ML20132E629

Forwards NOV Re Insp 50-324/96-16 & 50-325/96-16 Completed on 961026.Predecisional Enforcement Conference Held on 961209 to Discuss Violations

ML20132E629
Person / Time
Site:	Brunswick
Issue date:	12/13/1996
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Campbell W CAROLINA POWER & LIGHT CO.
Shared Package
ML20132E632	List: ML20132E629 ML20132E646
References
EA-96-442, NUDOCS 9612230353
Download: ML20132E629 (6)

See also: IR 05000324/1996016

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December 13, 1996

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-EA 96 442

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Carolina Power & Light Company  ;

l ATTN: Mr. W. R. Campbell  !

Vice President

Brunswick Steam Electric Plant

i Post Office Box 10429

j Southport, North Carolina 28461

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SUBJECT: NOTICE OF VIOLATION

l (NRC INSPECTION REPORT NOS. 50 325/96 16 AND 50 324/96 16)

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! Dear Mr. Campbell:

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This refers to the integrated inspection completed on October 26,19% at your-

Brunswick facility. The inspection included a review of your failure to

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provide temperature compensation for the Plant Process Computer (PPC)

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feedwater flow algorithm which resulted in operation of Brunswick Unit 2 in - ,

excess of (1) the maximum thermal aower authorized by the license and l

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(2) thermal limits required by Tec1nical Specification (TS) 3.2.1. The

inspection report was sent to you by letter dated November 22, 1996. -A

closed, predecisional enforcement conference was conducted in the Region II

office on December 9,1996, with you and members of your staff to discuss the

apparent violations, the root causes, and your corrective actions to preclude .

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recurrence. A list of conference attendees NRC slides, and a copy of your.

presentation materials are enclosed.

Based on the information developed during the inspection and the information

you provided during the conference. the NRC has determined that violations of

NRC requirements occurred. The violations are cited in the enclosed Notice of

Violation (Notice) and the circumstances surrounding them are described in

detail in the subject inspection report. Violation A involves the failure to i

maintain the Unit 2 thermal power within the operating license limits. On  !

August 28, 1996, a reactor engineer reviewing core thermal power calculations

associated with the Power Uprate Project determined that the Unit 2 PPC point 4

value for feedwater flow was not properly compensated for feedwater l

temperature deviations from the normal operating temperature. The condition l

had existed on Unit 2 since the unit restarted after a refueling outage ending '

in July 1994 when Unit 2 was modified to add a new PPC and associated

software. Due to the failure to temperature compensate the feedwater flow-

process point value, the core thermal power calculated and indicated by the

PPC was less than the actual core thermal power. During periods when

feedwater temperature was lower than the normal operating value, Unit 2 was

operated at indicated power levels of up to 100 percent power or 2436

megawatts (MW) thermal which was equivalent to actual power levels of up to i

102.4 percent power or 2494 MW thermal. This is a violation of License l

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Condition 2.C.1 of Facility Operating License Number DPR 62 which requires

that Unit 2 be operated at or less than 2436 MW thermal.

I~'3nnn

9612230353 961213

PDR ADOCK 05000324 ]

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CP&L 2

Violation B involves the failure to maintain the calculated Average Planar

Linear Heat Generation Rate (APLHGR) within the limits of TS 3.2.1. The

APLHGR limits vary based on power level and feedwater flow to assure that the

fuel thermal-mechanical design criteria are preserved during abnormal

transients. TS 3.2.1 specifies the approved methodology for determining the

limits placed on ALPHGR for a given power level and feedwater flw rate. Due

to the failure to appropriately compensate for feedwater temperature, the

calculated reactor aower level inputs to the APLHGR calculation were incorrect

and the resulting A)LHGR value was non conservative. The APLHGR values, as i

calculated using the actual power levels, exceeded the limits specified by l

TS 3.2.1 between December 10 and December 20, 1995. During the predecisional

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enforcement conference, your staff noted that the approved methodology for

calculating the APLHGR limits specified by TS 3.2.1 was based on generic

APLHGR adjustment factors. Your re analysis of the APLHGR limits using cycle

specific adjustment factors indicated that the APLHGR values, based on actual '

power levels between December 10 and December 20, 1995, were within cycle

specific design limits. Although the re analysis indicates that the actual

safety consequence of Violation B was low; the NRC considers any change in i

reactor parameters that cause unanticipated reductions in the margin of safety

to be a significant regulatory concern.

The root causes of the violations included the failure of your design team to

properly link the Unit 2 feedwater flow process points to the appropriate

compensation formula in the Unit 2 compensation database. The com) uter index

labels for the Unit 2 feedwater flow process points were changed w1en

additional process points were loaded into the database. Due to the

inappropriate index labels, the computer linked a compensation value of one to

the points instead of the correct compensation value. Your post modification i

acceptance testing for the new PPC did not verify that process point numbering

was the same in both units and did not verify that the correct relationships

between process points and compensation values were preserved when your design l

team, in an effort to reduce differences between the two units, copied the i

existing PPC database configuration from the Unit 1 PPC to the Unit 2 PPC.

These violations represent a significant failure to control design parameters

that affected the integrity of reactor core protection systems. The NRC

expects licensees to provide meticulous oversight of vendor changes to plant '

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process computer software and to conduct comprehensive post-modification

testing of new software used to assure operation within specified acce) table

fuel design limits. In this case, the NRC is particularly concerned t1at

specified core operating limits were exceeded due to the inadequate design

control and testing. Therefore, these violations are classified in the

aggregate in accordance with the " General Statement of Policy and Procedures

for NRC Enforcement Actions" (Enforcement Policy) NUREG 1600, as a Severity

Level III problem.

In accordance with the Enforcement Policy, a base civil penalty in the amount

of $50,000 is considered for a Severity Level III problem. Because your

facility has been the subject of escalated enforcement actions within the last

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CP&L 3

two years , the NRC considered whether credit was warranted for

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Jdentification and Corrective Action in accordance with the civil analty i

assessment process described in Section VI.B.2 of the Enforcement )olicy. The

NRC concluded that credit was warranted for Identification because your staff

identified both violations. With regard to consideration for Corrective

Action, your corrective actions included: (1) effective, immediate corrective

actions to reduce power and correct the software deficiency; (2) revalidation

of critical plant process computer functions and confirmation of appropriate

testing of the software: (3) review of other computer applications:

(4) enhancements to the control of design and testing of computer products;

and, (5) training on lessons learned and software configuration control.

Based on the above, the NRC determined that credit was warranted for

Corrective Action.

The application of the factors considered in the civil penalty assessment

process, absent the exercise of discretion, resulted in no civil penalty.

However, you should be aware that the NRC considered imposing a civil penalty,

under Section VII.A of the Enforcement Policy, because of the potential impact

of weak vendor oversight and inadequate design control and testing of software

affecting core operating parameters. However, because your reactor engineer

demonstrated a safety conscious attitude which resulted in the identification

of the software deficiency and to encourage prompt identification and

comprehensive correction of violations, I have been authorized, after

consultation with the Office of Enforcement, not to propose a civil penalty in

this case. Significant violations in this area in the future could result in

a civil penalty.

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response. In your

response, you should document the specific acticas taken and any additional

actions you plan to prevent recurrence. After reviewing your response to this

Notice, including your proposed corrective actions and the results of future

inspections, the NRC will determine whether NRC enforcement action is

necessary to ensure compliance with NRC regulatory requirements.

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A severity Level III violation was issued on November 19.1996. (EA 96 354) related to

environmental qualification program deficiencies. A severity Level III violation was issued on

July 12.1996. (EA % 181) related to design control measures for service water system

modifications. A severity Level III violation was issued on April 4.1996, (EA 96-054) for

failure to meet fitness for duty requirements. A severity Level III violation was issued on

November 20.1995. (EA 95 228) related to suitability of materials used in valves in the residual

heat removal system. A severity Level III problem was issued on september 8.1995. (EA 95166)

related to design control. modification and testing of the high pressure injection system and

reactor core isolation cooling system.

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

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this letter, its enclosures, and your response will be placed in the NRC

Public Document Room (PDR).

Sincerely,

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Original Signed by

Luis Reyes for

Stewart D. Ebneter

Regional Administrator

Docket Nos. 50 324

License Nos. DPR 62

Enclosures: 1. Notice of Violation

2. List of Conference Attendees

(Not to be Published in NUREG 0940)

3. Licensee Presentation Material

(Not to be Publi.ched in NUREG 0940)

4. NRC Slides (Not to be Published in NUREG 0940)

cc w/ encl:

W. Levis Director

Site Operations

Brunswick Steam Electric Plant

P. O. Box 10429

Southport, NC 28461

R. P. Lopriore  !

Plant Manager

Brunswick Steam Electric Plant

Carc, lina Power & Light Company

P. O. Box 10429

Southport, NC 28461

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J. Cowan Vice President

Operations & Environmental

Support MS OHS 7

Carolina Power & Light Company

P. O. Box 1551

Raleigh, NC 27602

Gerald D. Hicks

Manager Regulatory Affairs

Carolina Power & Light Company

P. O. Box 10429

Southport, NC 28461

cc w/encls cont'd: (see next page)

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cc w/encls cont'd:

W. D. Johnson, Vice President Public Service Commission

and Senior Counsel State of South Carolina

Carolina Power & Light Company P. O. Box 11649

P. O. Box 1551 Columbia, SC 29211

Raleigh, NC 27602

Jerry W. Jones, Chairman

Dayne H. Brown. Director Brunswick County Board of

Division of Radiation Protection Commissioners

artment of Environmental P. O. Box 249

N.Health

C. Dep& Natural Resources Bolvia NC 28422

P. O. Box 27687

Raleigh, NC 27611 7687 Dan E. Summers

Emergency Management Coordinator

Karen E. Long New Hanover County Department of

Assistant Attorney General Emergency Management

State of North Carolina P. O. Box 1525

P. O. Box 629 Wilmington, NC 28402

Raleigh, NC 27602

William H. Crowe, Mayor

Robert P. Gruber City of Southport

Executive Director 201 East Moore Street

Public Staff - NCUC Southport, NC 28461

P. O. Box 29520

Raleigh, NC 27626 0520

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Distribution w/encls: ,

PUBLIC

JTaylor, EDO

JHilhoan, DEDR -

RZimmerman, NRR -

SEbneter, RII

LChandler, OGC

JGoldberg, 0GC

JLieberman, OE

Enforcement Coordinators

RI, RIII, RIV

EHayden, OPA  !

EJordan, AE0D  :

EJulian, SECY

BKeeling, CA

PRabideau, OC ]

DDandois, OC ,

GCaputo 01 I

HBell, 0IG 1

OE:EA File (B. Summers, OE) '

(e mail plus 2 letterhead)

MSatorius, OE

AGibson, RII

JJohnson, RII 1

CEvans, RII i

Buryc, RII  ;

KClark, RII

RTrojanowski,RII l

CCasto RII l

MShymlock RII (IFS entry required) l

DTrimble, NRR '

MMiller, RII

RAiello, RII

GHallstrom, RII

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NRC Resident Inspector

U.S. Nuclear Regulatory Commission 4

8470 River Road, SE  !

Southport, NC 28461 i

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