ML20211M349

Informs Commission of Present Status of Staff Review of Activities of Licensee in Preparation for Restart of Plant, Units 1 & 2

ML20211M349
Person / Time
Site:	Brunswick
Issue date:	04/08/1993
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Curtiss, De Planque, Remick, Rogers K, Selin I, The Chairman NRC COMMISSION (OCM)
Shared Package
ML20211M323	List: ML20211M318 ML20211M349
References
FOIA-97-252 NUDOCS 9710140149
Download: ML20211M349 (19)

Text

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b MEMORANDUM FOR: The Chairman i Commissioner Rogers #

Commissioner Curtiss <

Commissioner Remick Commissioner de Planque FROM: James M. Taylor Executive Director for Operations

SUBJECT:

STATUS OF REA31 NESS FOR RESTART, BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 This memorandum is to inform the Commission of the present status of the NRC staff's review of the activities of Carolina Power & Light Company (the licensee) in preparation for the restart of the Brunswick Steam Electric Plant, Units 1 and 2 (BSEP). Because of a confirmatory action letter (CAL) dated December 18, 1992, the licensee must obtain the concurrence of the Administrator, Region II, before beginning the actual activities to return the plant to power operation. The licensee's schedule is based on a projected restart date of April 26, 1993, for Unit 2 and September 1993 for Unit 1.

The licensee voluntarily shut down both BSEP units on April 21, 1992, because the four emergency diesel generators (EDGs) were inoperable. The EDGs had been declared inoperable because of a concern about the capability of the LN. interior reinforced masonry walls separating the bays in the EDG building to bM withstand a seismic event. Although the licensee had previously identified the deficiency, the lack of an adequate corrective action program caused the O_ full extent of the problem to remain unrecognized until questions were raised

( during an NRC inspection. Subsequently, a more detailed investigation revealed that the lateral support of the masonry walls, via plates and angle braces, was ineffective. This problem was the result of numerous anchor bolts n securing the braces to the walls not having been properly installed during oriy ~_ J construction in the early 1970s. The construction personnel had tack welded the heads of these nonconforming anchor bolts to the braces without the bolt being driven into the masonry walls.

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Contact:

P. D. Milano, NRR/PD2-1 504-1457 \

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2-Following the shutdown of the BSEP units, both the NRC staff and the licensee '

identified additional civil and structural concerns that had to be resolved. *.i These included such items as (1) the failure to identify all safety-related j

masonry walls (2) numerous deficiencies in miscellaneous structural steel (, v platforms and supports to safety-related equipment, and (3) significant J7f corrosion of instrument racks and service rater system supports. Furthermore,A (

1. .. vf the licensee undertook a rigorous material condition walkdown of the critical areas of both units during which additional deficient conditions were "

identified. The deficiencies the licensee determined could affect the operability of safety related equipment have been appropriately corrected.

On the basis of its evaluation of the extent of the material deficiencies, the licensee identified corrective maintenance activities that would be completed before the startup of either unit. The licensee also committed to significant corporate and BSEP improvement efforts to resolve these deficiencies and to raise the level of overall performance of its nuclear facilities. These efforts are described in its Corporate improvement Initiatives and Brunswick Three-Year Plan submitted on December 15, 1992. In the December 18, 1992, CAL, the Administrator, Region II, affirmed the licensee's commitment to complete these corrective actions in accordance with the schedule developed and to request his concurrence before restarting either unit.

The NRC staff has conducted a significant number of inspections and t assessments to verify the resolution of the material conditions, s well as 1--9 M f the correction of the root causes that led to these conditions. Since the %I os licensee's efforts will continue past the unit restart in some areas, the staff will conduct inspection activities to monitor these long term Mg gem improvements in operation. Enclosure 1 gives the details of the status of the licensee's completion of the actions specified in the CAL and the PRC staff's e inspection and assessment efforts in these areas, # 3 a of  !

Ga "O NRCmanagementhasnotedanddiscussedtheobserveddeclineinperfor BSEP during all but one Senior Management Meeting since June 1988, although ag i

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BSEP was not placed on the NRC list of facilities requiring added management attention until June 1992. The basic issues identified by the staff were

,+f) M repetitive work control failures, personnel errors, and ineffective manage.aent oversight. Further. contributing factors included the material condition of et #y g the plant, lack of attention to detail, and a weak self-assessment program, f 9, t

The licensee developed an integrated startup plan and schedule to describe the various programs, processes, and assessment activities that will be needed to ensure that the unit will be ready for restart. To ensure operational readiness, the licensee also prepared a set of specific criteria for system engineering, operations, and management to assess each system before turning it over to plant operations, in concert with the startup plan, the NRC staff also pro ared a restart action plan to capture those NRC inspection, review, aM verification activities that needed to be completed. The NRC staff is conducting an operational readiness assessment team inspection as a final step

/ in determining the overall readiness of the licensee's equipment and

/ personnel. The licensee will be required to respond to any findings from this f inspection before the staff makes a decision regarding restart. Additionally, the NRC staff has concurred in the licensee's startup accession profile and Q (gQ { , , ' e . &$OW ' k Ji ds ova.

3 selection of specific assessment hold points. The staff will provide augmented inspection coverage to monitor the startup and return to power operation.

Although many of the programs and process improvements have benefited both units, the licensee has concentrated its efforts on the restart of Unit 2 before Unit 1. This decision was based on this unit's remaining core life.

Th'e licensee wH4-beg?n the Unit I refueling outage on April 745,1993, rather than continue its earlier efforts to restart in June 1993. The Unit I restart, thus, is now estimated to occur in September 1993.

The licensee will inform the NRC staff when the final restart issues for Unit 2 are complete and the unit is ready for restart. The staff will review this information to ensure that the resolution of any possible open issues has progressed to such a point that safe operation of the plant can be ensured.

Once the Administrator, Region II, is fully satisfied with the licensee's actions, he will concur in the licensee's restart decision. As stated above, the licensee is progressing toward a restart scheduled for April 26, 1993. I will inform the Commission if there are any significant changes in the activities or schedules for the Brunswick facility.

James M. Taylor g Executive Director for Operations p

rn c Readin cc w/ enclosure:

SECY OGC OCA OPA

3-selection of specific assessment hold points. The staff will provide augmented inspection coverage to monitor the startup and return to power operation.

Although many of the programs and process improvements have benefited both

, , units, the licensee has concentrated its efforts on the restart of Unit 2 before Unit 1. This decision was based on this unit's remaining core life.

The licensee will begin the Unit I refueling outage on April 15, 1993, rather than continue its earlier efforts to restart in June 1993. The Unit 1 restart, thus, is now estimated to occur in September 1993.

The licensee will inform the NRC staff when the final restart issues for Unit

' 2 are complete and the unit is ready for restart. The staff will review this information to ensure that the resolution of any possible open issues has i

progressed to such a point that safe operation of the plant can be ensured.

Once the Administrator, Region II, is fully satisfied with the licensee's actions, he will concur in the licensee's restart decision. As stated above, i

the licensee is progressing toward a restart scheduled for April 26, 1993. I will inform the Commission if there are any significant changes in the

, activities or schedules for the Brunswick facility.

~ James M. Taylor Executive Director for Operations Brunswick Readiness for Restart cc w/ enclosure:

SECY OGC OCA OPA OrnCE LA:PD2-1 PM:PD2-1 TechEd j (A)D:PD2-1 AD:DRPE D:DRPE NAME PAnderson PMilano JMitchell MMejak* Glainas SVarga DATE 04/ /93 04/ /93 04/ /93 04/05/93 04/ /93 04/ /93 OFFICE D:DET D:DRSS ADT ADP RA:Rll D:NRR 4 NME JRichardson FCongel WRussell JPartlow SEbneter TMurley 4

DATE 04/ /93 04/ /93 04/ /93 04/ /93 04/ /93 04/ /93 0FFICE EDO NAME JTaylor DATE 04/ /93 See previous concurrence

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=-DISTRIBUTION:

Central File PD-2-1 Reading File EDO Reading File J.-Taylor.

T. Murley/F, Miraglia

, J._Partlow-W. Russell S. Varga J. Richardson F. Congel G. Lainas J. Mitchell P. Milano P. Anderson M. Mejak S. Ebneter, Region II

-E. Mirschoff, Region II J. Johnson, Rey an II

Enclosure 1 BRUNSWICK STEAM ELECTRIC PLANT READINESS FOR RESTART

1.0 BACKGROUND

Brunswick Steam Electric Plant (Brunswick or BSEP) is a two-unit boiling water reactor (BWR-4) plant owned and operated by the Carolina Power & Light Company (CP&L). The plant is located in Southport, Brunswick County, North Carolina.

On April 7,1992, the licensee determined that the emergency diesel generator (EDG) building's interior, steel plate reinforced, masonry block wall between ,

EDG-4 and emergency bus E8 was not capable of withstanding a seismic event because of an insufficient number of adequately installed anchor bolts. Many ) B2 of the anchor bolts were improperly installed during construction in the early 1970s. The heads of these nonconforming anchor bolts were tack welded to braces without the bolt shanks being adequately anchored to the masonry walls, b On April 21, 1992, the licensee identified a poured concrete wall between EDG- /et h I and emergency bus E6 that was also deficient because the seismic supports were inadequately anchored. When it became apparent that other similar interior walls in the EDG building were likely to have these same deficiencies, all EDGs were declared inoperable, placing the plant in a two-unit Technical Specifications (TS) action statement requiring shutdown. A potential problem with fastener installation had been noted several years earlier by licensee personnel. However, the problem was not properly documented or evaluated, and appropriate corrective actions were not taken.

Not until prompted by concerns raised by an NRC inspector about this potential nonconformance did the licensee take action to identify and evaluate the full extent of the deficiency.

Past History of Problems The NRC staff has identified a repetitive series of problems with the performance of BSEP. The staff has noted that similar root causes of these weaknesses have been found in major inspection activities and Systematic Assessments of Licensee Performance (SALP) reports for almost 10 years.

Although the licensee has initiated a number of improvement programs over this period of time, the licensee has not been effective in correcting the underlying causes of the weak performance.

SALP The NRC staff had recognized a continuing weakness with the licensee's program to determine root causes and implement effective corrective actions. It had also ncted a decline in management effectiveness in defining and communicating goals and objectives and in communicating to the staff at BSEP management expectations regarding adherence to acceptance standards. These weaknesses

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had contributed to a decline in the overall performance at BSEP, as noted in the Systematic Assessment of Licensee Performance (SALP) report presented to the licensee in November 1988. Specific problems noted in the report included (1) instances of operator inattention to detail, (2) higher than expected equipment failure rates, (3) management tolerance-of material deficiencies, and (4) slow action by engineering support to correct design deficiencies.

Because of these issues, NRC management recommended that a diagnostic evaluation team (DET) conduct a thorough evaluation. The evaluation was

2 conducted in May 1989 to assist in revealing the root cause of the declining performance.

. Diaonostic Evaluation Tea... Inspection The DET identified a number of root causes for the observed decline in plant performance. The DET found management weaknesses such as its failure to clearly define and communpte :;ite ;nis, pri~ m ations. The DET also found a lack of(individual accountabili an ;eamwork an - (4 prN ineffective corrective action and root u u n uetermina ;... W vyram, and an ineffective' engineering design and technical support program.

On receipt of the DET findings in September 1989, the licensee established a performance improvement program, called the Brunswick Integrated Action Plan (IAP). The staff noted an overall level of improvement during the latter half of the SALP period that ended August 31, 1989. It attributed this trend to changes in senior-level management at both the site and corporate office, as well as the initial implementation of self-assessment recommendations J encompassed by the Brunswick IAP. However, these improvements we b. g _

negated by poor licensee performance in the areas of work control, perator performance during NRC-administered examinations, and additional instances of inade- 'te engineering support of the plant staff. These led to continuing d ons of BSEP's performance at the senior management meetings during 195 ad 1991.

Special Reaion il Inspections Because of the continued work control problems and the apparent inability of the IAP to sustain an overall improvement in plant performance, Region 11 conducted a series of five special inspections in the first half of 1992 to assess possible root causes. Although some improvement due to the IAP was noted, the licensee was expending significant technical support resources in reacting to equipment failures, allowing little attention to be paid to predicting or preventing future failures. These NRC inspections highlighted the previous management weaknesses in setting appropriate standards of acceptance for plant material condition and providing critical self-assessment.

CP&L Imorovement Plans NRC senior management determined in June 1992 that the continuing material deficiencies (further evidenced by the April shutdown) and the insufficient improvement in performance warranted placing BSEP on the list of facilities requiring additional management attention. In a letter of June 23, 1992, the Administrator, Region II, notified the licensee that the depth of issues associated with BSEP required an integrated approach to their resolution such as a performance improvement program. He noted in the letter that, although the licensee had made a number of changes in organization and in the physical plant, these changes had not corrected performance to the degree necessary and the decline identified in the March 1992 SALP report had continued.

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3 In response to the request for a performance improvement program and to the findings of the NRC special inspection, the licensee initially submitted its description of a proposed Corporate Improvement Program on July 23, 1992. The licensee provided a commitment to improve the performance of.BSEP, a description of the BSEP Startup Plan, and a description of the general structure of the company's long-term improvement program.

On November 30, 1992, the licensee submitted the formal details of its commitment directed at the corporate organization and its programs that would be implemented to benefit all three of its nuclear facilities (BSEP, H. B.

Robinson, and Shearon Harris). The licensee indicated that the outstanding projects described in its July 23, 1992, letter were incorporated into the new Corporate Improvement Initiatives (CII) and the Brunswick Three-Year Plan.

The CII was designed to address seven key are s:

(1) definition of organizational structure, responsibility, and accountability (2) nuclear safety oversight (3) managerial effectiveness in the areas of teamwork, communication, leadership, and employee motivation (4) programs and procedures (5) personnel development, emphasizing training and professionalism (6) basic work planning and control systems (7) material condition Integrating the projects noted in the CII, the licensee provided its Brunswick

- Three-Year Plan, which contains a description and schedule for each of the detailed initiatives and projects, to the NRC on December 15, 1992. The objective of the Three-Year Plan (1993-1995) is to improve safety, operations, cost performance, employee satisfaction, and achievement of the schedule and commitments as well .as to have the capability for achieving a "world class" level of performance by 1996.

Confirmatory Action letter After additional conversations with licensee management, the Administrator, Region II, issued a confirmatory action letter (CAL) on December 18, 1992, detailing the specific actions that the licensee would complete before the restart of Unit 2. Specifically, the CAL included an acknowledgement of the following commitments, as agreed to by the licensee. First, the licensee agreed to complete certain corrective actions previously identified in Enclosure 3 to its July 23, 1992, letter. Many of the corrective actions, that will be discussed in subsequent sections of this report, were necessary to upgrade the material condition of the plant. Second, the licensee would complete the repair and testing of the emergency diesel generators. Finally,

4 the licensee would perform a readiness review of equipment and personnel before restart.

h.

Incorporating the activities and process improvements that were required by the CAL and other applicable 'n pection documentation, the NRC staff prepared a Restart Action Plan dated July 24, 1992, as supplemented March 9, 1993, to verify the successful completion of all requirements. This pian will form an

, integral part of the staff's evaluation of the readiness of BSEP Unit 2 to

restart. The staff has been using NRC Inspection Manual Chapter 0530 " Staff i

Guidelines for Restart Approval," as guidance.

2.0 ROOT CAUSE IDENTIFICATION As indicated in Section 1.0, the licensee had.not succe ully corrected the i

root causes of the problems with the performance of BSEP. Recognizing this fact, the licensee addressed the key issue's identified by the NRC and the

! results of its own assessment (conducted by the Nuclear Assessment Department 1

(NAD)) and documented in a report dated June 19, 1992, as the basis for the Cll and the Brunswick Three-Year Plan. In addition to addressing the key NRC issues that were previously stated, the licensee self-assessment indicated the

need for improvement in the following areas:

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1. Weaknesses associated with cor) orate management's direction and 4

communication of expectations lave resulted in a limited ability of corporate management to sponsor or to sustain positive change.

! 11. The role of corporate management and staff has not been clearly

defined or implemented in the oversight and support of plant

performance.

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. Ill. Corporate management has not effectively assessed the total workload i at BSEP in order to provide the resources necessary to sustain j performance improvements.

IV. Self-assessment and correctiv. actions have been insufficiently effective in identifying, correcting, and preventing problems, i

V. Human performance weaknesses are a significant contributor to less-

! than-acceptable BSEP performance.

On the basis of the above key issues and-inspection and assessment findings, the licensee has developed a comprehensive program to improve plant i performance and safety, i

f 3.0 NRC ASSESSMENT OF CP&L ROOT CAUSES AND CORRECTIVE ACTIONS 4

) The NRC staff has highlighted the root causes of the decline in the performance and material condition of BSEP for several years. The staff has found that its present conclusions about the root causes have been generally l consistent with previous NRC findings. The root causes have been identified 4

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5 on a recurring basis in previous SALP reports and in the findings from the special inspections conducted since 1989. The root causes determined by the licensee agree with those identified by the NRC staff. The licensee addressed these root causes and the applicable corrective action initiatives and programs in the CII and the Brunswick Three-Year Plan (1993-1995). The NRC staff and the licensee are, thus, in agreement on the root causes and corrective actions.

g, The NRC staff has conducted a thorough review of the CII and 3Three-Year Plan to assess the scope, adequacy,- and implementation capability of the various projects and initiatives. The staff provided the results of its review and a request for additional clarifying information to the licensee in a letter dated March 8, 1993. The staff has found that the CII and Three-Year Plan are a comprehensive program that addresses the root causes for the observed decline in plant performance and provides a workable process for implementing the necessary changes and assessing the effectiveness of the corrective actions. The licensee will respond to the request for clarification in May 1993.

More so than in the earlier improvement programs, the licensee has now enhanced senior management authority, responsibility, and accountability for each of the projects. Each senior manager is fully accountable for the success of the project and has sufficient authority to bring the project to completion and make any necessary adjustments. This ownership of the projects was lacking in previous improvement programs.

The staff's questions concerning the CII and Three Year Plan, however, relate to the mechanisms by which the licensee will evaluate the progress of each project toward fulfilling its expected goal and objectives. The staff believes that additional work is needed in this area so that all individuals are able to properly assess their performance and the success of the project in correcting the specific issue.

Overall, the licensee has made significant progress in regard to the short-term actions to improve performance. Corporate management appears to be providing adequate support and oversight of the program. The NRC will <

continue to monitor the implementation of this improvement program by means of continued inspections and through periodic meetings to discuss the programs with the licensee.

4.0 NRC ASSESSMENT OF RESTART ISSUES AND STARTUP COORDINATION 4.1 Introduction The major issues requiring resolution before any decision is made on the restart of BSEP Unit 2 were listed in the confirmatory action letter of December 18, 1992. As previously stated, the root causes of the failure of the licensee's programs to improve the overall performance of the facility have been identified in a number of special inspection and SALP reports.

Additionally, in a letter dated June 23, 1992, the Administrator, Region II, included a list of long-term actions to correct process problems contributing

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to the decline in performance that needed to be factored into a comprehensive improvement program. Further, in a letter to the licensee dated June 30, 1992, the Executive Director for Operations summarized the discussions on BSEP that were held at the June 1992 NRC senior management meeting. He stated that repetitive work control failures, personnel errors, and ineffective management

, oversight were evidence of declining performance. The material condition of the plant, lack of attention to detail, and weak self-assessment program were also listed as contributing factors.

The NRC staff developed a comprehensive restart evaluation process called the Brunswick Restart Action Plan. This process will ensure that the required restart issues are addressed by the licensee and are thoroughly reviewed, inspected, and assessed by the NRC staff before the plant restarts. The staff has reviewed the short-term actions described in the confirmatory action letter to verify satisfactory resolution. It also has evaluated as acceptable the programs to implement the process and management oversight improvements designed to correct the previous trends in declining performance. It will continue to closely monitor these programs and the N iementing projects to ensure that the improvements are sustained.

In addition to these efforts, the NRC Oconduct an operational readiness assessment team (0 RAT) inspection from March 29 through April 9, 1992. The principal objective of this inspection 4 to perform an in-depth evaluation of those major functional areas necessary to verify that the licensee is ready to resume operations. In addition to evaluating the conduct of operations and other work control processes, the ORAT w+W evaluatelthe capability of the licensee's oversight and corrective action mechanisms. The ORAT inspection report is expected to be formally issued about May 15, 1993.

The following sections address the areas assessed by the NRC staff during its evaluation of the actions needed before the plant is ready to restart. The areas are consistent with NRC Inspection Manual Chapter 0350, 4.2 Physical State of Readiness of the Plant Masonry Walls During the original analysis of the masonry block walls at BSEP in response to Office of Inspection and Enforcement Dulletin (IEB) 80-11, several walls in the control, diesel generator, and Unit I and Unit 2 reactor buildings were classified as non-safety related. Since IEB 80-11 did not require control room habitability to be evaluated, and since several walls in the control room were not in the immediate vicinity of safety related equipment, they were not included in the IEB 80-11 analysis.

As of December 18, 1992, all masonry block walls in the control and diesel generator buildings are classified as safety related. The reasons for revising the safety classifications of walls originally classified as non-safety related include change in design function (e.g., control room habitability), installation of safety related equipment on or in proximity to masonry walls originally classified as non-safety related, and removal of tornado design considerations. Eleven walls in the Unit I reactor building

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7 have been upgraded to safety related, with 30 walls still classified as non-safety related; 12 walls in the Unit 2 reactor building have been reclassified as safety related, with 38 still classified as non-safety related. The licensee has completed design calculations using updated design-criteria for tornado and seismic loads for all walls classified as safety related. Those safety related walls that did not meet design criteria were modified for Unit 2 and are presently being modified for Unit 1. The NRC staff reviewed the safety classification of all masonry walls and performed inspections to examine the complete modifications; it identified no deficiencies during these

-inspections.

Eouioment Corrosion Equipment corrosion and ground water inleakage problems were identified during the NRC assessment of BSEP operations (February-April 1992) and during subsequent system / area walkdowns. The three major corrosion-related restart issues addressed during the current dual-unit outage were the effects-of corrosion on the structural integrity of service water pump lubrication water piping supports, seismic instrument racks, and short-term seismically qualified items (including service water pumps). The existing service water pumps have been repaired. The licensee's evaluation of the repaired condition

\ indicates that theatpumps

./f he earthquake and are alified meet the allowable for short-term operability limits untilLthe for the safa newchutd" QA di '

P; } replacement pumps aN'%t&d in 1994. Through the short-term qualification process, the licensee has evaluated each item to justify its operability until the next refueling outage, at such time a permanent repair or more detailed evaluation will be done.

The licensee has replaced the corroded carbon steel service water pump lubrication water piping supports with new stainless steel supports.

Similarly, it has replaced three corroded instrument racks in each unit and has made interim repairs to other racks (i.e., 21 in Unit 2 and-17 in Unit 1).

The interim repairs included the addition of lateral braces to some racks and/or installation of new' conduit supports and flexible conduits between existing conduits and racks. Corrosion of service water pump base sole plates and holddown bolts brought into question the existing short-term seismic qualification af the pumps. Consequently, the licensee was prompted to replace the co roded bolts and nuts, as well as ultrasonically test the sole plates, on all 10 pumps. Additionally, an indepent.ent, third-party review of short-term structural integrity items was conducted to ensure that any corrosion did not affect previous field assumptions in the short-term seismic analyses.

p Other areas of significance-in Unit 2, where corrosioa-affected items were repaired during the dual-unit outage, include the drywell, residual heat $

removal pumps, nuclear service water building, Yeactor feed pump and feedwater

• heater rooms, condenser pit inlet / outlet, and circulating water pump / motor structural steel. The NRC staff has inspected these repairs and found them to be satisfactory to support restart. In conjunction with categorizing and performing identified corrosion-related maintenance in accordance with CP&L Plant Notice PN-30, " Integrated Recovery Methodology," the licensee continues to implement its corrosion mitigation project on a system-by-system basis.

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8 Captured under the Brunswick Three Year Plan, the licensee's corrosion control program will address root causes of existing corrosion, implement preventive maintenance measures, provide for corrosion-related repairs, and upgrade material and coatings where appropriate. ~

Deferred Eouipment Maintenance On July 23, 1992, the licensee submitted its Pre-startup Plan, which outlined a methodology and criteria for defining the work activities that would be completed before startup. Because of concerns raised by the NRC staff on the restart work screening process, the licensee developed Plant Notice PN 30,

" Integrated Recovery Methodology," to identify, compile, categorize, schedule, and complete the open work items. The licensee included work activities such as the completion of work requests / job orders, temporary conditions, deficiencies noted in material walkdowns, engineering work requests, and pending plant modifications into the screening process. The NRC staff has found the licensee's work screening process to be effective in assuring the systems are ready for restart.

To improve the control of the backlog of corrective maintenance, the licensee's program prioritizes the work into a series of categories depending t13 on the impact on safety, equipment reliability, and conformance with regulations and commitments.

The licensee has established site-wide; hor N\ f p $

term (restart) and long-term (three year) targets / goals for thCnumber of oa , y work items and the completion rate to assist in the monitoring 'performanc_e.  ;

The NRC staff has determined that the target levels are appropriate and will '

continue to review the licensee's progress in attaining these targets. .h p Potential Structural Deficiencies (P

.- p p* p Structural deficiencies at BSEP primarily fall under the areas of miscellaneous structural steel (MSS) or short-term structural integrity (STSI). Miscellaneous structural steel, which consists of various platforms and beams spanning the main building steel, supports to various safety related and non-safety related equipment (including heating, ventilation, and air corditioning (HVAC) equipment, electrical raceways, piping, and instrumentation). By June 1992, numerous deficiencies in MSS in the BSEP reactor buildings had been identified. Since these deficiencies did not meet the requirements in the final safety analysis report (FSAR) and as-built updated drawings did not exist, the adequacy of MSS for safe plant operation was brought into question. Accordingly, the licensee retained Bechtel Power Corporation in July 1992 and implemented a two-phase miscellaneous steel verification program. Phase I activities (walkdowns of both reactor buildings) emphasized the elimination of significant irregularities, whereas Phase 11 activities (walkdowns of reactor building and drywell platform steel) focus on design-basis verification and preparation of as-built drawings.

Because Phase 11 of the program was not intended to be completed by restart, stress analyses were performed on six of the highest stressed platforms to ensure structural operability. Walkdowns of MSS in the Unit 2 reactor building and drywell (performed under Phase I and part of Phase II, respectively) have since been completed, with all related operability concerns corrected.

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9 Of equal importance are the structures and components that, because of various deficiencies, do not meet FSAR design margins and h:ve, therefore, been seismically qualified for the short term by the licensee. Known as STSI items, they were raised as concerns in April 1992 during NRC's appraisal of f BSEP operations. At that time over 200 STSI items had been identified, many of which had been in existence for a number of years. In several cases pursued by NRC (i.e., EDG building interior masonry block walls and control room emergency filtration system), the existing STSI qualification was found to be in error because of insufficient field verification of actual conditions. Accordingly, an independent walkdown of STSI items, as well as a review of the STSI program, was performed by a non CP&L organization. The walkdown focused on non pipe support STSI items ...e 91pe supports in areas with high corrosion potential in order to validate daign assumptions. The program review addressed evaluation techniques, field validation of critical assumptions, and communications from the site's technical support group to the CP&L Nuclear Engineering Department. '

The licensee completed repairs or satisfactorily analyzed the discrepancies '

for 65 of the original 88 Unit 2 STSI items. However, since the start of the current dual unit outage, approximately 142 pipe supports and 688 additional '

components were identified in Unit 2 by the licensee's Design Turnover Project and various plant walkdowns, in addition, a significant number of potential STSI items, such as loose or missing hanger nuts, were repaired at the time they were identified. Although all the open Unit 2 STSI items (approximately 853 as of March 5, 1993) are subjected to the PN-30 integrated recovery methodology, the licensee has performed an integrated safety review (under the provisions of 10 CFR 50.59) of the STSI items not repaired or analyzed before Unit 2 startup to ensure that their cumulative impact does not constitute an unreviewed safety question. Except for fuel oil small bore piping, which is scheduled for completion in 1995, the licensee committed to repair or evaluate in detail all remaining Unit 2 STSI items. This will be completed after restart but bafore the end of Refuel 10, currently scheduled to begin in March 1994. Based on the NRC staff's assessment of the licensee's approach and methodology, the NRC staff believes that the licensee's conclusion that no unreviewed safety question exists is satisfactory.

Aside from the miscellaneous steel and corrosion-related issues previously discussed, some of the key structural engineering issues completed or resolved "

during this current dual-unit outage involved 45 EDG building interior masonry -

block and poured concrete walls,12 control building m9sonry walls, 2 masonry walls in each reactor building, anchorages on 46 motor '.ontrol centers, '

recirculation system ring header supports, and all 4 EDG exhaust lines. In addition, because of the bolting deficiencies identified on EDG walls, the licensee sampled the anchor bolts installed in electrical raceways, building steel, HVAC components, and equipment foundations to determine if they were properly installed. The NRC staff has inspected the structural items addressed above to verify their acceptability for restart and has found them satisfactory.

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t 10 Backloa of Temoorary Conditions Excluding STSI items, which are discussed above, temporary conditions include the broad areas of operator work arounds, temporary modifications, disabled control room annunciators or instruments, and permanent caution tags. At the time of the NRC assessment of BSEP's operations (February-April 1992), the licensee was not aggressive in reducing temporary conditions, as evidenced by the fact that many of the temporary conditions have existed since 1984.

After the November 30, 1992, pre restart commitment to reduce the backlog of temporary conditions in accordance with the PN 30 integrated recovery methodology, the licensee established site-wide short-term (restart) and long-term (3 year) goals. These short-term goals are as follows: operator work-arounds less than or equal to 64; temporary modifications less than or equal to 50; disabled control room annunciators / instruments less than or equal to 10; and no permanent caution tags. The long term goals are as follows: no operator work arounds; temporary modifications less than or equal to 25, with NONE greater than 1 cycle old; disabled control room annunciators / instruments less than or equal to 10; and no permanent caution tags. In addition, the overall long-term average age target was established to be less than or equal to 1 cycle.

Since presenting the above goals to the staff during a management meeting at Region 11 on February 4, IJ93, the licensee has demonstrated an aggressive attitude in its efforts to ensure all temporary conditions have been accounted for, as well as toward achiaving its restart goals. The backlog of temporary conditions is showing an overall )ositive trend toward meeting all the established restart goals. On Fearuary 4, 1993, the temporary conditions were as follows: 90 operator work-arounds, 75 temporary modifications, 25 disabled control room annunciators / instruments, and 140 permanent caution tags. On March 16, 1993, they had decreased overall to 66 operator work-arounds, 66 temporary modifications, 26 disabled control room annunciators / instruments, and 15 permanent caution tags. The ORAT and the licensee will review further \

readiness reviews before unit the temporary conditions backlog during restart, b startup\b of otta-r rG..

Deficiencies Durina Material Walkdowns in February 1992, the Unit 1 3B feedwater (FW heater was removed from service when a remote camera showed movement of approx)imately 17 inches of the heater's extraction steam line. This movement was attributed to an earlier pipe replatament modification during which existing supports were removed.

Followup inspections in the shutdown Unit 2 revealed numerous FW-related hanger or support deficiencies. Because these deficiencies were in areas not normally accessed during operation because of Al. ARA concerns, the licensee performed what were known as " hot side" walkdowns during the current dual-unit outage. Because of the degraded material conditions found in February-April 1992 during the'NRC assessment of BSEP's operations (i.e., equipment corrosion problems, ground water leaks, seismic design deficiencies), as well as the number of deficiencies identified during the hot side walkdowns, the licensee also performed cold side walkdowns (i.e. walkdowns in areas normally accessed during plant operation).

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I1 In October 1992, because of NRC staff identified additional equipment and material deficiencies, the NRC staff determined that the licensee's hot and cold side walkdowns were not acceptable for restart. Consequently, the licensee developed a more structured inspection program known as material condition walkdowns. Under this program, walkdowns of 24 Unit 2 areas were performed by multidisciplinary teams governed by a procedure containing detailed inspection instructions, as well as inspection criteria and guidance on evaluation of potential deficiencies. Although most of the 24 Unit 2 areas were included in the earlier hot side walkdowns, the material condition walkdowns were more detailed. As a result many more deficiencies were identified. Similar walkdowns of Unit I areas are under way with an expected completion date in April 1993.

Together, the initial hot and cold side walkdowns and the subsequent material -

condition walkdowns have resulted in the identification of over 6,000 minor deficiencies to date. Most of these deficiencies were considered minor, as they insolved missing and loose bolts or nuts associated with electrical condui., cable trays, HVAC equipment, and miscellaneous structural supports.

(See the previous section entitled " Equipment Corrosion" for identified corrosion-related deficiencies.) A significant number of deficiencies were repaired under the licensee's newly implemented minor maintenance program.

Those items that could not be corrected in that manner were incorporated into the maintenance backlog to be categorized and worked accordingly under the licensee's PN-30 integrated recovery methodology. Because of the number of identified deficiencies, the licensee intends to perform material condition walkdowns in the remaining areas of the plant. The licensee informed the NRC that such additional walkdowns would be completed in Unit 1 before restart in September 1993 and in Unit 2 before Refuel 10 (currently scheduled for March 1994). Because the majority of items identified to date have had minimal impact on equipment operability, the staff finds the licensee's plans to complete these additional walkdowns after unit restart to be acceptable.

Emeroency Diesel Generators (EDGs) gdr Md bbW # '

Numerous problems with the EDGs identified during the electrical distribution + w@od system functional inspection (March-April 1991) called into question BSEP's -

EDG maintenance program. Contributing to the situation is that power operation of either one or both BSEP units require all four EDGs to be L operable. Because of this, the TS allows one EDG to be inoperable (i.e., 5 ' p?

taken out of service) for only 7 days, thereby limiting an EDG's maintenance # M windowwheneitherunitisoperahing. Therefore, during the current dual-unit En outage, the licensee conducted E G inspections (i.e., 54-month and TS-required @ud,J.

18-month) and significantly redu ed the backlog of EDG corrective maintenance "?" w items and modifications. 3 y,g g g W 7 L 6, n #

3 y, s A 7 Q i w fc o 4 # it % ,3 n With the exception of EDG 1, the diesel inspections were completed with little difficulty. The deficiencies in EDG 1 that prolonged its inspection and MN outage included:

1. camshaft drive train damage (i. e., both idler gears and right camshaft gear)

12 II. catastrophic failure of crankshaft thrust bearing No. 9

!!!. crankshaft alignment problems IV. crankshaft runout measurement problem V. evidence of 1/4-inch axial engine movement on base plate (based on discerned movement of engine collision blocks and bent generator stator dowel pins)

VI. damage to the flexible drive gear that couples the crankshaft to the jacket water and lube oil pumps VII. damage to the motor to pump coupling on the auxiliary motor-driven jacket-water pump The licensee made extensive use of contracted technical assistance to appropriately resolve these deficiencies and subjected EDG 1 to a 24-hour post-maintenance endurance run to ensure operability, in light of the concerns raised regarding EDG 1, the other three EDGs underwent further inspection of their No. 9 crankshaft bearing, flexible drive gear, engine collision blocks, and auxiliary motor-driven pump alignment. However, similar problems were identified only for the gear backlash setting on the flexible drives. Operability of EDGs 2, 3, and 4 was also ensured by the performance of a 24-hour endurance run.

4.3 Plant and Corporate Staff Readiness During the last SALP cycle, the overall performance in the area of plant

] operations was good.

events in the plant.

The licensed operators performed well when challenged by Although a slight decline in command, centrol, and communications was apparent, the operators were generally considered professional and knowledgeable of plant systems and procedures. Problems involving configuration control and ineffective supervisory oversight contributed to such things as a decline in plant housekeeping and lapses in operator attention to detail. The licensee has included these issues in the Cll and in the Brunswick Three-Year Plan.

One action in the Cll resulted in a reorganization at BSEP. Each unit now has its own plant manager, operations manager, and maintenance manager. This has resulted in more focused attention on each unit. The new organization also gives the site more control over support organizations in the areas of training, licensing, and engineering. To reduce distractions in the control room, the licensee has moved all work order screening and work approval activities out of the control room. Additionally, the increased management attention toward improving the material condition of the plant and reducing temporary conditions has improved the attitude of the operators. That is, the operators are more likely to identify plant deficiencies because their concerns are being addressed.

13 The licensee has also conducted training to improve the operators' command, control, and communication skills, along with training on the restart and power ascensiori testing. The NRC performed inspections in this area and determined that training has been adequate to support restart of Unit 2.

During the Unit 2 startup, the licensee will increase management control and oversight by having a startup duty manager, a power ascension test manager, a shift test coordinator, and a maintenance response team. The NRC will implement around-the clock inspection coverage for the startup.

To improve work control problems, the licensee has implemented a number of new programs. The work management process has been simplified; therefore, it is easitr to get work scheduled, planned and completed. A new procedure for determining post-maintenance test requirements was issued. A minor maintenance program whs established, and a new department was created to manage the work control process. NRC inspections in this area confirm that progress is being made.

The licensee has also made progress in its corrective action programs. The NAD requires a formal response to NAD findings, similar to the NRC's requirement to respond to cited violations. In the past, all adverse conditions were processed under the corrective action program and significant issues could get lost in the large volume of items. To improve this situation, the corrective action program now has a better defined subprogram for minor adverse conditions, thereby permitting more attention to significant adverse conditions. The NRC is still evaluating the effectiveness of this new process.

In summary, the licensee has (1) reorganized the BSEP organization according to unit to provide increased management focus, (2) implemented a number of new procedural processes to simplify work activities, and (3) conducted training to improve the skill and knowledge level of its staff. All these activities are part of the licensee's CII and Brunswick Three-Year Plan. Although the NRC staff finds these actions to be positive, it will continue to inspect the licensee's activities to ensure continued progress.

4.4 Licensee Management and Oversight Licensee management has demonstrated a serious commitment to improvement and has provided the management attention and resources necessary to effectively implement its CII and the Brunsw M k Three-Year Plan. It has made major organizational and personnel changes during the past year. Since September 1992, the licensee has enacted the following management changes:

(1) The position of President and Chief Operating Officer, reporting directly to the Chairman / Chief Executive Officer, was created and staffed.

(2) The position of Executive Vice President, Nuclear Generation Group, was created and staffed, replacing the position of Senior Vice President, Nuclear Generation Group.

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14 (3) The positions of Vice President, Brunswick Nuclear Project, and the Director, Site Operations Brunswick were created and staffed.

(4) Plant management was changed to a unit format as follows:

(a) Manager - Unit I and Manager - Unit 2, previously Plant General Manager (b) Manager, Operations - Unit I and Manager, Operations - Unit 2, previously Manager, Operations (c) Manager, Maintenance - Unit I and Manager, Maintenance - Unit 2, previously Manager, Maintenance These personnel changes were implemented using individuals from outside the CP&L organization or from the other two CP&L plants, thus providing site and corporate management with a broader industry perspective in operating and managing BSEP. To date, these individuals have been effective in improving overall site performance.

4.5 Licensing Actions Several licensing actions required NRC staff review and approval during the extended outage to support BSEP restart. These licensing actions included two license amendments, one inservice testing (IST) safety evaluation and relief, and two inservice inspection (ISI) safety evaluations (one of which was for Unit 2 only). The following is a summary of the significant licensing actions filed by CP&L and reviewed and approved (with one pending) by the NRC staff to ensure that BSEP and its prospective operation would not conflict with any h applicable regulatory requirements:

1. While reviewing the applicability of an operating experience report from another utility on the preferred / standby logic for standby gas treatment system filtration trains, the licensee determined that the emergency air filtration trains of the control building HVAC system use a preferred or standby logic. Further review indicated that previously unidentified single failures could occur that would defeat the safety function of the system. To correct this defect, the licensee applied for amendments to change the TS for the chlorine detection system and control room emergency filtration system, and their associated bases, to reflect the modifications being made to the actuation logic in the chlorine detection subsystem of the control building emergency ventilation system. The licensee modified the logic to change the present fail-safe design to a single-failure-proof design by increasing the number and type of detectors in each trip system, II. On February 24, 1993, the NRC staff issued a safety evaluation for two requests for relief from the ISI program to allow the substitution of an alternative program for the required system functional and hydrostatic tests of the main steam safety relief valves. The first ISI relief for Units 1 and 2 applied to the main steam relief valve discharge piping (ASME Code Class 3 component) connecting the safety / relief valves to the containment suppression pool. The second relief, for Unit 2 only, applied to the main steam relief valve