ML20086H938

Application for Amends to Licenses DPR-71 & DPR-62, Terminating Improvement Program,Per Confirmatory Order EA-82-106,based on Util Implementation of Program Via Integrated Action Plan

ML20086H938
Person / Time
Site:	Brunswick
Issue date:	11/27/1991
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
EA-82-106, NLS-91-292, NUDOCS 9112100193
Download: ML20086H938 (15)

Text

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Cuolina Power te Light Company P O Bon t$hi e Relegh. N C //f 02 NOV 2'T 1991  ;

G F "AUGHN m mwooni SliRIAL: NLS-91292 '

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10CFR50.90 90TS1109 l

United States Nuclear Regulatory Commission NITliNTION: Document Control Desk  !

Washington, DC 20555 l 9UNSW;CK STliAhi lilliCTRIC PLANT, UNIT NOS.1 AND 2 DOCKIIT NOS. 50-325 & 50-324/LICIINSli NOS. DPR 71 & DPR-62 Rl!OUliST FOR LICl!NS!! AhiliNDhiliNT TliRh11 NATION OF llRUNSWICK IN1PROVliA111NT PROGRAh! l l

Gentlemen:

In accordance with the Cose of Federal Regulations, Title 10, Parts 50.90 and 2.101 Carolina Power & Ligh' Company hereby requests a revision to the Operating License for the llrunswick Steam likcfric Plant (llSliP), Units 1 and 2.

On December 22., 1982, the NRC issued Confirmatory e 'rder IIA 82106 which required implementation of the I3runswick Improvement Program (111P). The actions recommended in the illP have been implemented and the intent of the program fulfilled.

As such, the Company has met the intent of Confirmatory Ordar liA-82106. Since 10 CFR 50.54(h) requires that the operating license be subject to all Orders of the Commission, the Company is requesting a license amendment to termin"'e the requirements of Confirmatory Order liA 82106.

Carolina Power and Light Company has mechanisms in place, outside of Confirmatory Order IIA 82-106, to assure the safe operation of the llrunswick Plant. These mechanisms include long-term practices established by the illP and the recently developed Integrated Action Plan (IAP). The I AP was developed by llrunswick Plant and Corporate management to ensure that the findings anJ. recommendations from Cresap's Nuclear Operational and hianagement litfectiveness Assessments and the NRC's Diagnostic livaluation Team (DliT) Report (dated August 2,1989) were considered; that an appropriate response was made to NRC findings; and that progress on the recommendations could he tracked. The IAP synthesized the recommendations of the studies and outlined the stept required to implement them.

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Document Control Desk NIS91292 / Page 2 linclosure 1 provides a detailed description of the proposed changes and the basis for the changes.

linclosure 2 details the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration.

Please refer any questions regarding this submittal to hir. hi.11. Oates at (919) 546 6063.

Yours very truly,

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G.13. Vaughn l

Gl?V/JCP l

cc: hir D.11.13rown hir. S. D. Ebneter hir. N.11. le hir. R. L Prevatte linclosures:

1. Ilasis for Change Itequest 2, 10 Cl:R 50.92 livaluation G. II. Vaughn, havP g been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.

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4 l!NCLOSURll 1 HRUNSWICK STIIAhi El.ECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50-324 OPERATING LICENSES DPR 71 & DPR 62 REQUEST FOR LICENSE Ah1ENDh11?NT '

TERh11 NATION OF llRUNSWICK lh1PROVEh1ENT PROGRAhi BASIS FOR CilANGE 11lLOUBST fwposed Change On December 22,1982, the NRC issued Confirmatory Order HA 82106 which required implementation of the Brunswick Improve.nent Program (HIP). The actions recommended in the HIP have been implemented and the intent of the program fulfilled.

-As such, the Company has met the intent of Confirmatory Order EA 82-106. Since 10 CFR 50.34(h) requires that the operating license be subject to all Orders of the Commission, the Company is requesting a licen' amendment to terminate the requirements of Confirmatmy Order !!A 82106.

lIMil On October 29,1982, CP&L submitted the Brunswick Improvement Program (HIP) to the NRC for review. The HIP is a comprehensive program designed to consolidate and facilitate efforts to implement iraprovements at the Brunswick Plant. The HIP specified 134 detailed tasks includirg actions such as filling a Senior Specialist position,100 percent Quality Assurance review of Technical Specification requirements every threc '

years, and reviewing and implementing, as appropriate, each of the 167 recommendations that resulted from hianagement Analysis Company's review of CP&l.'s Corporate. Quality Assurance Program. Jrhe NRC subsequently placed the IllP under a Confirmatory Order, on December 22,1982, which formalized CP&L's commitment to the program.' In accordance with its original schedule, the program was essentially completed as of December 31,1983. In a letter dated April 3,1984, the NRC actified the Company that they had determined that CP&L had met the requirements imposed ,

by Confirmatory Order EA 82106.

1 While cach of the specific BIP actions was appropnate at the time ofimplementation,

- some of these actions are either no longer necessary or the objectives can be achieved in a more efficient manner. In the HIP, the Company committed to perform periodic review in five areas: Technical Specification Surveillance; In Service Inspection / Appendix J; Commitment Verification; Technical Specification Amendments; and Regulatory Requirements Changes. Irnplementation of these actions was assigned to the Corporate Ouality Assurance Department and the Brunswick Onsite OA/OC Unit.

Based on the results of these periodic reviews, enhancements to managemerit programs, El 1 -

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and ongoing improvements in procedural controls, CP&L believes that line management continues to perform with appropriate control of existing programs and, as such, termination of Confirmatory Order EA 82106 would facilitate evolving management and process improvements.

Carolina Power and 1.ight Company has mechanisms in place, outside of Confirmatory Order EA 82106, to f acilitate operation of the llrunswick Plant These mechanisms include long tem practices established by the IllP and the recently dcveloped Integrated Action Plan (IAP). The IAP was developed by llrunswick Plant and Corporate mans;ement to ensure that the findings and rec mmendadons from Cresap's Nuclear Operational and Management Effectiveness Assenmenu and the NitC's Diag. astic Evaluation Team (DET) lleport (dated August 2,1984) were considered; that an appropriate response was made to NitC findings; une tiiat progress on the recommendations could be tracked. The IAP synthes red the recommendations of the studies and outlined the steps required to implement the:n.

NitC Inspection lleport 89-20, dated September 22,1989, documents the results of an inspection to determine if the long term illP ltems, intended to assure continued improvement, were in place. This report also correlates IllP ltems with DliT 1 mdings.

Por each of the long-term lilP ltems, *e inspector found that either the objective of the IllP ltem continued to be met or that WT 1;indings addressed the issue. Ilach of the DET Findings have been addressed by CP&L in the IAP. Since the long term IllP ltems are being met or are addressed by the IAP, maintaining Confirmatory Order EA 82-106 is no longer necessary.

The attached table, titled IllP ltem Status Summary, provides a description of each individual BIP ltem and status.

Carolina Power & Light Company continues to monitor performance to assure that appropriate management and programmatic controls are in place. Therefore, based on implementation of the IllP reouirements, the NitC's inspection finding that CP&L has satisfied the requirements of Confirmatory Order EA-82-106, and to facilitate management improvement efforts, Carolina Powo & Light Company requests that Confirmatory Order EA-82-106 be discontinued.

El-2

lilP ITEM STATUS

SUMMARY

ltem Action Comment 11 listablish centralized systematic Item I 1 is addressed by ongoing STSS program under Director of and discussed by the following DlIT Regulatory Compliance for Paragraph / Finding (source - Inspection identifying, scoping, scheduling. Report 50-325/324/89-20, dated tracking, or closing of all September 22, 1989),

s,.iveillance requirements and regulatory commitments and 2.1.4.1 (3.4.1.1) - Positive Finding requirements.

1-2 Document Corporate Procedure Task complete per Nbietter dated to address all NRC April 3,1984.

Confirmation of Action Letters, 111 IIstablish a Nuclear Operations Task complete per NRC letter dated procedure governing the April 3,1984.

standardization and preparation of plant procedures, 112 Utilize the services of a qualified item 112 is addressed by the following consultant to modify or develop DET Paragraphs / Findings (source -

necessary plant operating inspection Report 50-325/324/89 20, I procedures (effort to be dated September 22,1989).

<tonducted in concert with ,

Users" and subject to procedure 2.1.2.6 (3.2.3) in Item 11-1). 2.1.4.4 (3.4.1.3)

Im 2.1.4.6 (3.4.1.4) d 1

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lilP ITEh! STATUS SUS 1'51Al(Y  !

Item Action Comment Il 3A Review 100% of existing and item Il 3A is addressed by the new surveillance procedures following DET Paragraphs / Findings used to meet regulatory (source Inspection Report 50-requirements for technical 325/324/89 20, dated September 22, adequacy. 1989).

2.1.4.1 (3.4.1.1) 2.1.4.2 (3.4.1.2) 2.1.4.3 (3.4.1.2) l After HIP initiation in 1982 a comprensive program of first & second party nuclear safety and technical reviewers was established (Tech Spec  ;

6.5.1). In addition, the Nuclear  ;

Assessment Department (NAD) reviews procedures as an integral part of its performance based assessment process, although the NAD review is not an in line or 100% review. NAD is also charged with making recommendations for revised procedures in accordance with Tech Spec 6.2.3.

Il 3B Review changes in revised Task complete per NRC letter dated operational procedures for April 3,1984, technical adequacy; i.e.,100%

for safeguards procedures and selected screening for others.

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1 lilP ITEh! STATUS SUSth1AlW llem Action Coniment .

1111 Expand surveillance of ISI, item 1111 is addressed by the following Appendix J, Technical DET Paragraphs / Findings (source -

Specifications, and Regulatory inspection Report 50 325/234/89-20, Requirements to enhance dated september 22,1989),

comprehensiveness and increase frequencies. 2.1.5.3 (3.5.3) 2.L5.6 (3.5.4)

The (NAD) conducts surveillance of ISI, Appendix J, and Technical Specifications and regulatory r requirements as part of the assessment process on a routine basis in conjunction with maintenance assessments.

111-2 Establish program for QA to Task was met per Inspection Report monitor plant's implementation 50-325/324/89 20, dated September 22, of technical specification 1989. This item will be assessed in revision and regulatory conjunction with NAD's routine requirements, performance based assessment of plant activities.

111-3 Require QA to perform 100 This item is covered by LAP Item percent review of technical D.1.d. Over 7200 technical specification requirements every specification requirements have been three years, reviewed with only 10 problenis noted since the program began. This program will be terminated because of this low frequen,y of problem identification. This item will be assessed incidental to NAD's routine performance-based assessments of plant activities.

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lilP ITEM & LATUS

SUMMARY

ltem Action Comment 111-4 listablish program for periodie Item 1114 is addressed by the following review of items 111.1,2, and 3 by D13T Paragraphs / Findings (source -

Corporate Auditing. Inspection Report 50-325/324/89 20, dated September 22,1989).

2.1.4.1 (3.4.1.1) 2.1.4.2 (3.4.1.2) .

s 2.1.4.3 (3.4.1.2) 2.1.5.6 (3.5.4) 1115 Modify Corporate OA Program Task complete per NRC letter dated Part 1 to include an escalation April 3,1984.

mechanism.

1115 Modify Corporate OA Program Task complete per NRC letter dated Part 2 to include three levels of April 3,1984.

nonconformance.

IV 1 Continue the post maintenance item IV 1 is addresseIl by the following testing program established as DIIT Paragraph / Finding (saurce -

part of the prestart up action list inspection Report 50 325/324/89 20, (continue to evaluate), dated September 22,1989).

2.1.4.10 (3.4.3.2)

V-1 Upgrade program for the  !!cm V 1 is addressed by the following training of appropriate personnel DliT Paragraph / Finding (source -

in the post modification aspects ine,pection Report 50 325/324/F9 20, of plant systems and dated September 22, 1989).

components.

2.1.2.14 (3.2.6.6) - Positive Finding V-2 Develop and incorporate a film item V 2 is addressed by the following into the General Employee DliT Paragraph / Finding (source -

Training Program to cover the inspection Report 50-325/324/89-20, Discipline of Operations, dated September 22,1989).

procedural compliance and the philosophy of conservatism with 2.1.2.6 (3.2.3) respect to regulatory compliance.

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i lilP ITEM STATUS SUMMAlW llem Action Comment V3 Develop a training film on Task complete per NitC ietter dated quality performance and April 3,1984.

incorporate into General ,

I Employee Training.

V4 1(epeat the previously given Task complete per NltC letter dated corporate position on Discipline April 3,1984.

of Operations, procedural i l

compliance, and regulatory philosophy on an annual basis, ,

including testing as part of the l rebadging process.-

V-5 Upgrade the program for item V 5 is addressed by the following providing training in industry- DET Paragraphs / Findings (source -

wide events, incidents, and Inspection Iteport 50-325/324/89 20, operating experience reports, dated September 22,1989).

l 2.1.2.14 (3.2.6.6) - Positive Findmg i i

V6 Train selected unit managers Task complete per NilC letter dated i and supervisors in llSEP April 3,1984.

specifics:

I A. Three weeks of l- classroom training on systems operations and design.

l- H. One week of plant and equipment orientation.

C. One week of BWil Simulator Training.

V-7 Establish a formalized system to See item V-1. Inspection lleport 50-ensure that timely training is 325/324/89 20, dated September 22, i provided appropriate personnel 1989, Section 10 page 18 concluded l regarding new procedures and that this objective continues to be met.

l procedural revisions.

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lilP ITE51 STATUS SUhlalAltY ltem Action Comment l VI l lleassign some of the Item VI 1 is addressed by the following

independent review function DET Paragraphs / Findings (source -

responsibilities off site to inspection lleport 50-325/324/89 20, provide increased opportunity dated September 22,1989).

for direct plant observation.

2.1.5.5 (3.5.5)

VI 2 Initiate a program of periodic Task complete per NitC letter dated review of safety system April 3,1984. Also see inspection challenges and reactor lleport 50-325/324/89 20, dated transients. September 22,1989, Section 10 page 19.

l VI 3 Increase emphasis on direct Task complete per NitC letter dated surveillance and walk through April 3,1984.

activities - to include frequent review of operations' logs, direct This IllP ltem continues to be met per observation of individual actions, inspection lleport 50-325/324/89 20, advanced identification of Section 10, page 20, dated l

activities to be reviewed, and September 22,1989, written reports which summarize 4 activities and results as well as noted deficiencies and recommendations.

VI-4 Increase effort on special item VI-4 is addressed by the following investigative activities - to DET Paragraph / Finding (source -

include prompt review of Inspection lleport 50-325/324/89-20, incident and human factors dated September 22, 1989).

summary reports with follow-up evaluations as needed. It will 2.1.5.5 (3.5.5 and 3..:.1.2) also include increased sensitivity i

to the conduct of special investigations as established by CNS or operations ,vith follow-up reports and recommendations.

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lilP ITij,M STNI'US SUMMAlW ltem Action Comment VI 5 liold quarterly nuclear safety item VI 5 is addressed in inspection review meetings to discuss 1(eport 50 325/324/89-20, dated selected issues arising from the September 22,1989, Section 10, page routine independent review 20. CP&l intends to discontinue these program and the ISliG program. meetings ur'on discontinnance of Selected managers from other Confirmatory Order I?A 82106.

CP&L organizations and outside consultants will be invited.

Vil l' Management Analysis Company item Vil 1 is addressed by the has been retained to perform following 1) lit Paragraphs / Findings review of Corporate OA (source Inspection lleport 50-Program. 325/324/89 20, dated September 22, 1989).

2.1.1.1 (3.1.1 and 3.1.2) 2.1.1.3 (3.1.3) 2.1.1.4 (3.1.1 and 3.1.2) 2.1.1.5(31.3) 2.1.1.7 (3.1.4) 2.1.1.9 (3.1.6) 2.1.5.2 (3.5.2) 2.1.6.12.a, b (3.6.2.2. I and 3.6.1.1.2) 2.2 Vll 2 Initiate study to reduce outside Task complete per NI(C letter dated demands on plant st'iff to allow April 3,1984.

more attention to operations and maintenance. This IllP ltem continues to be m,;t per ,

inspection lleport 50 325/324/89-20, Section 10, page 21, dated September 22,1989.

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e lilP ITEM STATUS

SUMMARY

llem Acilon Coniment Vil 3 Commence INPO assessment of Inspection Report 50 325/324/89 20, operational activities, CNS, Section 10, page 21 dated September corporate / plant interface, and 22,1989, concluded that cert sin issues PNSC activities. raised by IF#O still exist as problems at ilNP, lhmver, the root causes of the issues are reficcted in the findings of tl+c DET, Therefore, no further j followup or action on this lilP item is j rcquired by the NRC. i Vil 4 Develop implementation Task complete per NRC letter dated schedule for appropriate April 3,1984.

recommendation of the shift foreman time utilization study. ._

Vil 5 Develop implementation Task complete per NRC ler r dated schedule for appropriate April 3,1984.

recommendations of the Essex Corporation lluman Factors No further followup or action on this Study, lilP item is required by the NRC per inspection Report 50 325/324/89 20, Section 10, page 21, dated September 22,1989.

Vil 6 Prepare a

• Conduct of Task complete per NRC letter dated

'l Operations" Manual to promote April 3,1984.

consistency among operating nuclear plants. ,

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e ENCLOSURE 2 13RUNSWICK STEAh! El.ECTRIC PLANT, UNITS 1 AND 2 NRC DOCKETS 50-325 & 50 324 OPERATJNG LICENSES DPR 71 & DPR 6J REQUEST FOR LICENS" / h1ENDhiENT TERhilNNilON OF HRUNSWICK IMI ROVEh1ENT PROGRAh!

.11LCFR 50.92 EVoj.UATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operatien of the facility in -

accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a acw or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Carolina Power & Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards consideration. The bases for this.

determination are as follows:

Proposed Changg On December 22,1982, the NRC issued Confirmatory Order EA 82106 which required implementation of the ikunswick Iml irovement Program (BlP). The actions recommended in the BIP have been implemented and the intent of the program fulfilled.

As such, the Company has met the intent of Confirmatory Order EA 82106. Since 10 CFR 50.54(h) requires that the operating license be subject to all Orders of the Commission, the Company is requesting a license amendment to terminate the requirements of Confirmatory Order EA-82-106.

JhEb The change does not involve a significant hazards consideration for the following reasons:

1, The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated. There are no physical changes to any safety-related equipment, no changes in any Technical

. Specification surveillance requirements or setpoints, and no changes to the manner in which the plant is operated as a recult of the proposed amendment.

The license amendraent terminates the requirements of Confirmatory Order EA-

'82-106, which formalized CP&L's commitment to the Brunswick Improvement E2-1

_. . .x

4 Program (BlP). In accordance with its original schedule, the program was essentially completed as of December 31,1983, in a letter dated April 3,1984, the NRC notified the Company that they had determined that CP&L had met the requirements imposed by confirmatory Order HA-82-106.

Carolina Power and Light Company has mechanisms in place, outside of Confirmatory Order BA 82-106, to facilitate the safe operation of the Brunswick .

Plant. These mechanisms include long term practices established by the IBP and I the recently developed Integrated Action Plan (IAP). The IAP was developed by j Brunswick Plant and Corporate management to ensure that the findings and  !

recommendations from Cresap's Nuclear Operational and Management j Effectiveness Assessments and the NRC's Diagnostle Evaluation Team (DET) 1 Report (dated August 2,1989) were considered; that an appropriate response was 1 made to NRC findings; and that progress on the recommendations could be i tracked. The IAP synthesized the recommendations of the studies and outlined I the steps . required to implement them.

NRC Inspection Report 89-20, dated September 22,1989, documents the results of an inspection to determine if the long term BIP ltems, intended to assure continued improvement, were in place. This report also correlates BIP ltems with DET Findings. For each of the long term BIP ltems, the inspector found that  ;

either the objective of the BIP ltem continued to be met or that DFT Findings addressed the issue. Each of the DET Findings have been addressed by CP&L in

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the IAP, Since the long term BIP Items are being met or are addressed by the

. LAP, maintaining Confirmatory Order EA 82-106 is no loeger necessary.

IM4 on this reasoning, the proposed amendment cannot involve a significant

+ , e in the probability or consequences of an accident previously evaluated.

2. n proposed amendment does not create the possibility of a new or different W ., of accident from any accident previously evaluated. As stated above, the proposed amendment does not involve any changes to safety-related equipment, Technical Specification surveillance requirements or setpoints, or the manner in which the plant is operated, Therefore, the proposed amendment cannot create the possibility of a new or different kind of accident.

E 3. The proposed amendment does not involve a significant reduction in the margin of safety. While cach of the specific BIP actions was appropriate at the time of implementation, some of these actions are either no longer necessary or the objectives can be achieved in a more efficient manner. As described in CP&L's letter dated October 26,1987 (NLS 87188), the Company committed to perform periodic review in five areas: Technical Specification Surveillance; In Service Inspection / Appendix J; Commitment Verification; Technical Specification E2-2 3

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Amendments; and Regulatory llequirements Changs. Ilased on the results of these periodic reviews, enhancements to management 1,rograms, and ongoing improvements in procedural controls, CP&L believes that ermination of Confirmatory Order EA 82106 would facilitate evolving management and process improvements.

NRC Inspection lleport 89 20, dated September 22,1989, documents the results of an inspection to det7mine if the long term IllP ltems, intended to assure continued improvement, were in place. This report also correlates IllP ltems with DET Findings. - For each of the long term lilP ltems, the inspector found that either objective d the IllP ltem continued to be met or that DET Findings addressed the issue. Each of the DET Findings have been addressed by CP&L in ,

the IAP. Since the long term IllP ltems are being met or are addressed by the IAP, maintaining Confirmatory Order EA 82106 is no longer necessary, ,

Therefore, based on thn above reasoning, the proposed amendment does not involve a significant reduction in the margin of safety. l 9

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