ML20091C217
| ML20091C217 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/30/1992 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-91-045, EA-91-158, EA-91-45, NLS-92-098, NLS-92-98, NUDOCS 9204030125 | |
| Download: ML20091C217 (6) | |
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l CP&L i
Carolina Power & Ught Company i
P, O. Boa 11,51
- Ramgh, N C 27602 SERIAL; NLS 92 098 MAR 301992 R,A.WATsoy Sonstw vwe Prescent N o w o n.,.non United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washingtrn, DC 20555 t3RUNSWICK STEAM ELECTRIC PLANT, UNIT NOS 1 AND 2 DOCKET NOS. 50 325 & 50 324/ LICENSE NOS. DPR 71 & DPR 02 SUPPLEMENTAL REPLY TO NOTICE OF VIOLATION (EA 91 158) r entlemen:
On January 3,1992, the Nuclear Regulatory Commission issued a Notice of Violation (EA 91 158) for issues at the Brunswick Steam Electric Plant, Units 1 and 2. Details of the NRC inspections are provided in inspection Report Nos. 50 325/9126 and 50 324/9126 dated November 22,1991.
By letter dated February 14,1992 (Serial: NLS 92 031), Carolina Pov er & Light Company responded to the Notice of Wolation.
Subsequently, by letter dated February 27,1992, the Nuclear Regulatory Commission acknowledged receipt of the Company's response. The letter further stated that the February 14, 199'! response was considered incomplete in that it f ailed to identify and fully discuss the reasons why the corrective actiora for the violations discussed in earlier enforcement action EA 91045 did not effectively prov the occurrences covered in the subsequent violation. The enclosure to this letter provides CP&L's supplemental reply to the Notice of Violation.
Please refer any questions regarding this submittal to Mr. M. R. Oates at (9191540 6901.
Yours very truly, hfb 7V R. A. Waten WRM/wrm (Wplea91158s.wpf)
Enclosure cc:
Mr. S. D. Ebneter Mr. N. B. Le Mr. R. L. Prevatte G30028
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Document Control Desk NLS 92 098 / PaDe 2 R, A. Watson, having 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, ernployees, contractors, and agents of Carolina Power & Llyht
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ENCLOSURE l
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50 325 & 50-324 OPERATING LICENSE NOS DPR 71 & DPR 62 SUPPLEMENTAL REPLY TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY V10LATIOt1J:
10 UR Part 50, Appendix J, Criterion XVI, Corrective Actions, requires in part, that rnessures be
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established to assure that conditions adverse to cuality, such as failures, malfunctions, l
deficiencies, deviations, defective raaterial and equipment, and nonconformances are promptly identified and corrected.
a Conttery to the above, effective measures wer6 not esta ilished to promptly identify and correct deficiencies that resulted in the continuing breakoawn of s.ianagement control nyer work control activities similar to those previously identified in NRC enforcement action (EA) 91045 which was issued on May 31,1991, as evidenced by the examples cited within the Notice or Violation and Proposed imposition of Civil Penalty.
i SUPPLEMENTAL RESPON$E TO VIOLATION 1:
L The corrective actions for the violation discussed in earlier NRC enforcement action EA 91045 may not have been completely elfective in preventing the occurrent.es in enforcement action EA 91158 for two primary reasons: (1) the correction of some of the noted deficiencies is en iterative and lengthy process that requires time and chant,ing human ew avuc, casi (2) some of the corrective actions had not been completed at the time of the occurrences identified in EA 01 158.
The following corrective actions were completed at the time of the occurrences ic3ntified in NRC
- nforcement action EA 91 158
l Please Listen Training Completed August 1,1991 o
BSP 50, Site Command Control and Communications Manualissued on April 8,1991 These corrective actions helped employees focus upon their work and emphasized self checking, communications and the importance of following procedures.
The corrective actions listed below were still forthcoming at the t!me of the occurrences identiflad in NRC enforcement action EA 91 158. The actual or projected completion schedule and projected benefits are also noted.
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= o Efforts to increase supervisory presence in the field were initiated in April of 1991.
As indicated by the events delineated in EA 01 150, this effort has not provided all of the desired results. Ongoing enhancements to the Site Work Force Control Group (SWFCG) process sre expected to afleviate some Maintenance supervisory admin;strative burden aruf allow increased in field supervision. Site Work Force Control Group procese refinements are expected to be implemented by September 30,1992, o
Although not requested per se in this supplemental response, please be advised that beginning in April 1992, key unit managers are being assigned an assistant on an -
interim basis to analyre their respective work processes, develop improvements in those processes and be a part of implementing enhancements there to. Improved work processes are expectd in ecduce thw probability of work control deficiencies and ultimately to reduce administrative burdens in each work group and consequently provide supervision additional time for in field oversight of work aClivitles, o
Periodic meetings have been established between the Vice President. Brunswick Nuclear Project and supervision on expectations, performance standards and employee coaching. This is an on going effort and will continue as long as management considers it necessary, o
Substantially increased Ouality Control and Nuclear Assessment Department surveillances of work activities were initlated in April 1991 as an interim measure designed to tupplement supervisory presence in the field until the above actions have progre r.W to the degree required to maintain the appropriate level of supervisory cv.
- sight.
While the actione described above have not been fully effective in preventing c rtair, recurrences of work control lskues, they have produced trends in performance in a number of areas that indicate early signs of success. Examples of improved trends are fewer personnel error Licensee Event Reports, fewer parsonnel error Adverse Condition Reports, lower radiation exposure, fewer contamination events and a decrease in the number of unsuccessful Emergency Safety Feature actuations.
The Company recognizes the difficulty of changing human performance in the short term and does not view the above improvement trends as evident e that our endeavors in this area are complete.
Internal and external assessments have been performod, and will continue to be purformed, to determine the effectiveness of corrective actions. Ne*v improvement initiatives and refinements to existing initiatives arising from these assessments include; o
Direct on site support from the Employee Relations Department, including a full time Organizational Development Specialist and a part time (currently 40 percent)
Resources Professional, is being provided to focus attention on personnel planning and development. The Organizational Development Speciallst is expected to E12 9
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support this effort up to May 1993 and the Resource Professionalis a permanent assignment, A corporate approach to Effective Performance Management (EPM) was initiated in o
1989 to iccus on priority tasks, communication, evaluation, and reward. A project team was initiated in 1990. Pilot training programs were conducted in October and November of 1990. Effective Performance Management training started in 1991.
Exempt and 60 percent of non exempt company personnel have completed this training. The remainder of non exempt personnel are expected to complete this training by end of the third Quarter 1992, o
First lias supervisor assessmant contors are being utilfred to assist in selection of future supbrvisors becaus) of a recognized need throughout the Nuclear Generation Group. The centers evaluate an individual's aprheation of supervisory skills via scenarlos. Assessment of twelve prospective superviso a has been completed sinco November 1991. Additional assessments are ongoing, c
A Supervisory Development Project was initiated in December 1990. Ninety one supervisors were surveyed in April 1991. The results of these surveys were reviewed in August 1991 and incorporated within the supervisory development training course curriculum. Course development was completed in February 1992.
A pilot five week course targeting first line supervisors with a focus on teamwork and twenty-seven attributes of leadership will commence in May and August of 1992. This courne is available to personnel within the Nuclear Generetion Group and twenty Brunswick Plant rersonnel will be among the first to be tralned, with approximate y ten frnm Brunswick attending each claan of twenty five scheduled to be conducted in 1992. Pilot course assessment will follow to support curriculum enhancement. This program is intended to be ongoing trainin9, o
A Technical Training Center to provide M.,intenaace and Environment & fladiauon Control hands on training was conceptualized in May 1991 and opened in March 1992. The facility includes four labs, a hands on/mo :k up facility, and classrooms to support realistic simulation of work activities, o
Project Management Training, a one week course focusing on skills such as scheduling, people selection, brainsterming, etc., was initiated approximately five years ago. Two courses providing training to forty four personnel were held l
in 1989, three courses providing training to sixty five personnel were held in 1991, and two courses providing training to forty seven personnel were held in 1992 with two additional courses planned for 1992, o
Management Advanced Systems Training, a thirteen week course targeted for managers and senior staff, was initiated in March 1992 The second class will bo i._
held in the fall of 1992. This is ongoing training that is being initiated with two or three clastes per year.
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Nuclear Generation Group Education and Training Project was initiated in 1991 to enhance training and development in the Nuclear Generation Group. Phase One, which included visits to other plants and interviews of line and training staff personnel from the three nuclear sites, is complete. Phase Two, which was initiated in December 1991 will pruWde recommendations and Im.6 mentation plans for actions o enhance Nuclear Generation Group employee training and development. Phase Two recommended actions will be presented to the Education and Training Steering Committee by the end of May 1992, in summary, while it is not possible to completely eradicate occurrences due to human behavior, CP&L oelieves continued efforts in this crea will result in a decrease in the frequency and significance of work controlissues.
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