspection Program (Staff Panel III, p. 23).
2247 144 86.
From March 1976 through September 1978, seven security inspections have been conducted at Brusnwick.
These inspections resulted in sixteen items of noncompliance (eleven infractions and five deficiencies). Two of the items, both infractions, were repeat items of noncompliance.
Based on the I&E's inspections and in the opinions of inspectors who have been involved in recent security inspections, Brunswick can be said to be average when measured against other Region II facilities and the overall I&E Inspection Program.
The differences between the numbers of non-compliance items identified at Brunswick and the number identified at Robinson are largely due to the greater complexity of the Brunswick security system (Staff Panel III, pp. 23-24).
- 87. A civil penalty was assessed for four items of plant security noncompliance at Brunswick for failure to implement access control requirements.
During three separate inspections Brunswick received noncompliances in security areas per-taining to access control and a meeting between CP&L and NRC was held on this matter prior to the inspection that resulted in the civil penalty. The recur-ring items of noncompliance involving the security program reflected upon management's apparent inability or reluctance to take corrective action.
In general the civil penalty appeared to be more related to the management program than the QA/QC program.
CPSL's security record has improved since 1975, perhaps the penalty having served a useful purpose (Staff Panel III,
- p. 25).
2247 145
48 -
88.
Inservice inspection nondestructive testing of the Robinson facility vessel, piping and piping components has been contracted to Westinghouse.
The inspection activities are coordinated by Carolina Power and Light (CP&L) inservice inspection coordinators at the corporate office and site level.
CP&L has shown a great deal of concern for proper implementation of the inservice inspection requirements at Brunswick and Robinson and CP&L management has been responsive to inspection findings by both CP&L and NRC audits and inspections'(Staff Panel III, pp. 26-28).
89.
CP&L's noncompliance history for Robinson has been:
1975 1976 1977 1978 Violations 0
0 0
0 Infractions 23 6
9 10 Deficiencies 9
6 9
5 Deviations 6
1 1
1 (Staff Panel III, p. 28, Dance, Tr. 3026).
At Brunswick it has been:
1975 1976 1977 1978 (through September)
Violations 0
0 0
0 Infractions 31 20 17 13 Deficiencies 4
13 5
7 Deviations 2
2 3
1 (Staff Panel III, p. 30)
Generally, although the exact definitions are complex, a violation is an item of immediate safety consequence, an infraction is one with a potential for il
t s'l-
't-'
.. : 114 ]
<t i
'i im whose safety consequence is remote (Murphy, Tr. 2215; see also Staff Panel I, pp. 11-16).
. 90. As previously indicated, on January 8-12,15 and 16,1979, shortly before this hearing an inspection was made looking into the quality assurance program at the Brunswick facilities.
This was part of a new series of in-depth inspections of a quality assurance program that is being conducted of licensees by the flRC Staff.
No prior audit of quality assurance to this depth has been conducted at Brunswick (Ruhlman & Kellogg, Tr. 2714-2715).
As a result of this inspection--7 infractions and 4 deficiencies were reported (Staff Exhibit 15).
These mainly dealt with the failure to set up or carry out programs or procedures that wou.1 assure quality control.
None of the matters discovered were considered hazardous to health or safety, although the inspection revealed that the Brur.swick plant's QA program requires significant upgrading (Ruhlm,
- c. 2714, 2717-2718).
Considering the depth of the inspection--Brunswick appeared, in regard to its quality assurance program in the areas inspected, an average utility (Ruhlman,Tr. 2638,27d0-2706).
91.
Noncompliances at Robinson have decreased from a high in 1975, and have been relatively stable in the past three years.
A detailed review of the licensee event reports and noncompliance from September 1977 through August 1978 indicate that H. B. Robinson management has implemented changes in facility operation and administrative controls which provide improved compliance with NRC regulations.
Specifically, corrective actions taken for licensee event reports and noncompliances have been directed to permanent corrective measures 2247 147
. necessary to prevent recurrences.
These corrective measures include:
comprehensive revision to plant operating procedures and administrative controls, indoctrination and training of personnel in identified problem areas, and investigations of occurrences for generic potential.
Improved procedural controls and personnel performance is reflected by the fact that licensee event reports caused by personnel or procedural error have decreased from ten in 1977 to four in 1978 (Staff Panel III, p. 29).
92.
Significant reportable occurrences during the past year besides the 11 in the radiation control area, include a failure of boron injection tank thermowell and a plant battery fire.
Robinson management's inmediate and long-term corrective actions were responsive.
Investigation and evaluation of the boron injection tank event resulted in replacement of the boron injection tank.
The evaluation of the battery fire included a request for vendor assessment of the occurrence to determine potential generic significance (Staff Panel III, p. 29-30). See Proposed Finding 114.
- 93. A significant improvement in noncompliance of all levels at Brunswick can be seen from the 1975-1976 period.
During the period from October 1, 1977 through September 30, 1978 there have been 27 items of noncompliance--
18 infractions and 9 deficiencies.
The general areas of noncompliance are:
Areas of Noncompliance Infractions Deficiencies Security 5
3 Radiation Protection 4
0
- Envir, Administrative and Procedural 9
3 2247 148 In addition there were the noncompliances found in January 1979 in the quality assurance area (see Proposed Finding 90).
Brunswic}; management has been responsive in addressing and initiating corrective actions for identified enforcement items, and noncompliances have generally been decreasing (Staff Panel Ill, p. 31).
94.
At Brunswick safety-related problems are identified and followed by a limiting condition for operation (LCO) sheet and trouble ticket.
There is a program in addition to a corrective maintenance trouble ticket, whereby they are identified and tracked to completion and reviewed by maintaining an LC0 status described in plant procedures.
The problem is then reported to and reviewed by the appropriate senior staff and/or the Plant Nuclear Safety Committee.
Problems related to safety that keep the plant from operating are given inmediate attention.
Some problems which have a lesser safety significance are handled less expeditiously.
An example of this latter type is the accur,ulation of water in safety-related areas which has been a chronic problem and still exists (Staff Panel III, pp. 25-53). Action to correct problems is tracked in a number of different ways but must generally appear on an outstanding items list with periodic reviews of due dates.
Repetition of certain items may indicate that the solution was ineffective.
The Staff feels the system works.
Infrequently, ISE inspectors have found items not properly tracked or remedial actions not promptly taken such as the HPCI delta temperature isolation circuit modification was a case where action was not taken promptly (Staff Panel III, p. 36).
2247 149
. 95.
CP&L has a program to identify incipient problems in operations, including start-up operations, before they develop.
The program requires CP&L to perform periodic tests, QA audits, preventative maintenance and inservice inspections on a routine schedule at operating plants.
They also review circulars and bulletins issued by the NRC and evaluate those applicable to their facilities.
Corrective action is taken where problems are identified.
This, of course, does not apply to Harris as it does not now have an operating license (Staff Panel III, p. 42).
At operating plants, problems are identified and followed by maintenance trouble tickets.
Once identified and reported, the licensee's supervisors and/or higher plant management has the responsibility for evaluating the matter.
Problems of a major nature are referred to the site engineering staff for evaluation.
Corporate engineering assistance can also be requested.
Consultants can also be called in.
CP&L does have the means to evaluate identified problems.
Qualifications of plant staff and nondestructive testing personnel are routinely checked to assure that they are qualified.
Matters which are safety-related are reviewed by the Plant Nuclear Safety Committee (PNSC).
They have the authority to make the necessary decisions.
The program appears to work.
I&E routinely confirms that the PNSC reviews safety-related matters.
Examples are reportable occurrences, plant modifications, and noncompliances.
CP&L QA reviews all periodic tests and maintenance requests to see that the work has been completed and that there are no indicated problems at Brunswick.
At Robinson QA audits the periodic tests and reviews the rain n'u're roa'indt.
Thic romm sco'n to be workinq.
(Staff Panel III, e
pp.,a-,,).
2247 150
. 96.
Robinson has been in operation since 1970 and has been relatively stable in its turnover of upper and middle management.
Brunswick had units starting up in 1975 and 1976, and had a high turnover.
In the past year managerial employment at both facilities has been relatively stable (Staff Panel III, p. 47).
97.
If one compared the management organization of Brunswick from 1975 to the present, overall management control is better.
It is better because of the additional experience gained in operating the plant, the emphasis placed upon additional training, and the refinements made in administrative procedures.
The Staff notes that the changes in job positions since January 1976 were required by the resignation of four staff members and the reassignment within CP&L of others.
In May 1975 and, as we stated, in February 1976, the management of NRC Region II met with CP&L management and were critical of CP&L's past operational performance at Brunswick (Staff Panel III, p. 48 and App. B.1, C.1).
As indicated, shortly af ter the 1976 meeting several management moves were made at the plant and corporate level, and a short supervisory course for BUR operation was started at Brunswick.
By March of 1977, two of the nine plant staff in training for SRO's were plant supervisors.
This training has continued to the present.
The above coupled with a more refined and developed QA/QC program has resulted in an improved management.
The Staff is of the view that I&E's actions directly precipitated improvements in CP&L's management of its nucl "
f" ili'
( ~ ' f f D'
0
"3 2247 15i
- 98.
Since January 1977 the turnover rate at both plants'has been stable. At Brunswick one superintendent was transferred (11/77) to Robinson as Plant Manager and a second maintenance supervisor was added when the maintenance responsibilities were split.
The vacancies created were filled from within the Brunswick organization.
The outgoing Robinson plant manager was transferred to other corporate responsibilities.
Any loss of experience during a program expansion is always felt'.
In the long term, however, management moves accompanied by the recognition of increased training requirements have re'sulted in a more informed staff (Staff Panel III, p.49).
99.
In the 1976-1977 period the people in the middle and upper manageme~nt positions at the CP&L operating plants met the requirements for the positions they held which are defined in American National Standard Institute Code N18.1 and the facility Technical Specifications, and they are currently so qualified.
Currently there are 14 SR0's and 12 R0's at Robinson and 27 SR0's and 13 R0's at Brunswick.
This is indicative that CP&L is aware of their expanding licensed requirements of multi-plant operation.
CPSL has in operation a PWR simulator at the Harris facility and Robinson personnel are actively taking training.
(Staff Panel III, pp. 50-52).
The Staff considers Jrunswick and Robinson to be adequately staffed now and has no knowledge of regular extended work weeks for personnel there.
Extended work weeks can be expected at Harris when 2247 152
. it goes operational but only to a limited degree. Based on the Brunswick experience CP&L managemen+, is more fully aware of the requirements of a start-up progrcm and should factor in overtime versus experience of personnel (Staff Panel III, p. 54).
100.
CP&L applies sufficient resources to deal with the health and safety concerns.
In marginal nonsafety cases, CP&L has sometimes been slow in applying resources.
However, there has been continued improvement in plant management training, reduced repetitious occurrences, and trends in LER's and noncompliances (Staff Panel III, p. 68).
101.
An operational program is not now necessary to deal with problems expected to arise at Sharon Harris.
Some two to three years prier to expected fuel loading is the normal time for a heavy involvement of operational personnel.
Training of operating personnel should be well underway prior to the initiation of preoperational testing which is some one to two years prior to fuel load. The Staff has no present questions of the adequacy of the size of CP&L's QA/QC staff.
It is consistent with their units in operation, and NRC requirements, and the personnel are adequately trained (Staff Panei III, p. 36).
2247 153
. 102.
In preparation for these hearings, surveys were taken of all I&E inspectors in all Branches in Region II to see if any had:
- any evidence on the capability of CP&L management to construct or operate Shearon Harris
- any matters which would assist the Licensing Board in considering these matters
- an opinion concerning CP&L's capability to construct and operate Shearon Harris.
(Staff Panel III, App. A; Staff Exh. 17).
Generally the inspectors replied that they had no evidence, no opinion or a positive opinion on CP&L's capability to construct and operate Shearon Harris.
However, some inspectors in the operating area, in contrast with those who inspect construction, indicated that CP&L had grudgingly met Commission QA and oth :r requirements before December 1976, but had improved since then (Staff Panel III, pp. 38-40, App. A).
CP&L was not satisfied with its quality control at Brunswick in this period either.
( Utley, Tr. 3530-3531, 3599).
The Regional office supervisior personnel nas considered the positions of these inspectors in its testimony and concluded that CP&L's reliability is acceptable and is improving.
The I&E supervisory 2247 154
. opinion is based on CP&L's continually improving management stability and involvement, the QA/QC program, the trend in decreasing enforcement items, and periodic involvement with management (Staff Panel III, p. 41).
103. The Staff feels, based upon personal inspections and NRC records that CP&L has demonstrated their ability to manage and operate nuclear plants.
Overall trends indicate continued improvement.
CP&L is presently properly using its resources in seeing that its nuclear facilities are operated safely.
The Regional Office has no cause to presently believe that CP&L will not operate Shearon Harris consistent with the public health and safety once it is (.onstructed.
In sum the Staff concludes that CP&L's management of the Robinson and Brunswick facilities has evolved for the better over the years (Staff Panel III, pp. 69-70).
VII.
VIEWS OF IrlDIVIDUAL I&E IflSPECTORS 104.
Floyd S. Cantrell was the principal I&E operations inspector at the Brunswick plant for 3 years from August, 1974 to July, 1977 (Cantrell, Tr. 3347, at p. 1).
Mr. Cantrell's view on the operating experience at Brunswick were solicited in September 1977 in preparing I&E's testimony for the 2247 155
58 -
1977 hearing in this proceeding and were incorporated in a hand-written memorandum of September 16, 1977 to his supervisor Hugh Dance.
(See Cantrell following Tr. 3347, Attachments 1 and 2), As we have indicated, it was fir. Cantrell's view that his views were not fully presented to the Licensing Board, which precipitated this hearing.
Generally, Mr. Cantrell felt that the facts set out in the testimony given to the Board, properly. reflected the facts set out in his memorandum to Mr. Dance (Cantrell, p. 6).
However, he did not agree with the opinions and conclusions in that testimony.
He felt the testimony indicated that CP&L willingly adopted a QA/QC program and management control required to assure quality, whereas he felt they did not.
He felt that the Quality Assurance / Quality Control (QA/QC) program was required as a condition cl the licensing of Brunswick Unit flo. 2 in 1974, and that Region III of I&E had required improvements in management control in 1975,1976, and 1977 because of the number of noncompliances and reportable occurrences, and problems in taking effective action.
He further felt at the time of writing the memorandum that the construction permits for Harris should be pre-conditioned to require a recruitment and training program that would avoid staffing shortages and training inadequacies that he perceived occurred at Brunswick (Cantrell, following Tr. 3347, pp. 7 and 10).
In his memorandum of September 19, 1977, he stated:
The following information is submitted in response to your request to provide information on the operating experience at Brunswick.
CP&L possibly can obtain the technical
.,,,,.,,,> %,. a r,., o,n...,,,,,,, -., +,, n n N rn e a i i.aprovnig L a cunaition oi.
,a Brunswick they apparently underestinated the problems and the need for people.
As a result 2247 156
personnel were assigned extended work weeks that continued from weeks to months, and in some cases to years.
This apparently contribute to the turn-over of some of the personnel.
This shortage of manpower undoubtly contributed to some of the problems that were identified.
CP&L management still does not appear to have com-mitted the required manpower and financial resources to assure tha t plant problems are identified promptly, the problems are analyzed by a person (s) knowledge-able in that area, that corrective action is initiated, and that the corrective action is fol-lowed up to assure the action is timely and appropriate.
The followir.g are some examples of the bases for the above conclusions.
(Cantrell, Attachments 1 & 2, pp. 1-2).
He then detailed in the memorandum problems he perceived in (1) per-sonnel training and experience; (2) the number of reportable occurrences (Licensee Event Reports) (LER's); (3) the enforcement history; and (4) technical problems (Cantrell Attachments 1 and 2, pp. 4-10).
The technical problems he emphasized were RCIC (reactor core isolation cooling) system trips; contamination of lubricating oil in the diesel generators; repeated isolation of the HPCI (High Pressure Coolant Injection) system; and failing to keep HPCI room bulkhead doors closed to prevent common flooding.
Other problems were also mentioned, and in concluding Mr. Cantrell stated:
From the number of citations for failure to have and/or follow procedure (20) the plant does not appear committed to the procedures required by their technical specifications.
This could be the result of management attitude, or ineffective QA program..
. [Cantrell, Attachments 1 and 2, p.10].
2247 157
- ~
105.
During the period Mr. Cantrell was principal inspector at Brunswick, August,1974 to July,1977, CP&L did not have sufficient staff at Brunswick, and the turnover of senior and middle management personnel at Brunswick was too high (Utley & Banks following Tr. 3502, pp. 50-53, Utley, Tr. 3584-3586,3587-3583).
It was caused in part at least by these officials having to work long weeks of 55 to 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br />, and even 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />, for extended periods from at least August,1974 until late 1976.
(Utley
& Banks, p. 52, Utley, Tr. 3624).
During that period 6 of the 8 top or middle management positions at Brunswick had three incumbents.
(Cantrell following Tr. 3347, p.11, Bd. Exh.11, p.114).
CP&L has conceded that its manpower needs for this period far exceeded its estimates and that it did not have sufficient staff (Utley and Banks, pp. 50-51,53).
The large turnover of supervisory personnel caused an undesirable discontinuity of experience at the plant; and although qualified replacements were hired for those who left or were transferred it was not always possible to hire employees as qualified as those who left or who had the desired boiling water reactor experience (Utley & Banks, p. 51-55, Cantrell, Tr. 3476-3478; Utley, Tr. 3625).
106.
Concurrently, in the 1974-1975 period during the start-up of Brunswick No. 2 reactor, CP&L was engaged in an " earnings improvement program" (Jones,Tr. 3565-3566,3590).
It cut salaries and ceased hiring, at the same time it was calling on its supervisory employees to put in 2247 158
. very Icng hours and incur personal hardships so Brunswick flo. 2 unit could receive an operating license by December 27, 1974 (Jones, Tr. 3572, 3578; Utley, Tr. 3623-24).
It wished to receive the license by that date because after that time it would have to reet new ECCS requirements that would thereafter be in effect (Jones, Tr. 3581-3582; Utley, Tr. 3600).
The General Electric analysis of the ECCS system on which CP&L ho9ed to rely to meet the new f!RC requirements to be in effect after December 27, 1974, was not approved and the operation of Brunswick Unit ilo. 2 would have been sub-stantially delayed pending proof of compliance with the new standards, if Brunswick could not become licensed under the old standards (Utley, Tr. 3578-3579, 3668-3669; Utley & Banks, pp. 49-43).
Thus, CP&L viewed it as essential to have its Brunswick Unit flo. 2 licensed by December 27, 1974, in order to minimize its cests (Jones, Tr. 3581).
As a result the Brunswick plant staff developed a very narrow focus on "the criticel path" for plant licensing and start-up, and all work not viewed as directly necessary for those goals was deferred (Utley & Banks, p. 52; Cantrell, p. 8).
107.
CP&L was not satisfied and knew that it had to improve its quality assurance program in this period (Utley, Tr. 3530-3531).
However, CP&L was proud of the job it did in this period to get the plant licensed by December 28, 1974 (Utley Tr. 3590-3591; Jones, Tr. 3597).
2247 159
- 108.
The turnover described also decreased the number of these CP&L official working at Brunswick who had reactor operators (RO) or senior reactor operators (SRO) licenses, or who had the equivalent experience or training necessary to obtain those licenses.
fleither the Brunswick's flRC license nor NISI (American fluclear Standards Institute) 18.1 - 1971, referenced in the applicable flRC Regulatory Guide 1.8, requires such a license or equivalent training of plant officials other than the plant manager or the operations supervisor (Staff Panel III, pp. 50-51).
The Brunswick plant's operating license indicated that these qualifications were also " desirable" for eight other supervisory officials at the plant (Staff Panel III, p. 51).
While this may not be an appropriate license condition because it is unenforceable, it is desirable, but not mandatory, that these officials have these qualifications (Jones, Tr. 3631-32; Cantrell, pp. 12-13; Wilber, Tr. 2839, 2856-2857; Allenspack, Tr. 3306-3308; Minor, Tr. 3317-3318).
Such training does make the officials more versatile, increases organizations flexibility, and gives them greater knowledge of the operations of the facility. (Jones, Tr. 3631-3632, Cantrell, pp.12-13; Panel III, p. 49-53).
Further, the top officials at Brunswick served on the Plant fluclear Safety Committee (PflSI) which among other things reviewed plant procedures, tests, changes to systems and equipment, and reviewed operations to detect potential safety hazards.
If a majority of these officials had had the license or the training or experience for a license for boiling water reactor plants, they might have been more alert to and conscious of safety and ninlity c^ntrnl mmhl-~ (h n'rn11 l '.1 -
r m*rall.
T-m-
3362, 3Ju), A01<, Stati runei 111, pp. a-ow.
2247 160
- ~
109.
CP&L while admitting it was understaffed and had large upper and middle management turnover, set forth the increase in f1RC regulations as its primary excuse for problems encountered in the 1974-1975 period during the start-up of Brunswick Unit flo. 2.
It stated that it could not foresee increased fiRC regulations and requirements (Utley-Banks, pp. 33-53).
- However, much of the requirements, particularly as to the quality assurance program, had been promulgated or announced years tiefore (Utley, Tr. 3638-3641, 3600, l'tley & Banks, pp. 42-43).
110.
The off-gas generating system problems were cited in the record as indicative of management control at Brunswick. After an explosion of hydrogen in the off-gas system at Brunswick on January 19, 1976, Howard Wilber, the principal inspector for verification of the preoperational tests at Brunswick, investigated the incident and its causes.
He found several examples of failure to perform proper design reviews and improper internal CP&L inspections.
These were cited in an inspection report sent to CP&L on February 18, 1976.
(Sta ff Exh.18, Att.1, p.1-6; Wilber, Tr. 2833).
As a result of these explosions in January and other problems with CP&L's performance, a meeting, previously mentioned, was held in February 1976 with CP&L officials to press them to take corrective action (Cantrell, Tr. 3464-3465; Sta ff Panel III, Att. B.1, C.1; Bd. Exh.11, p. 99).
CP&L on March 17, 1976, replied that although the defects found by the inspector on investigation of the off-gas explosion indeed existed, there was no 2247 161
- failure in CP&L's quality control procedures as those procedures did not call for checking the particular facet of the impro'per equipment that led to the explosion and because the failure to conform to specifications were caused by its employees' acts after quality control inspections were made (Wilber, Tr. 2383, Staff Exh.18, Att. 2; Utley, Tr. 2655-3663).
fleither of these excuses show that quality control was present.
111.
On June 21, 1976, Floyd Dance, the principal I&E inspector at Brunswick, wrote a memorandum to Frank Long, his supervisor, calling attention to the high turnover in management at Brunswick, the general lack of experience of those people and their lack of BUR experience (Cantrell, Att. 3, see Utley, 3616-7).
lie recommended that the matter be called to the attention of CP&L and it be determined what plans they had to stabilize their work force (Cantrell, Attachment 3).
In September 1976 ISE Principal Inspector, ifoward Wilber, responsible for verification of the preoperational test program at CP&L, found that CP&L's QA personnel had only observed 2 or 3 of the numerous preoperational tests.
(Wilber,Tr. 2839-2838, 2855-56; Bd. Exh. 11, p. 25; Staff Exh. 18, Att. 4, p. I-2).
Although such observation was not specifically required, it was good practice.
(Wilber,Tr. 2359-2869).
Again later in " test condition III" when Brunswick was starting up, Mr. Wilber's inspection reveal'd that the CP&L site QA period had not observed this phase of the start-up, although that would be expected.
(Bd. Exh.11, p. 25; Wilber, Tr. 2838).
2247 162
. 112.
In January, 1977, I&E Inspectors, Floyd Cantrell and Howard Wilber, met with their supervisor Hugh Dance and expressed concerns about the high turnover of personnel at Brunswick and lack of any in-depth BWR experience (Bd. Exh. 11, p. 26; Wilber, Tr. 2839,2857).
This was also expressed in a memorandum of Cantrell to Dance of January 4,1977, where he urged these matters be discussed with CP&L (Cantrell, Att. 5, Tr. 3469).
The Test and Start-up Superintendent had left CP&L, and the new plant manager did not have experience with boiling water reactors (Bd. Exh. 11, p. 26).
As a result of inspector's request, I&E Inspector, Richard Wessman was assigned to evaluate Brunswick Plant supervisory activities (Bd. Exh.11, pp. 26, 113).
He did this from January 17-21, 1977, and provided in a memorandum to Hugh Dance an appraisal of the plant's senior staff's quali-fications and involvement in plant activities.
He surveyed activities during the beginning two weeks of January.
He found that two of the four most senior supervisory personnel had not been in the plant during the period and had not attended plant planning meetings, and that other senior super-visors were in the plant rarely (Bd. Exh. 11, pp. 113-116).
He further found that only 2 of the 10 senior supervisors had any training for boiling water reactors other than a short 36-hour course, four of those 10 had no training in quality assurance t>ut what given in that course, and 3 of the 4 most senior super-visors had only been on site but seven months and had never participated in emergency plan drills (3d. Exh.11, p.114). He further concluded that the licensee's senior supervisory personnel were not paying sufficient attention 2247 163
. to quality control or plant malfunctions to see that proper corrective measures were taken and procedures modified to avoid repetition of reported incidents.
(Bd. Exh.11, pp.115-116; Wessman, Tr. 2799-2800).
Al though these may not have been violations, infractions or deficiencies, they were indicative of problems in CP&L's management of the Brunswick facility (Wessman,Tr. 2814-2825; cf. Utley, Tr. 3530-3531, 3633, 3584-3585, Utley
& Banks, pp. 50-55).
113.
As a result of these memoranda, another meeting was held on liarch 17, 1977, between CP&L officials and Region II of I&E to discuss maintenance controls and the turnover of CP&L supervisory personnel (Cantrell, Attachment 8; Staff Panel III, Appendix B.1, C.1).
114.
Licensee Event Reports (LER's) are reports by licensees to the NRC of potential or actual problems in plant safety equipment or procedures (Utley and Banks, p. 57).
Mr. Cantrell was concerned with what he viewed as an excess number of these reports in his memorandum of September 16, 1977.
The LER's reported for the CP&L nuclear facilities were:
Brunswick Brunswick Year _
Unit 1 Unit 2 Combined Robinson 1975 2
172 174 18 1976 13 166 160 18 1977 117 71 187 30 1978 96 84 185 30 Utley and Banks, pp. 61-62).
2247 164
. At Brunswick an LER is not lightly issued, but must go through as many as seven levels of review (Ibid., p. 58-60, Utley, Tr. 3683-3696).
It is noted Brunswick Unit No. 1 did not become operational until 1977 Therefore, a decreasing trend in LER's appears at Brunswick, although not at Robinson.
115.
In 1975, CPAL became aware that it was submitting a large number of LER's for Brunswick (Ibid., p. 58).
In the 1975-1977 period 120 LER's were caused by instrument problems including over-conservative setpoints.
By modification of these setpoints, the number of instrument problems LER's was reduced to 5 in 1978. Similarly, the containment atmosphere control system caused many LER's until modifications to the system were made in 1978 (Utley and Banks, p. 61).
The LER's in other areas have apparently increased in 1978, as there has been no general decrease in their number.
116.
The enforcement history for Brunswick is set out in finding 89, above.
Generally,as Burnswick Unit No. I did not start to operate until 1977, there has been a marked reduction in citations for Brunswick.
117.
Mr. Cantrell's concern with the Reactor Core Isolation Cooling System (RCIC) involves a system that provides feedwater when the normal feed-water system has been isolated during a shutdown.
It is not an Emergency Core Cooling System (ECCS), but is a partial back up for the High Pressure
( ml i, 2247 165
. p.15, Utley, Tr. 3703).
The RCIC would " trip out" as if running at over-speed if it was started after it sat idle for a few days (Utley and Banks, pp. 64-65; Cantrell, Tr.15-16; Staff Panel III, p. 59). This problem was first identified in July, 1975, and first considered to be caused by an electronic overspeed trip being set too low.
(Cantrell, Att. 1 and 2,
- p. 6, Attachment 11; Utley and Banks, p. 65).
However, this was not the cause and the system was not corrected until the following year when the hydraulic system on its governor mechanism was modified (Utley and Banks,
- p. 65; Cantrell, Tr. 3488).
118. Another failure of CP&L management control, cited by Mr. Cantrell, involved the addition of waste diesel oil instead of lubricating oil to emergency diesel generators on October 2, 1975.
This was caused by CP&L improperly storing the waste diesel oil in drums labelled lubricating oil in the diesel generator building and the failure to check what was in the drums before it was added to the lubricating oil in the generators (Utley & Banks, p. 66; Cantrell, Tr. 3486; Utley, Tr. 3680). The licensee realized this error when adding this waste oil instead of lubricating oil to Diesel Generator No. 3 (Cantrell, Tr. 3369-3370).
It estimated that 110 gallons of waste diesel oil had been added to the 1000 gallon lubricating oil tank on Diesel Generator No. 2, and 55 gallons to the 1000 gallon tank on Diesel Generator No.1.
After speaking with representatives of Mobil Oil Co., it replaced the lubricating oil 2247 166
. in Diesel Generator flo. 2 with the correct oil from sealed containers (Cantrell, Tr. 3370).
From the infomation given that on'y 55 gallons of waste oil were added to the lubricating oil tank fo: Diesel Generator flo.1, Mobil Oil Co. advised there was no need to inmediately replace that oil.
(Cantrell,Tr. 3370,3386-7).
liowever, CP&L did not immediately sample oil from that Generator or Diesel Generators flo. 3 or 4, to see if waste oil had been put in their lubricating systems of this emergency equipment prior to the incident on October 2,1975, although it should have and could have done so.
(3376, 3387-8, 3558, 3680 (Banks)).
flo one at CP&L could tell how long the lubricating oil drums with waste diesel oil had been stored in the diesel generator building, or could verify whether waste oil had been added to the diesels on other occasions (Cantrell, Tr. 3378-3383, pp.16-18; cf. Utley and Banks, pp. 66-67).
119.
The High Pressure Coolant Injection (liPCI) problem cited by Mr. Cantrell involved part of the Emergency Core Cooling System (ECCS) used to supply water to the reactor in an emergency when the low pressure cooling system would not work (Cantrell, p. 21-22, Utley and Banks, pp. 67-68).
The system penetrates the secondary containment and was designed to be auto-matically isolated in the event of a line break. One of the systems to sense such a break and activate the isolation was the occurrence 50-degree difference between inlet and outlet ventilation air temperatures for the llPCI room (Staff Panel III, p. 56).
Sudden temperature changes, particularly durinq +bn wintor, m ld alco cause the isolation to occur, rendering the 1
m oeei. p.
- i).
a y :, u.. i. u, e r c o l e u 2247 167
. 120.
CP&L requested a change to its technical specifications on August 4, 1976, to correct this problem.
The change was not granted by the 11RC until April 28,1978 (Utley and Banks, p. 68; Cantrell, Tr. 3412-3420).
The change was not made until June, 1977, and CP&L tests to assure the HPCI system would still operate with normal ventilation shutdown were not made until September 3,1977, at the spurious isolations were only viewed as a cold weather problem (Cantrell, Attachments 1 and 2, p. 8; Utley and Banks, p. 68).
CPSL sought to explain its delay conducting the tests until September because it needed hot weather to perform them (Utley and Banks, p. 68).
However, these weather conditions existed in July and August (Utley, Tr. 3704).
121.
The problems involving the bulkhead doors between the HPCI and the separate rooms housing the dual Residual Heat Removal (RHR) systems was another matter relevant to management control at Brunswick that Mr. Cantrell called attention to in his memorandum to fir. Dance of September 16, 1977 (Cantrell, Attachments 1 and 2, p. 9).
CP&L indicated to the flRC during license review this ECCS equipment was to be located in separate watertight compartments to prev 9t loss of redundancy in the case of flooding.
The dual RHR systems are lc:ated in two separate rooms with the HPCI system, also an ECCS system, in a room between them.
The safety-related RCIC system is also in one of the RHR rooms.
To provide access to 2247 168
- the HPCI system there are watertight bulkhead doors.
The watertightness of each of the compartments must remain secure, as recognized by CP&L in the license review, so there could be no common failure of equipment from a single cause.
CP&L did not understand that leaving the doors open so that flooding could occur in all compartments in an emergency would make the equipment of little use in such a situation (Utley, Tr. 3546,3673).
Common flooding of compartments would lead to loss of redundancy necessary in cuergency situations.
(Banks,Tr. 3675-3676).
Further, the bulkhead doors must be kept closed.in order to maximize the effectiveness of the fire suppression system for HPCI turbine fires (Cantrell, p. 9).
122.
On December 1,1976, both bulkhead doors were found open and unattended.
(Banks, Tr. 3669). The latching mechanism on one was jammed so it could not be closed.
CP&L repaired the door, posted a sign to keep the doors closed, and instituted a system to check that they were kept closed on each shift.
Again on February 1, 1977, the doors were found open.
CP&L reviewed with all its employees the need to keep the doors closed.
On July 21,1977, one of the doors was again found open.
There was no alarm to tell if the doors were open (Banks, Tr. 3673).
A few days later, CP&L agreed to install annunciator alarms on the doors that would signal in the control room when the doors were open.
D'f L was confirmed by a CP&L letter of October 5,1977.
(Cantrell,pp-a alt. 12, 13, 14, 15; Cantrell, f, p. 62). This change was not Tr. 3407-11, 3446-9, 3474 ; Stafi ain :
completed until 15 months later in February b79 (Utley and Banks, p. 67).
2247 169
. 123.
Another problem cited at the hearing involved the augmented off-gas system (Cantrell, p. 23-24 following Tr. 3347; Cantrell, Att.1 & 2, p.10; Cantrell, Tr. 3429-3430). The inoperability of this system could have an adverse effect on radioactive gas releases in the case of loss of fuel integrity (Staff Panel III, p. 20; Dance, Tr. 3184-3186).
- However, this augmented system was designed to bring releases below the design limits of Appendix I to 10 CFR Part 50 and CP&L's technical specifications, which the Brunswick system now meet (Schwencer, Tr. 3258-3259, Dance, Tr.
3185).
It is not the off-gas system Mr. Wilber's testimony referred to (Dance, Tr. 3184).
The problem did not arise until April 1977 when the licensee attempted to put this system into operation (Cantrell, pp. 23-24).
When the licensee attempted to put the presently designed augmented off-gas system there were hydrogen explosions in the rystem and it will not work (Banks, Tr. 3550). The licensee is investigating a recombiner to re-place the augmented system which will recombine oxygen and hydrogen to form water, and proposes to do this work in 1981 (Banks, Tr. 3552).
As any increased radioactive releases caused by fuel failure could be con-trolled by either reducing power or shutting the plant down and since the licensee is presently meeting requirements, the Staff has not objected to the licensee's proposed schedule (Schwencer, Tr. 3280-3286).
124.
lieither flRR nor Region II of 1&E nor Floyd S. Cantrell,who originally thought so, believes the CPSL license to construct Harris should be 2247 170
conditioned upon improving its staffing, manpower practices or training (Staff Panel IV, pp. 4, 6-8, 19-20; Staff Panel III, pp. 2-4, 41-42, 68-72; Miner, Tr. 3271-3272, Haass, Tr. 3331-3334; Cantrell, p. 35, following Tr. 3347; Cantrell, Tr. 3428,3455-3456; see also Wilber, Tr. 2879; Bd.
Exh. 11, p. 27 (Wilber); Wessman, Tr. 2802-2803, 2806; Bd. Exh. 11, p. 112 (Wessman); Kellogg & Ruhlman, Tr. 2709-2712; Cantrell, p. 30-31).
CP&L's operations have considerably improved since Mr. Cantrell reconmended that the license be conditioned (Cantrell, pp. 30, 35; Cantrell, Tr. 3455-3459; Staff Panel III, pp. 69-72).
125.
NRR will require CP&L to develop a plant staff capable and trained to accomplish all preoperational testing and start-up of each unit of Harris, and to operate that unit before recommending operating license for that unit (Haass,Tr. 3331-334).
Plant staffing and training will be looked at closely by NRR and I&E prior to recommendations to issue operating licenses for the Harris units, and the Staff presently has no reservations that CP&L will provide staff and training necessary to operate those units (Haass, Tr. 3271-3272).
CP&L offered extensive testirony on its present training, its training plans, and its projected staffing -of the Harris units (Utley
& Banks, pp. 73-76,91).
At present the hRC Staff has reviewed these plans for proposed training, and found them adequate to provide a basis to develop a qualified and capable operating staff for the Harris units (Staff Panel IV,
- p. 19).
2247 171
126.
On the basis of the evidence rer.ounted in the preceding findings, the Board con luded that CP&L has adequate plans which should result in the proper s:
fing and start-up of the Harris units.
On the same basis no additional condition, relevant to the issues litigated in this supplemental proceeding, should be attached to CP&L's construction permit for the Harris units.
The Board further finds on the basis of preceding findings that CP&L is equipped to observe and agrees to observe the safety standards to protect health and to minimize danger to life and property as the Commission may establish (See Atomic Energy Act of 1954, as amended, 5103(b)(2); 42 U.S.C. 2133(b)(2).
VIII. RANKING UTILITIES HAVING NUCLEAR POWER FACILITIES 127. At the opening of the remanded hearing (Tr. 2172), Staff counsel provided copies of a Draf t Report An Evaluation of the Nuclear Safety-Related Management Performance on NRL Operating Reactor Licensees During 1976, February 1977 (Draf t Report) (Board Exhibit 8).
There is great interest, by the government, industry and the general public in rating or ranking the performance of utility companies having nuclear units up to their performance.
The Draf t Report is an effort in that direction.
It was extensively discussed among Board members and the Staffs I&E witnesses, Tr. 2280-2301, 2320-2328, 2330-2332, 2353, 2419-2421.
The Board concludes, 2247 172
. based on its discussion with the witnesses and based upon its own expertise after examining the methodology of the Draft Report; that methods of evaluating licensees set out in the Draf t Report were not shown to be reliable in this hearing, and that the Draft Report is not competent evidence of the quality of perfonnance of licensees, but only a first step in such a process as the report itself recognizes (see Bd.
Exh.
8, Tab. 2).
IX.
CONCLUSIONS OF LNe!.
128.
The Board finds the evidence presented by the Staff and CP&L to be sub-stantial, probative and unimpeached by other evidence or by cross-examination.
On the basis of that evidence, the Board finds that Carolina Power and Light Company, together with its contractors and consultants to be technically qualified to design and construct the Shearon Harris facility, and further meets the standards of Section 103(b)(2) of the Atomic Energy Act of 1954, as amended, 42 U.S.C. 2133(b)(2), as CP&L is equipped to observe and agrees to observe such safety standards to protect health and to minimize danger to life or property as the Commission may establish.
The Board further finds no further conditions, at this time, need be attached to the construction permits for the Harris facility dealing with issues litigated in this proceeding.
2247 173
X.
ORDER 129. Based upon the Board's findings and conclusions, and pursuant to the Atomic Energy Act of 1954, as amended, and the Conmission's regulations, IT IS ORDERED, in accordance with 10 CFR 562.760, 2.762, 2.785 and 2.786, that this supplement to the Initial Decision shall be effective immediately and shall constitute the final action of the Commission thirty (30) days af ter the date of issuance hereof, subject to any review pursuant to the above cited rules.
Exceptions to this Supplemental Initial Decision may be filed by any party within ten (10) days after service of this Supplemental Initial Decision.
Within thirty (30) days thereafter (forty (40) days in the case of the Staff) any party filing such exceptions shall file a brief in support thereof. Within thirty (30) days of the filing and service of the brief of the appellant (forty (40) days in the case of the Staff), any other party may file a brief in support of, or in opposition to, the exceptions.
130.
Respectfully submitted, tw Edwin J. Reis Counsel for NRC Staff Dated at Bethesda, Maryland, t h i s M "' < ' ' " " " " ' - "
2247 174
~
~
UNITED STATES Of AMEPsICA fiUCLEAR REGULATORY C0i"iISSI0fl BEFORE THE ATOMIC SAFETY'AND LICENSIflG BOARD In the Matter of CAROLINA POWER AND LIGHT COMPANY
)
Docket Nos. 50-400
)
50-401 (Shearon Harris Nuclear Power Plant,
)
50-402 Units 1, 2, 3 and 4)
)
50-403
' CERTIFICATE OF SERVICE I hereby certify that copies of " STAFF'S PROPOSED FIrlDINGS OF FACT AND CON-CLUSIONS OF LAW Ill THE FORM 0F A SUPPLEMEllTAL INITIAL DECISI0il (CONSTRUCTION PERMITS)" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal mail system this 10th day of May, 1979:
Ivan W. Smith, Esq., Chairman
- Thomas Erwin, Esq.
Atomic Safety and Licensing 115 West Morgan Street Board Panel Raleigh, North Carolina 27602 U.S. Nuclear Regulatory Com:aission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board
- Mr. Glenn 0. Bright
- U.S. fluclear P,egulatory Coainission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Parel*
U.S. i'uclear Regulatory Connission Dr. J. V. Leeds, Jr.
Washington, D.C.
20555 10807 Atwell Drive Houston, Texas 77095 Docketing and Service Section*
Office of the Secretary Richard E. Jones, Esq.
U.S. Nuclear Regulatory Comnission Associate General Counsel Washington, D.C.
20555 Carolina Po.ler & Light Conpany 336 Fayetteville Street Wake County Public Library Raleigh, North Carolina 27602 104 Fayetteville Street Raleigh,iiorth Carolina 27601 2247 175
.. ; t,. ',
- 2_
George F. Trowbridge, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, fl.W.
Washington, D.C.
20036 Dennis P. Myers Attorney General's Office State of florth Carolina P. O. Box 629 Raleigh,tiorth Carolina 27602 i
Edwin J. Esis Counselgorf4RCSt'aff 2247
'76 e
,