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LTIO%s1. Wills 11.Elil.oMH Cn in I
517 Florida Avenue.NW 3
Washington, DC 2(XX)l.1850 (202) 667-7515 Fa t2021462 4145 4
URGENT MATTER g
April 28, 1993 j
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Hon. Ivan Selin Chairman U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l
Re:
carolina Power & Liabt company Bruns _ wick _ Steam Electric _ Plant j
Dear Chairman Selin:
e We are writing to inform the Nuclear Regulatory Commission
("NRC") of extremely serious allegations concerni6g the operation of the Brunswick Steam Electric Plant, near Wilmington, North i
Carolina. These allegations h:v4 been received by the National Whistleblower Center ("NWC") from a whistleblower at the plant who, due to his status as'an employee in the nuclear industry, would prefer to be granted confidential alleger status.
From the information obtained by the NWC, it appears that the operation of the Brunswick nuclear plant by the Carolina Power & Light Company has reached crisis proportions.
The consequences of these allegations are severe and-we believe may constitute an imminent health and safety risk to the entire Wilmington, N.C. metropolitan area.
These allegations are as follows:
(1)
A complate breakdown in the Quality Assurance (QA) program overseeing the integrity of the plants vender manuals.
This QA breakdown raises the risk that the' spare parts which have been installed in the plant over a ten year period may be defective; (2)
A breakdown in the plant's security system which may
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leave the facility open to terrorist attack; 3093&o/95 a :e z,,i-
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'xPP-OG-93
&J E D 13 309 P. O3 e
j Ivan Selin, NRC chairman April 28, 1993 Page Two 3
(3)
The harassment and intimidation of employees who raise safety related concerns to their management; I
(4)
The failure to CP&L to train the thousands of contractors they have employed in the proper QA procedures and the failure to implement a QA program in j
the work assignments of the contractors; (5)
A breakdown in the plants preventative maintenance program; Attached to this letter is a sample memorandum which 4
indicates the scope of CP&L's QA breakdown.
The memorandum, which was not intended for outside release, documents the QA l
problem CP&L has experienced in just one.small area of the plant.
From the information obtained by the NWC, it appears as if this QA problem is systemic throughout the entire facility, j
i We request that the 4RC take immediate action regarding f
these ongoing unsafe and hazardous conditions.
The Brunswick plant should be immediately shut down until these serious safety problems have been fully resolved.
CP&L should not be permitted to restart Brunswick until it can prove that it can operate the plant in conformance with its licensing requirements.
Furthermore, a special investigative team should be appointed to monitor and inspect conditions at the plant.
i Respectfully submitted, b
(
Stephen M.
Kohn chairman, Board of Governors, National Whistleblower Center 6
Enc.
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""*~OG-93 WED 13: 09 P. o.
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E63 l l C. M TO:
Suroch Cupca, CPT=L PMDD 2roject Managor R G. c t <~D f,C"~P P
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OCrS
!. cud Analyot FECM:
M2.1 1
l CATih 2/05/93 I
Diccussion of M::qcr Diocrop.mcico :dontified
.V3 K.0T :
.o summarize seine of ti f-
- .wtructions frcm Surcch,
- will t ry "f i nd dura ng. tne life <'.
vW w:ficiencJ ec that have bcon identi Thenn " global" diucrepanciev arc. indicativra of a t
...dicuratien Management Program that has not being affcetivu y l
projecc
- .m;uemented.
These discrepancies w;.ll s:.gni ficantly impact i.)m our ulti:nate product: Attachment l
r:redibility and usefulness of j
The following is a summarization:
j 3's.
in che Cheer. list / Procedure field i
Numercus erroneous ener:.eeThese are dividad into four types of errorn.
1 on AMMS/EDES.
j j
a)
The entry :.s an incorrect Plant. Procedure number.
This indicates that Frocecures are-revised and/or deleced without changes being consis tentl y incorporated into the Plant Data Bases M MS/EDBS).
It is our understanding that the plant does nou l
see
'4 controlled data ' cases, i'
consider EDBS/AMMS as I
" Generic / Global" Dicerepancy' Report 0000-00004.
b)
Thu correct Plane Procedure number was incorrectly i
cntered into cho data base.
See
" Generic /Globel" j
Discrepancy Report 0000-00004.
I c)
There are numerous entries in
'he FM Procederv
?
(Checklist) field that are act a procedura (examp]<ri are:
N/A, see above, FP-2tb9, EER Required, etc).
i Atter hours of evaluation we have determined that there are two types of "hoefas "
entries _
in th' l
i checklist field:
t' The PM taak has no procedure detailing ito performance, but the PM task needs a procedav<-
i 1)
Those have been identified in Glob.? I j-Discropancy Report d 0000-00082.
Note c h.~ t-i th.
rocolutten of.this d2acrepancy may require j
initiation of new procedures or the simp.u into an existimi incorporation of the Equipment
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procedure.
does not require a
wriutno 1-2)
The PM taskThe FM cauk ir, within the skill
.t Procedure.
the craft.
See Global Discrepancy Report
- . I-Resolution of this discropancy i
0000-00083.
requires the creation of one uniform code thit f.. eld 4
aChecklist" will be used in the Data Easo i
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W P R - 2 :3 - 9 3 WED 13 : 10 P.
05 for chic altuat:.cn.
3,u ad en downicad 5,
tnere dre apprcximately 1200 unique Prctedure entries in the PMS3 module.
Cf those entries, only 908 are correct.
The above Giccal Discrepancy Reports cover appronmately 2 5'r of all the record ener:.ca f or "checklista.
i 2.
Alcng the some line. we have numerova spec:fic ~;iscrepancy Reports which note that several plant Procedures contain Equipment ID Numbers that do not match up ident:.cally with j
the AMMMS/EDBS Equipment ID entries.
Examples are:
tho procedure leaves off the unit 1/2 designatort procedure ic for a given system, but the tag ID has no unit /cyntem ident:.fier.
This is documented on spec:.f ic Discrepancy Report Forme.
3.
We have found examples cf the following:
Different recordn for the same tag numbers will have different model numbers / vendor manual numbers against the one Equipment ID Number.
4.
Numerous procedures do not list applicable Tag Numbers.
Some use textual dcecriptions that may ellow a person to make a reasonable assumption as to what the real tag number is, but this is an interpretation.
This situation will be identified by the use of a
validation code:
"G" for Generic.
Discrepancy Reports are not being written for this occurance.
5.
Frcquency problemo; We have over 177 codes on AMMs for frequency.
For the frequency of " Refueling" there are the following codes R1, RO, D.M, BR, CY, R,
YM.
Same state refuel, 18 months, or a specific number of days (540).
The routes have not been changed to reflect the new maximum of 16 codes.
6.
The above 5 items raise the following question: Aro Plant Procedures receiving a documented review for irnpact on FM tasks (route v3 applicable taoks vs applicable Equip ID Numbers) and is information being properly captured in a controlled manner for use on site?
7.
During the review of Vendor Manuals, the following Global Discrepancies were noted:
a)
The number of FP#'s identified n the FMBC Module for downicad Five is 464.
We have noted the following problems no microfiche for the FP4 in the library:
NCRS does list the FP# as active.
This is documented as Global Discrepancy Report 9 0000-00002.
c)
For the :.9,0 00 plus Equipment ids for the 11000 plus PM activitics (routes) subject to our revie.w, we nc,ted that there approximately 5,000 records with no WM
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'NPR-OG-93 LIE D 13: 11 p,gg i
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t Model er Model Number entered an AMMS/EDBS.
'here are j
also 1000's of records.with no modei number er vendor manual entry.
The inability to
'ocate chio l
informat:.on wil'. significantly :.mpact the ability to j
complete Attachment Pa offactively.
These are documented as Global Discrepancy Reports 0000-00003.
I 0000-00005, and 0000-00006.
1 j
d)
- t appears that vendor related :.nformatio:1. rece.ived at the site was not alwayo reviewed for applienbil;.ty and i
incorporatien into the
" master" vend.er h.anual.
~
Instead, vendor information (we have ide.ntified ten j
different types) was given an FP# ar d, placed in the files.
During cur reviews, we have found.up to six l
FPd's against one model number.
.It is important to i
note that the Equipment Tag Numbers For the above
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Model Number never reference the eix FP#'s.
This is l
alco common in the situation where there are two FP#'s against one model (Equipment ID's will reference.cn FP l
but not the other).
This creates a situation which l
will hamper us when we.do r.ct achment 3's.
We will i
never. know for sure that we have all: the applicable l
V/M information for any Medel/ Equipment combination, j
This situation has been identified in global i
' l, Discrepancy Report'# 0000-00194.
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e)
It was also noted. that most V/M FP#'s (we. have reviewed over 200 FP Manuala) reviewed so far by tho group do not have any documentation attesting to an 4
Engineering review for plant applicability.
Lists of applicable Plant Equipment ID Numbers to the FP8 are frequently missing.-
These. situations are being identified 'by the.une of validation codes (see memo SLF.29) by the analyst performing che PM V/M reviews.
l A Global Discrepancy Report will be written when all i
FP#'a have been reviewed.
We have also nocod that fps' were found whern portion.1 of the manual are lined i
out with no uplanatica ur initids.
2 1
8.
Along with item a above, it was noted that numerous Plant Procedurcs do not reference the applicable V/M and Model information in the reference section/ body of the procedures.
Numerous PM Procedures (OMI'S in particular) have - no Vendor Manual, Model, or applicable Equipment ID-Uu:thers in the procedure Reference section or procedure c
j body.
This situation has been identified in ' global Discrepancy Report # 0000-00186 and 1t0000-00194.
I 9.
~t was also noted that the numerous PM tasks (routes) on i(
A:HS/EDBS listed a scheduled performance date that wan exceeded by the current date.
We do not know if they wero actually performed or if there was a problem in getting the i
performance data into AMMS/EDBS.
This situation has boon 4
identified in Global Discrepancy Report # 0000-00008.
i i
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" PR-OG-93 WED 13: a2 P.o-I I
10.
A review of download 5 data indicates tha: PM records in the data base are being changed without proper Engineering review and approval.
Download 4 occurred on 1/11/93.
Download 5 cccurred on 2/5/93.
Between these two dacco, changes in Equ:.pment ID Number field entries numbered 339 There were 135 deletions and 204 additions.
Were'these all identified on PMRRs?
It appears that planneru have traditionally, and still are, making unreviewed changec to j
PM tasks which include deleting and adding equipment to PM casks (this is the authors subjective opinien).
cct Peter Ecuglass - Charleston Chron File l
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