ML20235R331

Forwards Emergency Operating Procedures Insp Repts 50-324/88-200 & 50-325/88-200 on 880926-1007

ML20235R331
Person / Time
Site:	Brunswick
Issue date:	02/23/1989
From:	Lainas G Office of Nuclear Reactor Regulation
To:	Utley E CAROLINA POWER & LIGHT CO.
Shared Package
ML20235R333	List: ML20235R331 ML20235R342
References
NUDOCS 8903030259
Download: ML20235R331 (6)

See also: IR 05000324/1988200

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

k . . . . . p# February 23, 1989

Docket Nos. 50-325, 50-324

Mr. E. E. Utley )

Senior Executive Vice President i

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Carolina Power and Light Company

P.O. Box 1551

Raleigh, NC 27602

Dear Mr. Utley:

SUBJECT: EMERGE!1CY OPERATING PROCEDURES INSPECTI0ll  !

(IllSPECTION REPORTS 50-325/88-200AND50-324/88-200) l

Th'is letter forwards the report and Executive Summary concerning the emergency

operating procedure (E0P) inspection conducted by the NRC's Office of Nuclear

Reactor Regulation f. rom September 26 through October 7,1988. The activities

involved are authorized by NRC Operating License Nos. DPR-71 and DPR-62 for the

Brunswick Steam Electric Plant (BSEP), Units 1 and 2. At the conclusion of the

inspection, the inspection team discussed the findings with Mr. J. Harness and

other members of your staff identified in Appendix A of the enclosed inspection

report.

The purpose of the inspection was to verify that your E0Ps were technically

correct; that their specified actions could be meaningfully accomplished using l

existing equipment, controls, and instrumentation; and that the procedures had t

l the useability necessary to provide the operator with an effective accident l

mitigation tool. The inspection team reviewed the draft E0Ps which were based i

upon Revision 4 of the Boiling Water Reactor (BWR) Owners' Group (BWROG)

Emergency Procedure Guidelines (EPGs) and were in the final stages of

development. Areas examined during the inspection are identified in the

report. Within these areas, the inspection consisted of selective examinations

of procedures and representative records, simulated emergency exercises using

the plant-specific simulator, plant walkthroughs, interviews with personnel,

and observation of activities in progress.

The inspection team identified se'eral

v technical inaccuracies and determined

that the draf t E0Ps did not in every instance represent an accurate incorpora-

tion of the accident nitigation strategy of the BWROG EPGs. As a result, the

team concluded that the E0Ps would not adequately assure the successful j

accomplishment of all specified actions. For example, the level / power control l

procedure, containment flooding procedure and containment venting procedure j

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were adversely affected by the methods used to measure reactor and containment

} water levels. The inspection team concluded that the E0Ps could be performed

j by the operating staff; however, the method used differed from those specified

j by administrative procedures. As a result, the shift foreman alone could not 1

direct the implementation of the E0Ps because of their level of complexity and

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the incorporation of event-based, post-trip actions within the E0Ps. Finally,

the inspection team concluded that the accident mitigation strategy for

containment venting was severely limited because of the limitations on

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electrical power to the containment vent valves. /

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Mr. E. E. Utley -2- February 23, 1989

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The inspection team identified several concerns regarding the draft E0Ps which

affected the E0Ps in use at the facility at the time of the inspection. For

example, the methodology used to measure the reactor water level during

accident conditions could adversely affect the operator's ability to mitigate

an anticipated transient without a scram. Also, the methodology used to

monitor the containment drywell temperature could potentially mask valid E0P

entry conditions. The inspection team discussed these concerns in detail with

your staff at the exit interview on October 7,1988.

It should be noted that the enclosed executive sumary and inspection report

addresses the draft E0Ps based upon Revision 4 of the BWROG EPGs, as well as

the E0Ps in effect during the teams inspection which were based on Revision

2 of the BWROG EPGs. It is our understanding that the E0Ps that are currentiy

in effect are based upon Revision 4 of the BWROG EPGs. It is also our under- ]

standing that the concerns raised by the team in regard to the E0Ps that were

in effect during tho inspection were addressed and corrected promptly.

We request that you formally transmit to the NRC your plans for corrective

actions related to the inspection findings within 30 days of the receipt of

this letter. These corrective actions should specifically address the actions

that you took to resolve the inspection team's concerns which affect the E0Ps

l which were in use at the facility during the inspection, as well as the concerns s

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related to the E0Ps that are currently in effect. All of the-inspection I

team's concerns are detailed in the enclosed inspection report. Some of.the )

items identified by the team may be potential enforcement findings. Any  ;

l enforcement actions will be identified by Region II in separate correspondence. j

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure

will be placed in the NRC Public Document Room.

The responses requested by this letter and its enclosures are not subject to

the clearance procedures of the Office of Management and Budget as required by

the Paperwork Reduction Act of 1980, Pub. L, No.96-511.

Should you have any questions concerning this inspection, please contact me or

Mr. C. A. VanDenburgh (301-492-0965).

Sincerely,

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( Gus C. Lainas, Acting Director

Division of Reactor Projects I and II

Office of Nuclear Reactor Regulation

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Enclosures:

1. Executive Summary

2. NRC Inspection Reports 50-325/88-200 and 50-324/88-200

cc w/ enclosures: See next page

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Mr. E. E. Utley -3- February 23, 1989

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cc:

Mr. P. W. Howe Mr. J. L. Harness

Vice President Plant General Manager l

Brunswick Nuclear Project Brunswick Steam Electric Plant

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P. O. Box 10429 P. O. Box 10429

Southport, North Carolina 28461 Southport, North Carolina 28461

Mr. R. E. Jones, General Counsel Mr. H. A. Cole

Carolina Power & Light Company Special Deputy Attorney General

P. 0 Box 1551 State of North Carolina

Raleigh, North Carolina 27602 P. O. Box 629 .

Raleigh, North Carolina 27602 l

Mr. Mark S. Calvert i

Associate General Counsel Mr. Robert P. Gruber

Carolina Power & Light Company Executive Director

P. O. Box 1551 Public Staff - NCUC

Raleigh, North Carolina 27602 P. 0. Box 29520 '

Raleigh, North Carolina 27626

Ms. Grace Beasley

Board of Commissioners

P. O. Box 249

Bolivia, North Carolina 28422

Mrs. Chrys Baggett

i State Clearinghouse

Budget and Management

l 116 West Jones Street

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Raleigh, North Carolina 27603 i

Resident Inspector

i U. S. Nuclear Regulatory Conunission

i Star Route 1

P. O. Box 200

Southport, North Carolina 28461

Regional Administrator, Regicn II

U. S. Nuclear Regulatory Commission

101 Marietta Street, Suite 2900

Atlante, Georgia 30323

Mr. Dwayne H. Brown, Chief

Radiation Protection Branch

l Division of Facility Services

1

North Carolina Department of Human Resources

701 Barbour Drive

Raleigh, North Carolina 27603-2008

Institute for Nuclear Power Operations

1100 Circle 75 Parkway

Atlanta, Georgia 30339

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Mr. E. E. Utley - 4 -- February 23, 1989

Distribution: (w/ encl)

Docket Files 50-325/324

DRIS R/F

RSIB R/F

PDR

LPDR

BKGrimes, NRR

CJHaughney, NRR

JEKonklin, NRR ,

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CVanDenburgh, NRR

Inspection Team

TMurley, NRR i

JSniezek, NRR ,

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GClainas, NRR

RCapra, NRR

CVogan, NRR

ETourigny, NRR

JCraig, NRR

. WRegan, NRR

GLapinski, NRR

BClayton, ED0

DVerrelli, RII

CJulian, RII

PFredrickson, RII

DStarkey, RII

DFlorek, R1

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SRI, Brunswick, RII

ACRS(3)

OGC (3)

Regional Administrators

Regional Division Directors

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EXECUTIVE SUMitARY .

INSPECTION REPORTS 50-325/88-200 AND 50-324/88-200 ,

BRUNSWICK STEAll ELECTRIC PLANT, UNITS 1 AND 2 f

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The Office of Nuclear Reactor Regulation performed a special team inspection of {

the Emergency Operating Procedures (E0Ps) at the Brunswick Steam Electric Plant l

(BSEP), Units 1 and 2 on September 26 through October 7, 1988. The inspection i

was based on o draft of thc E0Ps which were in the final stages of development  ;

and were expected to be implemented on December 15, 1988. The draft E0Ps  !

incorporated Revision 4 of the Boiling Water Reactor (BWR) Owners' Group '

(EWROG) Emergency Procedure Guidelines (EPGs). They corrected deficiencies

which had been identified during an Operational Safety Assessment and a

Probabilistic Risk Assessment based inspection [ Inspection Reports '

50-325(324)/88-19 and 50-325(324)/88-11] performed by Region II on the E0Ps

presently in use.

The inspectors were impressed with the scope of the corrective actions taken in 4

response to the deficiencies identified during the previous inspections and  ;

with the licensee's controls for the development of the E0Ps. All of the 3

previously identified deficiencies had been corrected, and the development

process was well documented and defined.  !

The E0Ps were developed as post-trip recovery procedures and integrated the

post-trip operator actions with the required actions of the BWR0G EPGs and

Station Blackout procedure. The E0Ps provided a high level of detail and

prioritized the operators' actions based on the significance of the event. As

a result of this methodology, however, the E0Ps had a significant potential to

delay the required accident mitigation actions as the event-based, post-trip

recovery actions were accomplished. In addition, the inspection team

concluded, based on the simulator scenarios, that the required EPG actions

could not be accomplished in a timely manner without the direct involvement of

both the shift foreman and the shift technical advisor to read and perform the

E0P action steps. The active participation of these individuals was not in

accordance with the licensee's administrative instructions, but was considered

by the team to be an adequate method of E0P accomplishment.

The inspection team determined that the draf t E0Ps did not in every instance

represent a technically accurate incorporation of the BWROG EPGs and would not

adequately assure the successful accomplishment of all specified actions

because several procedures had a low probability of success and several

calculational errors were identified. For example, the level / power control

procedure was deficient because pressure and temperature compensation factors

had not been provided for the use of reactor pressure vessel (RPV) level

instruments in the fuel zone range, and because an unjustified deviation of

+8.44 inches had been taken in the designation of the top of active fuel (TAF).

The containment flooding procedure was deficient because an inaccurate method

for level measurement was developed. The alternate boron injection procedure

was deficient because the amount of poison required was incorrectly calculated.

The cmergency actions for containment drywell temperature control would

potentially be delayed because of the method of temperature measurement.

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Future licensee action is necessary to upgrade the draft E0Ps prior to their .

implementation. These actions should include: (1) reduction in the con.plexity l

of the E0Ps and removal of event-based actions from the E0Ps, (2) a review of

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all calculations for accuracy. (3) completion of the verification and valida-

tion program to identify and correct similar errors not identified by the

inspection team, and (4) evaluation of the validation program as it relates to

the use of simulator exercises in light of the limitations of the simulator

modeling capabilities.

Several of the inspection team's concerns Effected the E0Ps which were being

implemented at the time of the inspection. These E0Ps were based upon

Revision 2 of the BWROG EPGs. This includes RPV level measurement and

drywell temperature control. The licensee was advised to take immediate

action to evaluate and correct these operational concerns.

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