ML20056C152

Informs That 921130 & 1215 Submittals Re Plant Corporate Improvement Initiatives & 3 Yr Plan Acceptable W/Appropriate Measures Being Proposed to Overcome Organizational & Performance Weaknesses

ML20056C152
Person / Time
Site:	Brunswick
Issue date:	03/08/1993
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Cavanaugh W CAROLINA POWER & LIGHT CO.
References
NUDOCS 9303300158
Download: ML20056C152 (7)

Text

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i VLR - 8 W3 Docket Nos.:

50-325, 50-324

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License Nos.:

DPR-71, DPR-62 Carolina Power and Light Company ATTN: Mr. W. Cavanaugh, III President and C00 P. O. Box 1551 Raleigh, NC 27602 Gentlemen:

SUBJECT:

CAROLINA POWER AND LIGHT COMPANY (CP&L) AND BRUNSWICK IMPROVEMENT.

PLANS This is in reference to your Corporate Improvement Initiatives (CII) and Brunswick Three-Year Plan submitted on November 30, 1992, and December 15, 1992, respectively. Overall, we find the approach taken in both of these improvement plans to be acceptable, with appropriate measures being proposed to overcome organizational and performance weaknesses.

However, due to the developmental status of the plans' improvement items, there are some uncertainties regarding implementation and monitoring. Accordingly, you are requested to address these uncertainties, as well as other concerns, by responding to the enclosed questions within 30 days of the date of this letter.

t In addition, it is our understanding that your material walkdown inspections will continue subsequent to restart of the units. We believe your plans and schedule for such walkdowns should be included in the Three-Year Plan.

In response to this letter, you are also requested to address this issue.

As we discussed at our meeting on February 4, 1993, we should meet periodically to discuss the progress and status of your CII and Brunswick Three-Year Plan.

In your response to this letter, I request that you propose a schedule for these meetings.

Should you have any questions concerning this matter, please contact us.

Sincerely, Original signed by:

Stewart D. Ebneter Stewart D. Ebneter Regional Administrator

Enclosures:

1.

Questions Concerning i

CP&L's Corporate i

Improvement Initiatives 2.

Questions Concerning The i

Brunswick Three-Year Plan cc w/encls:

(See page 2) gg 9303300150 930308 DR ADOCK 050003 4 290038 ypoj

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1 IKR - 8 1993

' Carolina Power and Light Company 2

l cc w/encls:

i R. A. Anderson

[

Vice President i

Brunswick Nuclear Project j

P. 0. Box 10429 Southport, NC 28461 i

t R. E. Morgan i

Plant Manager Unit 1

_l Brunswick Steam Electric Plant i

P. O. Box 10429 i

Southport, NC 28461 M. Brown Plant Manager Unit 2 Brunswick Steam Electric Plant P. O. Box 10429 Southport, NC 28461 H. Ray Starling Vice President - Legal Department Carolina Power and Light Co.

P. O. Box 1551 Raleigh, NC 27602 j

Kelly Holden i

Board of Commissioners i

P. O. Box 249 i

Bolivia, NC 28422

.j Chrys Baggett State Clearinghouse Budget and Management

.i 116 West Jones Street Raleigh, NC 27603 Dayne H. Brown, Director Division of Radiation Protection N. C. Department of Environment, Health & Natural Resources P. O. Box 27687 Raleigh, NC 27611-7687 H. A. Cole t

Special Deputy Attorney General State of North Carolina P. O. Box 629 Raleigh, NC 27602 (cc w/encls cont'd - See page 3)

I

IMR - 8 1993 Carolina Power and Light Company 3

(cc w/encls cont'd)

Robert P. Gruber Executive Director Public Staff - NCUC P. O. Cox 29520 Raleigh, NC 27626-0520 Ms. Gayle B. Nichols Staff Counsel SC Public Service Commission P. O. Box 11649 Columbia, SC 29211 bcc w/encls:

Document Control Desk H. Christensen, RII P. Milano, NRR L. Plisco, DED0 NRC Resident Inspector U.S. Nuclear Regulatory Commission Star Route 1, Box 208 Southport, NC 28461

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(cc w/encls cont'd)

Ms. Gayle B. Nictrls Staff Counsel SC Public Service Commission P. O. Box 11649 Columbia, SC 29211 bec w/encls:

l Document Control Desk H. Christensen, RII

rR d o, NRR L P. C o m.

!iRC9edidenl.Inbp$ctor U.S. Nuclear Regulatory Commission Star Route 1, Box 208 Southport, NC 28461 i

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t ENCLOSURE 1 l

QUESTIONS CONCERNING CP&L'S CORPORATE I

l-IMPROVEMENT INITIATIVE (CII) l l

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1.

What standards will be used to track and assure success of initiatives?

?

L Are they quantitative / measurable?

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2.

On page V-3, what addresses NAD issues 3, 4 and 5?

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3.

How will self-assessment corrective action program. inadequacies (issues 3 I

and 5 on pages V-1 and 2, respectively)-be corrected by CII-2 and 3?

4.

Will the makeup and function of the Nuclear Safety Review Committee (NSRC)

I and the Nuclear Safety Oversight Committee (NSOC) be included in Technical Specifications? How are these safety review committees related to those oversight requirements currently in the T.S.?

j 5.

Are there qualification requirements and length of terms for outside l

members / experts of the NSRC and NSOC?

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i la ENCLOSURE 2 QUESTIONS CONCERNING THE BRUNSWICK THREE-YEAR PLAN

'l.

What is NAD's role with regard to the three-year plan?

2.

Has the three-year plan been crossed referenced with the Corporate l

Improvement Initiatives to assure that no conflicts or inconsistencies exist? Provide cross-reference.

3.

Chapter 3, page 5, Plannina What is meant by, "the backlog of plant modifications and corrective maintenance will be optimized to the number that is cost effective...."?

4.

Chapter 4, page 14, Items Scheduled Beyond Commitment Date What is the reason for missing original completion dates on PID numbers:

Ol821A (Improve Security Lighting), 05644A (AC Voltage Drop Analysis),

G0017A, (DC Voltage Profile Study), and G0051A (Upgrade Scam Modules)?

Have any potentially significant issues been identified under PID 05644A or G0017A, and are they subject to PN-30 screening?

t What other regulatory commitments have been or will be missed which are not included on page 14 and 15?

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5.

Chapter 7, page 30 Status Report Frequency l

^t How often will summary reports be given to employees?

Like the three-year plan, the IAP also had key managers over projects / task items, utilized status reports for senior management, and relied on the Control and Administration organization for administrative facilitation.

1 Accordingly:

j i

What will ensure success of the three-year plan?

r Are standards / goals quantitative / measurable?

i 6.

Chapter 8, Initiatives For initiative (s):

103 (Corrective Maintenance Backlog);

How is 12 weeks of backlog determined, and what will be the levels at restart?

i 302 (Work Processes);

With regard 'to an interim modification process to expedite B0P fixes (Task 03A), what steps will be used to ensure adequate reviews and evaluations are performed?

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Concerning removal of acceptance testing from plant modification packages (Task 08A), what type of training / procedures will the system engineers have to ensure that appropriate acceptance testing is performed?

303 (Improve Ability To Identify And Correct Problems);

As the designated management sponsor no longer works for CP&L, who will now perform this function?

Since an effective self-assessment / corrective action program (CAP) i is a major key to Brunswick's recovery, why isn't related program implementation and training scheduled to be accomplished sooner?

1 What action will ensure sub-program issues are tracked and trended for detection of adverse trends / common root cause; and therefore entry into the CAP for broader root cause resolution.

503 (DBD);

Task 02C shows completion of safety-related system

+

t validation by 12/31/95, but Chapter 4 (page 14, PID B0019A)

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indicates 12/94 - - Which is correct?

r P

508 (AC Source Improvement); Why have previously committed GDC-17 related modification dates (June 18, 1991 meeting with NRC staff) been delayed for further review?

t 103, 104, 106, 207, 208, 305-310 and 509-515; There are no general or specific beginning and completion dates...Have these initiatives been assigned resources (i.e., time, people, funding, etc.)?

7.

Chapter 8. Major Projects l

For PID(s):

04830A (Maintain EQ Program);

What do the 14 EQ-related EWRs specifically concern, and are they subject to PN-30 screening?

05092A (Instrument Rack Repair);

What instrument racks are being scheduled for design work after the units are restarted?

07250A (Eliminate SRM and IRM Noise);

If related cabling is not in conformance with FSAR, what is restart justification?

07647A (Thermal Binding of RHR F004 Valves):

Have all related E0P f

operations been considered in the deferral of this item to well into the future?

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