ML20235R331
| 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: |
| References | |
| NUDOCS 8903030259 | |
| Download: ML20235R331 (6) | |
See also: IR 05000324/1988200
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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February 23, 1989
Docket Nos. 50-325, 50-324
Mr. E. E. Utley
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Senior Executive Vice President
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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
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(IllSPECTION REPORTS 50-325/88-200AND50-324/88-200)
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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
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existing equipment, controls, and instrumentation; and that the procedures had
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the useability necessary to provide the operator with an effective accident
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mitigation tool. The inspection team reviewed the draft E0Ps which were based
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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 technical inaccuracies and determined
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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
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accomplishment of all specified actions.
For example, the level / power control
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procedure, containment flooding procedure and containment venting procedure
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were adversely affected by the methods used to measure reactor and containment
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water levels. The inspection team concluded that the E0Ps could be performed
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by the operating staff; however, the method used differed from those specified
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by administrative procedures.
As a result, the shift foreman alone could not
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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
electrical power to the containment vent valves.
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8903030259 890223
ADOCK 03000324
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Mr. E. E. Utley
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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
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-
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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
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which were in use at the facility during the inspection, as well as the concerns
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related to the E0Ps that are currently in effect. All of the-inspection
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team's concerns are detailed in the enclosed inspection report. Some of.the
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items identified by the team may be potential enforcement findings. Any
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enforcement actions will be identified by Region II in separate correspondence.
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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
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February 23, 1989
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cc:
Mr. P. W. Howe
Mr. J. L. Harness
Vice President
Plant General Manager
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Brunswick Nuclear Project
Brunswick Steam Electric Plant
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
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Raleigh, North Carolina 27602
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Mr. Mark S. Calvert
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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
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Raleigh, North Carolina 27626
Ms. Grace Beasley
Board of Commissioners
P. O. Box 249
Bolivia, North Carolina 28422
Mrs. Chrys Baggett
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State Clearinghouse
Budget and Management
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116 West Jones Street
Raleigh, North Carolina 27603
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Resident Inspector
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U. S. Nuclear Regulatory Conunission
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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
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Division of Facility Services
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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
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February 23, 1989
Distribution:
(w/ encl)
Docket Files 50-325/324
DRIS R/F
RSIB R/F
LPDR
BKGrimes, NRR
CJHaughney, NRR
JEKonklin, NRR
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CVanDenburgh, NRR
Inspection Team
TMurley, NRR
JSniezek, NRR
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GClainas, NRR
RCapra, NRR
CVogan, NRR
ETourigny, NRR
JCraig, NRR
WRegan, NRR
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GLapinski, NRR
BClayton, ED0
DVerrelli, RII
CJulian, RII
PFredrickson, RII
DStarkey, RII
DFlorek, R1
SRI, Brunswick, RII
ACRS(3)
OGC (3)
Regional Administrators
Regional Division Directors
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0FC
- RSIB:DRlS:NRR
- RSIB:DRIS:NRR :RSIB:DRIS:NRR :D:
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EXECUTIVE SUMitARY
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INSPECTION REPORTS 50-325/88-200 AND 50-324/88-200
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BRUNSWICK STEAll ELECTRIC PLANT, UNITS 1 AND 2
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The Office of Nuclear Reactor Regulation performed a special team inspection of
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the Emergency Operating Procedures (E0Ps) at the Brunswick Steam Electric Plant
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(BSEP), Units 1 and 2 on September 26 through October 7, 1988. The inspection
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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
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incorporated Revision 4 of the Boiling Water Reactor (BWR) Owners' Group
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(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
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presently in use.
The inspectors were impressed with the scope of the corrective actions taken in
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response to the deficiencies identified during the previous inspections and
with the licensee's controls for the development of the E0Ps. All of the
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previously identified deficiencies had been corrected, and the development
process was well documented and defined.
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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
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implementation.
These actions should include: (1) reduction in the con.plexity
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of the E0Ps and removal of event-based actions from the E0Ps, (2) a review of
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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