ML20084F916

Answers to Joint Intervenors Interrogatories & Request for Production of Documents to Applicants on Joint Contention I (First Set).Certificate of Svc Encl.Related Correspondence

ML20084F916
Person / Time
Site:	Harris
Issue date:	05/01/1984
From:	Sean Flynn CAROLINA POWER & LIGHT CO.
To:
References
OL, NUDOCS 8405040361
Download: ML20084F916 (189)

Text

REtATED CONRES?ONDENCE May 1,1984 000KETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS$NAY -4 A10:34 BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD ry _c., -

II $

In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL

)

(Shearon liarris Nuclear Power Plant, )

Units 1 & 2) )

APPLICANTS' ANSWERS TO JOINT INTERVENORS INTEltROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO APPLICANTS ON JOINT CONTENTION I(FIRST SET)

Applicants Carolina Power & Light Company ("CP&L") and North Carolina Eastern Municipal Power Agency, pursuant to 10 CFR S 2.740b, hereby submit the following responses to " Joint intervenors Interrogatories and Request for Production of Documents to Applicants on Joint Contention I(First Set)." The provision of answers to these interrogatories is not to be deemed a representation that Applicants consider the information sought to be relevant to the issues to be heard in this proceeding.

ANSWERS TO GENERAL INTERROGATORIES ANSWER Gli (a) The followhg list identifies those persons who provided information upon which Applicants relied in answering the interrogatories on Joint Contention I and indicates the particular interrogatory answer for which such person provided information:

8405040361 840501 PDR ADOCK 05000400 G PDR QSO3

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I r

INTERROGATORY TECHNICAL CONTACT (S) 1-1 through 9 Sherwood Zimmerman a

Ronnie Coats

! Joe Harness Blaine Rieck Bill Hindman I-10 John Eads 1-11 through 12 Wayne Ennis Ron Brown l Ronnie Coats Mike Jones 1-13 through 15 Ronnie Coats John Eads 1-16 through 21 Ronnie Coats l I-22 Henry Oehman Joe Harness Blaine Rieck Bill H!ndman 1-23 John Eads

' 1-24 Ronnie Coats i 1-25 Henry Oehman i

1-26 John Eads Ronnie Coats i

i 1-27 Ronnie Coats Joe Harness Blaine Rieck Bill Hindman I Wayne Ennis/Mac Harris i

J I-28 (a & b) Ron Brown (c f) Ron Brown 3

(g) Jim Deaton (h) John Eads I-29 Joe Harness Henry Oehman Ronnie Coats 4

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1-30 (a-c) John Eads (d) Joe llarness (e) Joe llarness Ronnie Coats Ray Hanford (f-g) Joe Harness (h-m) Jack Hammond (n-q) John Eads (r) 1-xxyl Joe Harness Ronnie Coats (r) xxvil-xxix Ronnie Coats (r) xl-end Ronnle Coats 1-31 Ron Brown 1-32 through 33 Bob Stancil 1-34 through 37 Ron Brown 1-38 Bob Stancil 1-39 (a-h) Jim Deaton (1-j) Malcolm Holmes Bob Stancil (k-1) Bob Stancil (m-n) Wayne Ennis John Eads (o-s) Manley Pope (u-x) Manley Pope 1-40 Ronnie Coats Joe liarness 1-41 Ronnie Coats Sam McManus Ray Hanford I-42 Ronnie Coats 1-43 Joe liarness 1-44 Ronnie Coats 1-45 Fred Tollison 1-46 (a-f) Ronnie Coats (g) Dave Fleshood R. B. Richey (h) Ronnie Coats I (j) Ronnie Coats i

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1-47 (a-b) John Eads (e-end) Ronnie Coats  ;

l-48 through 49 Ronnie Coats 1-50 Blu Hindman Jim Nevnt Peggy Morris 1-31 Ronnie Coats 1-52 through 54 Murray Johnson 1-55 Henry Oehman I-56 through 57 Joe Harness 1-58 Ronnie Coats 1-59 Joe Harness 1-60 Ronnie Coats 1-61 Joe llarness 1-62 through 65 John Ends 1-66 through 67 Bill Hindman 1-68 through 69 Joe Harness I-70 Joe Harness Ronnie Coats 1-71 John Eads Joe llarness I-72 (a-c) John Each (d) Dr. Tom Elleman I-73 Ronnie Coats I-74 through 75 John Ends l-76 Fred Tollison 1-78 Bob Stanell Ron Brown ~

Wayne Ennis I-79 Wayne Ennis

.3

John Eads I I-40

! Henry Oehman  :

John Walker i 1-81 through 83 Ron Brown -

}

f 1-84 Bill Hindman

(

l-85 Dr. Tom Elleman l  ?

I l-86 Joe llarness [

1-87 John Walker i Joe Harnem 1-88 John Walker I

Joe llarness l-89 through 95 Murray Johnson  !

l-96 Dr. Tom Elleman 1-97 through 99 Murray Johnson l-100 Bob Stanell Lynn Farmer ,.

(b) See Answer Ol(a) i ANSWER G2: ,

(a) Applicants have not yet identified the expcet or other witnemes they expect to call in this proceeding regarding Joint Contention 1. When and if such witnemes are identified, Appilonnts will supplement this response in a timely manner.

(b) See Answer 02(a). ,

ANSWER 03:  !

(a) Documents relled upon by Appliennts are either identified within each response to the speelfle interrogatories or will be provided for Joint Intervenors inspection upon rept as stated in the various responses.

(b) See Answer 03(a).

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ANSWER 04:

(a) See Answer 03(a).

(b) See Answer 03(a). ,

ANSWER 05:

(a) Applicants have not at this time identified which documents, if any, they intend to use in cross-examination of witnesses presented by Joint Intervenors and/or the NRC Staff on Joint Contention 1.

ANSWER 06:

Applicants have no such information.

ANSWERS TO INTERROGATORIES ON JOINT CONTHNTION I l

ANSWER l-l through I-Si The following documents, whleh pertain to regulation of Appliennts' nuclear units by the U.S. Nuclear Regulatory Commission new! which contain Information responsive to these Interrogatorien, will be mndo nvallable for Joint Intervonors' inspection at CP&L's General Offico upon request Document Dewrlotion Datae NRC Irmpection Reports and CP&l, Resporwes 1978 to prencnt

! (llarris)

NRC Irmpection Reports and CP&L Respoewes 1976 to present (Ilrunswick)

NRC Irmpection Reports and CP&l. Respotwos 1975 to present (Robinson)

SALP Reports and CP&L Responses covering periods l

i 7/80 12/91 l 1/s2 1/s3 Licensee livent Reports (llrunswick) 1974 to present l 1976 to present I l.leengee Event Reports (Robitwon)

Reports of occurrences reportable tmder 1978 to present 10 CPR 5 50.55(e)(Harrin)

Reports of occurrences reportable uruler 1976 to present 10 CFR 550.55(e)(Urunswick)

Reports of occurrences reportable under 10 CFit Part 21 (llarris) 1978 to present Reports of occurrences reportable under 1976 to present 10 CFR Part 21(Brunswick)

Reports of occurrences reportable uruler 1979 to present 10 CFR Part 21 (Robinson)

Summary Exposure Reports required tmder 1976 to present 10 CFR $20.407 (Brunswick)

Summary Exposure Reports required under 1978 to present 10 CFR 520.407 (Robinson)

Semlannual Radioactive Effluent Itelcano 1976 to present Reports required under Iteg. Guido 1.21

! (Urunswick)

Seminnnual Radioactive Effluent Rolcaso 1978 to present Reports required under Reg. Guido 1.21 (Robinson)

' Documents rotating to civil penalties lovled against Applicants sineo 1982 by the State of South Carolina under regulations pertaining to radioactive wasto shipments will also be mado available for Joint Intervenors' trupection at l

CP&Us General Offlee upon request. Additionally, documents relating to exceedences of NPDl3 permit offluent limitations sinco 1970 pertaining to the llarris, Itobinson and Brunswick Plants will bc nado available for Joint Intervenors' inspection at CP&Us General Office upon request.

ANSWElt 1-4 through I-R Applicants interprot these Interrogntories as referring to occurrences related to operation of their nuclear units. To the extent that any such occurrences are riflected in the documents provided in ros1xmso to intorrogntory 1

1 Nos.1-1 through I-5, referenco should be mndo to the documents themselves. In addition, the final orders of the North Carolina Utilities Commission and um South Carolina Publio Service Commission in the following dockets contain langungo that can be Interpreted as responsive to these Interrogatories 7

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1 NCUC ORDERS l l

Case Docket No.  !

l I 1981 N.C. Rate Case Docket E-2, Sub 418 i

. 1982 N.C. Rate Case Docket E-2, Sub 444 l 1943 N.C. Rate Case Dooket E-2, Sub 461 i October 1980 N.C. Fuel Clause Case Dooket E-2, Sub 402 l SCPSC ORDERS l

I Case Dooket No.

1982 S.C. Mate Case Docket al-183-E, ,

Order No.82-284 l 1983 S.C. Rate Case Docket 82-328-E, l Order No.83-583 August 1981 S.C. Fuel Clause Case Docket 79 7-E,  !

Order No.81-596 September 1982 S.C. Fuel Clause Case Docket 79-7-E, l Order No.82-680  ;

i Copies of these orders will be made available for Joint Intervenors' Inspection at CP&Us General Offlee upon request.

ANSWER l-9:

Apptleents,have no knowledge of any oceurtenees that were required to be reported to the NRC that have not beesi reported. (See response to j intereogatory No.1-30(f-s)). ,

ANSWER l-10:  ;

The design basis for Brunswick and for Robinson is different from that of Harris ami different from one another. The applicability of safety requirements, rerstations or restrictions to the Isrunswlok, Robinson, and Harris nuclear plants is detailed in their respective Final Safety Analysis Reports t (FSAR), copies of whleh will ue made avallable for Joint Intervonors' inspeetion at l CP&us General Offlee upon requeet. As part of the regulatory process, the NRC has required beektitting of seleeted requirements for already Indit plants. The l NRC may, at any time, require beektitting of a facility in aseerdance with le 1

.g.

CFR 50.109 if such action "will provide substantial, additional protection whleh is required for the public health and safety or the ammon defense and security." l ANSWERS l-11 and 1-12:

The fouowing list identifies testimony that contains discussions  :

relating to problems at Brunswick and Robinson from 1979-1984. The transcripts and profiled testimony of these witnesses will be made available fbr Joint Intervenors' inspection at CP&L's General Office upon request. ,

N.C. Rate Cases Case Witnesses  ;

E-2, Sub 431 (1984) P.W. Howe, J.M. Davis, M.A. McDuffie, S.H. Smith i E-2, Sub 481 (1983) L.W. Eury, S.H. Smith, M.A. McDuffie i E-2, Sub 444 (1982) L.W. Eury, M.A. McDuffle, B.J. Furr, S.H. Smith, R.M. Coats E-2, Sub 416 (1981) 5.H. Smith, L.W. Eury, BJ. Furr E-2, Sub 391 (1980) 5.H. Smith E-2, Sub 368 (1979-80) 5.H. Smith N.C. Fuel Cases ,

Case Witnesses  ;

E-2, Sub 446 B.J. Furr E-2, Sub 434 L.W. Eury E-2, Sub 420 B.J. Furr E-2, Sub 383 B.J. Furr/J.B. McGirt E-2, Sub 380 B.J. Furr I

S.C. Rate Cases Cane Witnesses ,

82-328-E (1983) 5.H. Smith, R.M. Coats

$1-163-E (1982) 5.H. Smith 80-69-E (1980) 5.H. Smith, R.B. Starkey 5.0. Fuel Cases (79-7-5)

SMf, Witstesses March 27,1984 R.M. Costs September 27,1983 R.M. Coats March 29,1983 TJ. Eueman September 28,1982 R.M. Coats ,

l .g.  !

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August 24,1981 L.W. Eury September 23,1980 R.A. Watson Other Hearings Case Witnesses HBR Steam Generator - J.J. Sheppard Docket 50-261-OLA T.F. Timmons (Westinghouse)

Harris ASLB Remand E. E. Utley Hearing - Docket Nos. H. R. Banks 50-400,50-401,50-402 M. A. McDuffie 50-403 J. A. Jones Applicants will also make available copies of press releases (Company statements generally mailed or released to the media), media inquiry forms (internal News Services documents that reflect information given to a reporter (s) in response to a specific question or questions), and Infobulletins (informational bulletins prepared and distributed to CP&L offices which generally reflect Company statements or positions given to the media), which contain information about problems at Brunswick or Robinson Unit 2 for Joint Intervenors' inspection at CP&L's General Office upon request.

ANSWERS I-13 and I-14:

The Company's organization with respect to nuclear plant design, construction and operation through March 1979 was discussed in detail in the Ilarris ASLB remand hearings and is set forth in the record of that hearing.

Since March 1979, the Company's organization with respect to nuclear plant engineering, construction, operation, and support has been described in detailin a series of Management Capability Reports w5 ich were submitted to the l

NRC and dated August 1979, September 1980, July 1981, August 1983, and 5.

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January 1984, respectively. ,

Copies of these reports will be made availabih for Joint Intervenors' inspection at CP&L's General Office upon request.

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In addition, organizational changes have been discussed in rate case l

testimony before the South Carolina Public Service Commission and North Carolina Utilities Commission. The following witnesses discussed organizational changes:

N. C. Rate Cases Case Witnesses Docket E-2, Sub 481 (1984) M. A. McDuffie Docket E-2, Sub 461 (1983) L. W. Eury, S. H. Smith Docket E-2, Sub 444 (1982) M. A. McDuffie, B. J. Furr, L. W. Eury Docket E-2, Sub 416 (1981) L. W.' Eury, B. J. Furr S. C. Rate Case Docket 82-328-E (1983) S. H. Smith Copies of these transcripts and prefiled testimony will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

! Over the years of CP&L's involvement in nuclear power, CP&L's

organization has experienced significant growth. The structure of. CP&L's organization has been modified when appropriate to accommodate that growth as well as changes occurring in the nuclear industry. In developing and implementing any reorganizations or reassignments during this period, CP&L's major objective i

has always been that of maintaining and/or improving its ability to engineer, construct, operate, and maintain its nuclear - plants in a safe, reliable, and ,

! efficient manner and in full compliance with applicable regulatory requirements.

i In developing and implementing organizational changes, CP&L has been attuned not only to immediate organizational needs but also to the need to' develop its organization and personnel in an orderly and logical manner in order to facilitate future growth.

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Each manager / supervisor has an inherent responsibility to develop his assigned organization and personnel in a manner that provides for satisfactory accomplishment of assigned responsibilities now and in the future. Thus, the need for organizational changes may be identified at various levels of responsibility within the Company. The Company provides for review and approval of changes at succeeding management levels up to and including the Company's Senior Management. The approval level will vary depending on the change being proposed.

ANSWER I-15:

Company records regarding approval of organizational changes since January 1981 will be made available for the Joint Intervenors' inspection at CP&L's General Office upon request. Records relating to the years prior to 1981 are not accessible without undue burden.

ANSWER I-16:

Attachment 1-16 provides the information requested in the first sentence of Interrogatory No.1-16 for the years 1977 through 1983. Records of outages prior to 1978 are not accessible without undue burden.

Whenever a nuclear unit is taken out of service, appropriate general office management personnel are notified. The timing of such reporting depends on the reason for the outage. Because scheduled outages are planned, management personnel up to and including the Executive Vice President - Power Supply and Engineering & Construction are aware of the outage in advance. In the case of a forced outage, notification to the general office is normally made by phone as soon as reasonably possible. The notification sequence may vary depending on personnel availability and the nature of the outage. in any case, during normal working hours, the Senior Vice President Nuclear Generation and/or j l

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the Executive Vice President Power Supply and Engineering & Construction are j normally advised of a forced outage within a few hours of its occurrence.

In addition, daily reports (Monday - Friday) that document the status of allof our units are provided to other management personnel.

ANSWER I-17:  !

CP&L files a monthly report with the North Carolina Utilities i

Commission that documents the reasons for off-line outages and the remedial

(

action taken. These reports were initiated in May 1978. Copbs of these reports will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

ANSWER I-18:

See Attachment I-16 for the definition of planned outages and identification of planned outages since 1977 for each of CP&L's nuclear units.

Attachment 1-18 compares the scheduled versus actual duration of these planned outages and summarizes the reasons for any extension of the originalschedule.

Copies of the outage reports for those planned outages identified in Attachment I-18 for which outage reports were written will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

ANSWER I-19:

Limitations on plant output can occur due to various reasons such as (1) unit outages, (2) routine equipment related limitations (such as a pump out of service for maintenance), (3) other plant conditions (such as condenser cooling water temperature or fuel preconditioning limits at Brunswick), and (4) restrictions due to regulatory limitations.

Limitations relative to (1) above are included in response to Interrogatory No.1-16. Limitations related to (2) and (3) are routine operating

occurrences. Identification of such limitations as requested is not practical and would be extremely burdensome. Limitations associated with item (4) are discussed below:

Robinson Unit 2 During the period from May 16,1973 to July 25,1973 Robinson Unit 2 was limited to approximately 95% power due to a generic concern related to fuel densification. The limitation was removed when special core surveillance equipment was installed and approved for use. This concern was fully resolved at the end of cycle 2 by replacing core regions 2 and 3 with new fuel not subject to the densification phenomenon.

During the period from September 2, 1981 to November 6,1981 Robinson Unit 2 was limited to a power level of approximately 50%. This reduction was established in order to reduce steam generator hot leg temperatures to reduce the rate of tube corrosion. During the period of November 6,1981 to November 19, 1981 the unit was shut down to make instrumentation set point changes. Following this outage, the unit was limited to approximately 80% power until it was chut down on January 26, 1984. Steam generator replacement is currently in progress.

Brunswick Unit 1 During the period from August 30,1979.to September 1,1979, Unit I was limited by approximately 10% due to a rotated fuel bundle. The limitation was lifted after analyses were completed to verify the acceptability of operation with the rotated bundle. ,

I Brunswick Unit 2 During the period of August 1981 through April 24, 1982, output from Brunswick Unit 2 was limited to comply with technical specification limits on off-

gas activity releases. The off-gas releases were due primarily to leaking fuel bundles in the originally installed 7x7 fuel bundles that remained in the core at that time. Reductions ranged from 10 - 30% at various times during this period.

The remaining 7x7 fuel bundles were removed during the outage that began on April 24,1982.

ANSWER I-20:

Documents relating to the limitations discussed in Applicants' response 1 to Interrogatory No.1-19 will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

ANSWER I-21:

See response to Interrogatory No. I-13.

ANSWER I-22:

i i CP&L maintains an Employee Handbook for all employees. This q

! handbook identifies 14 personnel policies that apply to all employees of the Company. In addition, the Company maintains a Standard Personnel Practices Manual which further amplifies and helps explain the 14 Company policies. The first manual covering Company policy and personnel practices was published in January 1947. Since that time it has been revised and reprinted 13 times. CP&L does not routinely maintain any of the prior printings of the manual; however, some copies of previous manuals may be available from individuals in Employee Relations or other departments. Those known to exist will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. In October 1981 the Company developed a separate policy manual for construction craft employees. This manual became part of : the Construction Craft Employee 4

Handbook published for craft employees. The use of the Construction Craft Handbook has been discontinued and all employees are covered by the Standard -

Personnel Practices Manual. These manuals will be made available for Joint Invervenors' inspection at CP&L's General Office upon request.

In addition to these two manuals, two programs, which are

. amplifications of Company policy, should be mentioned. The first is the Drug and Alcohol Abuse Procedure. This procedure explains the details of the policy statement in the Employee Standard Personnel Practices Handbook on drug and alcohol abuse as applied to all employees working at a nuclear project and those other employees requiring unescorted access. In addition, the Company maintains

, a procedure of personnel screening for unescorted access to the protected and vital areas of the nuclear plant. This procedure identifies the screening requirements for employment of applicants and the screening prior to placement of employees into a nuclear unit. Both of these procedures are designed to enhance the security of the nuclear plants by assuring the reliability, trustworthiness, and stability of employees working within those nuclear units, i Copies of these procedures will be made available for Joint Intervenors' inspection i at CP&L's General Office upon request.

The Conduct of Nuclear Operations Manual was prepared in 1982 and 1983 in support of CP&L's management's desire and direction to achieve greater consistency at CP&L's nuclear facilities with respect to programs, methodology, and practices to be utilized in the management of the nuclear facilities.

The manual contains a codification of the philosophy and executive directives regarding performance, responsibilities, management, and operations.

It further defines nuclear operations programs and methodology that are instituted to achieve consistency in practices within the three nuclear plants and defines organizational functions and interfaces.

Chapter 4 of the manual was developed in futherance of CP&L's belief .

that an essential part of nuclear operations management control is that the l

i intentions, desires, and opinions of management be articulated through specific j management concepts, statements, and policy interpretations. Examples of the subjects that are covered in this section are safety, housekeeping, responsibilities and accountabilities, management attitudes, control room discipline, discipline of

operators, nuclear operational consistency, and integrity.

ANSWER I-23:

See Applicants' Management Capability Reports dated August 16, 1979, September 22,1980, July 31,1981, August 4,1983 and January 10,1984; in addition, see Section 13.1 of the FSAR.

ANSWER I-24:

Attachment 1-24 is a summary of the staffing levels for the Brunswick i

and Robinson plants operating staffs for the period 1978 to July 1983. The summary c'etails the authorized level of employees by major functional classifications and presents the actual number of employees on a total plant basis. Data necessary to respond in the detail requested is not readily available and would be burdensome to retrieve.

In the fall of 1983, CP&L instituted a computerized Personnel Inventory Tracking System (PITS) that can provide the type of detail requested. A

copy of the PITS report for year-end 1983 will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. Historical data that existed prior to the implementation of PITS has not been backfitted into the system. The PITS report referenced above provides the detail requested for each

! of the Nuclear Projects, which includes the operating organization.

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ANSWER I-25:

CP&L does not maintain records in the form requested in Interrogatory No.1-25.

ANSWER I-26:

The following reports are nonroutine, formal management studies concerning the safety or operation of Applicants' nuclear units which will be made available for Joint Intervenors' inspection at CP&L's General Office upon request (see response to Interrogatory No.1-51):

- United Engineers & Constructors, Inc. " Brunswick Steam Electric Plant t Units 1 & 2 Design Decisions"

- A. Ronald Jacobstein " Investigation of Carolina Power & Light Company Brunswick Steam Electric Plant"

- Analysis & Technology, Inc. "An Evaluation of Carolina Power & Light Company's Nuclear Operator Training Program"

- Lapp, Inc. " Assessment of the Health Physics Program at the Brunswick Steam Electric Plant"

- General Electric " Management Team Review of the Brunswick Site Operations"

- Management Analysis Company "An Evaluation and Audit of the Carolina Power & Light Company Quality Assurance Program and Its Implementation During Construction and Operation of Its Nuclear Power Plants"

- NRC Performance AppraisalTeam Report

- INPO Evaluation Reports for the Robinson and Brunswick plants for the years 1981-1983 and the Harris Self-Initiated Evaluation Report dated December 10,1982.

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ANSWER I-27:

l (a-d) Statements 1-51 were made by Messrs. Jones, McDuffie, Utley, or Banks as identified in the transcripts of the Harris Remand Hearings. These statements were made under oath. All of these individuals, with the exception of Mr. Jones, are currently employees of CP&L. Mr. Jones retired on October 1, 1982 and has contracted with CP&L to perform various consulting functions in the area of corporate nuclear activity since his retirement. The three remaining individuals all hold different positions now than they did at the time of the Harris Remand Hearings. In 1979, Mr. McDuffie was Senior Vice President - Engineering and Construction; currently, he is Senior Vice President - Nuclear Generation.

Mr. Banks was Manager - Nuclear Generation in 1979; currently, he is Manager -

Corporate Quality Assurance. Mr. Utley was Senior Vice President - Power Supply Group in 1979; currently, he is Executive Vice President - Power Supply and Engineering and Construction.

(e-h) These statements were made in an open regulatory proceeding.

The transcripts and exhibits for the proceeding support the statements. Each such person was employed with CP&L in such a position as to serve as spokesperson for CP&L.

Applicants acknowledge that statements numbered 52 through 117 were contained in various news publications. Their accuracy . has not been verified. l (i-1) Details of follow-up action are outlined below: l l

Item 21 - See the Management Capability report which addresses .I organization and staffing at Harris.

Item 22 - Appropriate - inspections of work at Harris have been conducted as part of our Quality Assurance Program.

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l Item 27 - See the testimony of CP&L witnesses in hearings before the 1

North Carolina Utilities Commission. See response to Interrogatory No. I-ll.

Item 28 - Does not require CP&L follow-up.

Item 29 - See response to Interrogatory No. I-30(rXviii).

Item 32 - See the testimony of CP&L witnesses in hearings before the North Carolina Utilities Commission. See response to Interrogatory No. I-ll.

Item 37 - See the Management Capability report for a discussion of Applicants' current Quality Assurance Organization.

i Item 40 - Based upon modifications made to the fire protection system at Brunswick, the NRC issued a final Fire Protection Safety Evaluation Report on June 11,1980. On November 19, 1980, the NRC issued Appendix R to 10 CFR 50 which established new and additional fire protection criteria. Additional modifications to the fire protection system are planned and/or in progress in l

response to the revised criteria.

Item 50 - Does not require follow-up.

ANSWER I-28:

(a) Mr. Shearon Harris, 1969-1980 - resume provided as Attachment I-28 A.

Mr. Sherwood H. Smith, Jr.,1980 - Present - resume provided as Attachment I-28B.

(b) Education and professional experience are - identified in the.

> resumes provided. Through the Chairman / President's involvement in the listed nuclear industry organizations, he is . continuously informed of and involved in nuclear-related activities and issues critical to the industry.

(c) With the exception of expense records and a record of nuclear plant visits, CP&L does not retain any other records of the Chairman / President's

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past appointments, travel, telephone calls, daily activities, etc in a form that would permit Applicants to respond to this Interrogatory without undue burden. A record of the Chairman / President's visits to the nuclear plants has been maintained since 1981. A list of these visits is provided as Attachment I-28C.

(d) See response to Interrogatory No.1-28(c).

(e) See response to Interrogatory No. I-28(c).

(f) See response to Interrogatory No. I-28(a and c).

(g) Under the Agreements between CP&L and North Carolina Eastern Municipal Power Agency (NCEMPA), CP&L has full responsibility for constructing, operating and maintaining jointly-owned facilities. NCEMPA has the right to have an observer at each plant in which it has an ownership interest and CP&L keeps NCEMPA informed about matters relevant to the construction, operation and maintenance of jointly-owned facilities. Pursuant to the agreements between CP&L and NCEMPA, NCEMPA pays its proportionate share of the costs of constructing, operating and maintaining jointly-owned nuclear plants. Only in this sense does NCEMPA have a role in item (iv) " financing.

nuclear plants" and item (viii) " financing repairs needed to assure safety of nuclear plants it co-owns."

(i) The terms of the Agreements between CP&L and NCEMPA were arrived at through negotiations between the parties.

(ii) Not applicable.

(iii) Not applicable.

(h) Attached are resumes for the senior management executives other than the Chairman / President who have responsibilities regarding CP&L's nuclear facilities: Mr. E. E. Utley - Executive Vice President, Attachment I-28D; Mr. M.

A. McDuffie - Senior Vice President, Nuclear Generation, Attachment I-28E; and

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Mr. James M. Davis, Jr. - Senior Vice President, Operations Support, Attachment l-28F. Education and professional experience are identified in each resume.

Other than expense records and the record of nuclear plant visits for Mr. Utley, CP&L does not maintain any records of the executives' past appointments, travel, 4

telephone calls, etc. The record of nuclear plant visits for Mr. Utley is provided as Attachment I-28G.

A copy of CP&L's Management Capability Report as filed with the Nuclear Regulatory Commission for the Shearon Harris Nuclear Power Plant in Docket No. 50-400 and 50-401 will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. This document detait: CP&L's organization and personnel qualifications in all nuclear activities.

ANSWER I-29:

(a-d) CP&L does not possess a list of each person who has been hired as an operator or trainee at our nuclear plants since commercial operation of j those plants. A list of current operators and trainees will be made available for

Joint Intervenors' inspection at CP&L's General Office upon request.

(eX1-4) In compliance with NRC requirements, reactor operators must  ;

be licensed by the NRC at the plant at which they work. Based on an individual's background, varying levels of training and experience are required prior to taking the NRC licensing exams. CP&L does not tender applicants for the NRC l

examinations unless they have satisfied the applicable training and qualification l requirements for our plants.

Details of CP&L's training and qualification requirements, including retraining, and requalification, are discussed in the following references which will be made available for Joint Intervenors' inspection at CP&L's General Office l upon request:

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_...m, _

1. Plant Final Safety Analysis Reports (FSARs)

2. Training Instructions contained in the Plant Operating Manuals

3. Plant Technical Specifications 1

4. Training Manual for Nuclear and Fossil Operations Personnel l l

All licensed CP&L operators have passed their licensing exams in accordance with NRC criteria applicable at the time of their licensing. Current NRC requirements specify that each candidate tested must achieve a minimum total score of 80% with a score of 70% or greater on each section of the test.

(eXs-6) CP&L Management is not aware of any CP&L operators cheating on an NRC exam.

(eX7) CP&L policies ph k for disciplinary action for various reasons. There have been instances in which disciplinary action has been taken against operating personnel. Such action, when taken, has been in accordance with company policy. When employee action results in a violation of NRC j

regulations, disciplinary action taken as to the employee may be discussed in CP&L's response to the NRC's Notice of Violation which would, in turn, be provided in response to Interrogatories 1-1 through I-5. Any additional details

! regarding such actions are considered confidential. At no time has CP&L allowed an individual to remain in an operating position if there were questions regarding that person's fitness for duty (see response to Interrogatory No.1-39(p)).

(eX8-ll) Periodic retraining is required by the NRC. See response to a

(eX1-4) above.

(f) See responses to (eX1-11) above.

(gXi-ii) In addition to the documents referred to in pesponse to (eXI-4) above, CP&L requirements for employment of personnel, including testing requirements, are contained in policies established by the Company's Employee

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Relations Department. Documents containing these requirements will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.  !

i (gXiii) At all times the role of senior management with respect to selection of power plant operators has been to ensure that app'r opriate qualification and hiring criteria and training programs are established such that personnel placed in an operating position are qualified for the position in accordance with company policy and regulatory criteria. The criteria and programs so developed have been revised from time to time as required in order to ensure continued compliance with applicable regulations and company policies.

(h) See response to (a-d) above.

(j) No.

(k) Not applicable.

(1) CP&L's pay schedule for operators is established to be competitive within the industry. The pay schedule is reviewed at least annually and revised as appropriate in order to maintain Applicants' competitive posture.

(mXI-v) Applicants' response to Interrogatory No.1-24 identifies the number of reactor operators at Brunswick as of year-end 1983. Applicants do not possess a list of the number of operators who have left Brunswick, Robinson, or Harris, for any reason.

(mXvi) Many of the operators or operator trainees at Harris were hired for the Harris Plant but received training at either Robinson or Brunswick.  !

These personnel have been transferred to Harris on a schedule consistent with the schedule for completion of Harris and in a manner that has not adversely affected I the availability of operators at Robinson or Brunswick. As of March 30, 1984, there were 87 operating personnel at Harris (Auxiliary Operators (AO), Control Operators (CO), Senior Control Operators (SCO), and Foremen). Of these

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, e

personnel, 20 have had experience at Brunswick (eight were licensed at Brunswick) and 18 have experience at Robinson (seven were licensed at Robinson).

(mXvii) See response to (eX7) above.

l (n-p) Applicants have established security and background requirements for personnel who work in Applicants' nuclear plants. These requirements are included in Applicants' Security Plan which has been approved by the NRC. A copy of Applicants' screening program will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. Operators are included in this program and therefore have been appropriately screened.

ANSWER I-30:

(a) Copies of the testimony of CP&L witnesses in the Harris construction permit hearings and remand hearings will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

(b-c) Since 1979, CP&L has made numerous communications to NRC under oath pursuant to NRC regulations. Some of these communications could be ,

viewed as responsive to this interrogatory. It would be unduly burdensome,

! however, to locate and examine each such document to determine its content.

(d) The issue of the High Pressure Coolant Injection (HPCI) door annunciators was discussed extensively in the Harris Remand Hearings. A copy of the hearing record will be made available for Joint Intervenors' inspection at l.

CP&L's General Office upon request.

f As discussed in those hearings, when the issue of the HPCI doors was initially raised, CP&L took action to implement administrative requirements to keep the doors closed. The hearing record further indicates that when administrative controls were found to be inadequate, additional measures were taken in the form of adding annunciators to the doors that would alarm in the

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control room, thus alerting the operators if the doors were open. This modification was scheduled as part of the ongoing fire protection upgrade work.

Actual completion of the modification was accomplished in the spring of 1979.

(e) The watertight doors between the HPCI compartment and the RHR compartments are designed for normal access between the compartment and, therefore, are opened several times daily. In addition, plant procedures allow that one of these doors may be left open when maintenance and other functions are taking place in the HPCI compartment provided personnel are available to shut it in a fire or flood situation.

The opening of this door for other than normal passage makes the HPCI CO2fire suppression system inoperable due to opening up the compartment; therefore, a Limiting Condition for Operation (LCO) is established to assure its return to service and to monitor the time it remains open. In addition, routine tours are made to assure that the doors are maintained in the closed position as required by procedures.

The NRC is not routinely informed of the opening of these doors as this is a routine operation governed by the plant's license. ,

l (f) There have beEn events at Brunswick which the NRC has determined to be reportable but for which CP&L had not submitted an LER. Upon reevaluation of these events by CP&L, CP&L determined they were reportable and reported them in accordance with appropriate regulations. In addition, where these events were identified by the NRC, a violation was usually issued by_ the NRC and a nonconformance report (NCR) may have been issued by QA. NRC correspondence regarding such events is included in the documentation discussed in response to Interrogatory Nos. I-1 through I-8.

(g) There have been reportable events at Brunswick for which an LER

l was not submitted within the required time frame. Upon determination of the reportability o,f the events, CP&L notified the NRC and filed appropriate reports per applicable regulations. In addition, a violation may have been issued by the NRC or a nonconformance report may have been issued by QA on these events.

NRC correspondence regarding such events is included in the documentation discussed in response to Interrogatory Nos. I-l through I-9.

(h-j) CP&L Nuclear Plant LER totals are as follows:

Robinson 2 Brunswick i Brunswick 2 1970 13 1971 18 1972 19 21

- 2 1973 32 - 1 1974 1975 20 - 35 1976 21 9 165 1977 33 118 70 1978 32 95 83 1979 37 118 107 1980 29 92 120 1981 33 94 145 1982 19 152 144 1983 31 63 98 (k) CP&L does not segregate LERs into safety significant categories, such as those having " unusual safety significance". The LERs are reported in accordance with the criteria, format, and time limits specified in NRC regulations. CP&L's actions to correct problems and prevent recurrence is addressed in each LER. The NRC and CP&L's Corporate Nuclear Safety Section review the appropriateness of the corrective actions.

(1) See response to Interrogatory No. I-30(k).

(m) See response to Interrogatory No I-30(k).

(n)(i) Brunswick has experienced some instrument drift with various I

types of instrumentation. Evaluations of the instrument drift occurrences do not 1

l

indicate that the drift problem is out of line with industry standards or experiences. When trending indicates that instrument drift may be a problem with a particular instrument or type of instrument, an evaluation is normally performed to determine appropriate corrective actions which may include:

1. more frequent calibrations

2. establishment of a more conservative setpoint to assure safe actuation

3. replacement of the instrument.

Where instrument drift problems cause limiting conditions for operations as outlined in the technical specifications, an LER is generally required. LERs on instrument drift are included in the documentation made available in response to Interrogatory No. I-1.

(ii) There have been problems identified at Brunswick where moisture / corrosion caused instrumentation to become inoperable. These events i

i occurred mainly in the -17' elevation of the Reactor Building or other 'high moisture areas. As required by technical specifications, appropriate reports and/or LERs were submitted. These reports will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. In addition, an extensive program has been initiated by CP&L in accordance with IE Bulletin 79-OlB to assure the environmental qualification of designated equipment.

Completion of this program should minimize moisture / corrosion problems.

(iii) In accordance with the Brunswick Technical Specifications, several instruments may be taken out of service simultaneously as long as appropriate designated actions are taken. At certain times,- this is done in a planned sequence for planned evolutions (testing, preventive maintenance), while at other times it may be caused by either failed equipment or a combination of

i failed equipment and planned testing. Individual events which fall into these categories are reported to the NRC as required by technical specifications and NRC regulations. These reports /LERs will be made available for Joint l Intervenors' inspection at CP&L's General Office upon request.

(o) The moist climate at Brunswick was considered in design, installation, and procurement specifications by specifying the humidity the equipment would be exposed to. Special humidity conditions independent of the f site itself, such as saturated steam conditions or water spray, were also specified I

when appropriate.

Moist ambient conditions at the site have not of themselves, to the best of Applicants' knowledge, given rise to any unusual problems.

(p) General design criteria for electricalo instrumentation, and air handling equipment at Brunswick are detailed in the FSAR for the Brunswick plant. Specific criteria are also contained in the design specifications for such equipment. A copy of the FSAR and equipment specifications will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

A review of the equipment specifications to specifically identify design requirements related to salt or salinity in the environment at Brunswick has not been performed. During the design of Brunswick, however, CP&L's general approach was to tailor equipment specifications to reflect the environment in which the equipment was expected to operate._ Material requirements were specified based upon the process fluid with which the parts would normally come into contact. General environmental criteria such as humidity and temperature were also specified. Other general provisions, such as painting, galvanizing, or other protective coating were specified as deemed appropriate based on the specific equipment and its location within the plant.

l

During construction, equipment was stored in accordance with established storage procedures and criteria. Specific storage requirements ranged from outdoor storage to storage in environmentally controlled enclosures l

depending upon the particular equipment.

Additional information regarding corrosion problems that have been experienced at Brunswick is contained'in response to Interrogatory No. I-41(d-g).

(q) CP&L was aware of the salinity and corrosive nature of the cooling water at Brunswick. The corrosiveness was a major consideration in the selection of the materials for the condenser. The original materials of construction for the Brunswick condensers were 90-10 copper-nickel for both the tubes and tube sheets. Copper-nickel materials were selected based on recommendations by CP&L's architect / engineer and independent evaluations by CP&L. At the time the material was selected, copper-nickel was considered to be state-of-the-art material and was used extensively in seawater applications. The United Engineers evaluation and recomme'ndation will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. In selecting the materials for the Brunswick condensers, no specific consideration was given to the question of -

radiation exposure during replacement. As indicated above, the material selected was state-of-the-art at the time, thus the potential for replacement was deemed to be no greater than that for other materials considered.. CP&L recognized that condenser retubing might be required, however, and appropriate provisions were made in the plant design to facilitate such work when and if required.

CP&L upper management was aware of the use of copper-nickelin the original condensers. Messrs. J. A. "Ott" Jones and W. B. Kincaid approved that decision based on the fact that copper-nickel was the unanimous choice of experts in industry and other utilities for salt water service.

In May of 1981 an evaluation was completed on replacement of the Brunswick condensers. Modification of the condenser was considered necessary to i

minimize the potential for condenser in-leakage. In-leakage had been a problem at Brunswick and was due to several factors such as tube inlet and erosion, sulfide corrosion, and tube-to-tubesheet leakage. The modifications involve retubing the 1 condenser with titanium tubes, which are more corrosion resistant than copper-nickle, and replacement of the tubesheet with a recently developed integrally i

grooved tubesheet that provides increased protection against leaks at the tube-to-tubesheet joint.

l CP&L management was aware of and gave approval to the replacement decision. Any testimony by Mr. Smith as to the Brunswick condensers is contained in the transcripts referenced in response to Interrogatory No. I-11.

(r) (1-vii) Applicants refer the Joint Intervenors to the testimony '

and exhibits in the record of the Shearon Harris Remand

• Hearings wherein the -

subjects of the Augmented Off-Gas (AOG) System, problems related to explosions j in the system, and NRC limits with respect to the system were reviewed in detail.

(viii) CP&L decided to install new hydrogen recombiners on the front end of the off-gas system at the steam jet air ejector discharge. Installing

! the recombiner at this location reduces the hydrogen and oxygen concentrations at 1 the earliest possible point and thus minimizes the potential for explosions in the

! system. In addition, CP&L decided to replace the cryogenic distillation system with a charcoal absorption system. These modifications were completed in 1983 on Unit I and are being completed in 1984 on Unit 2. Documents regarding the regulatory and design history of the AOG System will be made available for Joint .

1 Intervenom' inspection at CP&L's General Office upon request. l 1

i

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l (ix) The AOG System is not needed to maintain the amount of l gaseous radicactive effluents released within 10 CFR 20 limits and 10 CFR 50 design objectives. ' Upon review of the Brunswick Semi-Annual Environmental and Effluent Release Reports for the period 1976-1983, the highest annual calculated j whole body exposure (utilizing the methodology contained in NRC Regulatory Guide 1.109-Calculation of Annual Doses to Man From Routine Releases of l Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, i Appendix I) to a member of the general public was 4.34 mrem (1983). The 10 CFR 3

50, Appendix I design objective for the Brunswick Plant is 20 mrem.

(x) An AOG System will reduce the amount of gaseous radioactive 4

effluents by increasing the radioactive decay time from the reactor to the J

effluent release point. As discussed in response to Interrogatory No. I-30(r)(ix),

gaseous effluent releases from the Brunswick Plant have not exceeded 10 CFR 20

. limits nor 10 CFR 50 design objectives during the operating history of the plant.

I i

(xi) The NRC has never imposed a license amendment or i condition on the Brunswick Plant which limits operation based upon an estimated or calculated amount of failed fuel.

(xii) In 1978, as part of the discussions between CP&L and NRC regarding the proposed modification and operation of the AOG System, CP&L- ,

committed to meet the numerical guidelines of 10 CFR 50, Appendix I in the 4

interim period prior to the operation of the AOG System. As part of this commitment, an amendment was made to the Brunswick Technical Specifications, Appendix B, to provide somewhat more restrictive gaseous effluent release limits. No violation of these limits occurred during this interim period.

j (xiii) The Brunswick Plant has never operated with one percent or I

i greater failed fuel.

i i

q

(xiv) The highest percentage of failed fuel that Brunswick Unit I has operated with was approximately .003 percent.

The ' highest percentage of failed fuel that Brunswick Unit 2 has operated with was approximately .041 percent.

These figures are based on the results of fuelinspections (sipping) at the Brunswick Plant. Documentation relative to the failed fuel determination will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

(xv) A small amount of contaminated material was inadvertently shipped to the Brunswick County landfill and local scrap dealers between 1978 and 1980. Plant administrative controls have been strengthened to prevent a recurrence of this event.

CP&L senior management was made aware of the presence of these small amounts of low-level radioactive material at these locations within one day of its discovery.

(xvi) Inadvertent shipments of slightly contaminated material from the Brunswick Plant occurred from mid-1978 through April 1980 until its discovery at the Brunswick County landfill.

(xvii) The presence of contaminated material at t'w!locallandfill and scrap dealers was first noted by a CP&L foreman and an NRC inspector, who promptly reported this information to management personnel.

(xix) No.

(xx) Approximately 0.0000038 curies of activity was recovered from the landfill. Somewhat less activity was recovered from the local scrap dealers.

(xxi) All low-level radioactive waste generated at the Brunswick

Plant is accounted for. This material is disposed of at state and NRC-licensed facilities in accordance with CP&L and NRC procedures.

(xxil) The fonowing is a summary of measures which CP&L has taken in response to the landfin concerns:

1. staff increases in the plant Health Physics organization

2. expansion of the Ilealth Physics training program for au plant employees

3. a lowering of plant background radiation levels

4. purchase of new Health Physics survey equipment and upgrade of existing equipment

5. Institution of additional administrative controls to reduce the volume of low-level radioactive waste generated at the Brunswick Plant (xxill) CP&L believes that the prompt and thorough corrective action with respect to the low level radweste disposal incidents was indicative of good management. See the response to Interrogatory No.1-30(rXxxil) for a summary of corrective actions resulting from this event.

(xxiv) The person in charge of record keeping at Brunswick as it relates to records required to be maintained by the NRC is the Document Control Supervisor. This position was established in 1983. - Prior to that, it was the Administrative Supervisor, but with a position reporting to the Administrative Supervisor having direct accountabuity. Generauy the same individual has been directly accountable for record keeping although he has held different titles during the period.

e

Some temporary record keeping has occurred in various locations at Brunswick but all required by the NRC to be retained ultimately are delivered to the Records File Room (Vault) and maintained under the control of the Document Control Supervisor.

(xxv) Ensuring that NRC-required tests are carried out is ultimately the responsibility of the Plant General Manager; however, specific responsibility assignments for various tests are made on a functional basis. In other words, the operating staff is responsible for operational testing, the maintenance staff is responsible for maintenance testing, etc. This functional responsibility assignment has been followed since the unit began commercial operation.

(xxvi) Maintenance controls related to testing are contained in 3

the Plant Operating Manual procedure RCI-02.4. The Technical Specifications Surveillance Test Scheduling and Tracking System provides the details of these

- procedures and references several other procedures that spell out detailed procedures in various area. Before 1984, the key procedures in this area were found in AI-21, Technical Specifications Surveillance Test Scheduling.

Additional controls are provided by the Quality Assurance Program via audits to ensure compliance with established procedures and testing schedules.

(xxvil-xxix) The Containment Testing Program for the !)runswick Plant involves numerous tests ranging from tests of individual lines and valves (Local Leak Rate Tests) up to and including a total containment test (Integrated Leak Rate Test). During the period of 1979-1982, integrated Leak Rate Tests that measure the leak tightness of the containment and penetrations as a whole were performed as required. Applicants assume that Interrogatory No.1-30(r)(xxvil-xxix) is directed at the failure to perform localleak rate testing of certain valves C

which was identified in July 1982. Reasons for the failure to test these valves has ,

been documented in the testimony of CP&L personnel in regulatory proceedings before the North Carolina Utilities Commission, the South Carolina Public Service Commission, and ln CP&L's May 2,1983 response to the NRC concerning this event. Copies of transcripts covering this issue and the May 2,1983 response to the NRC will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

Pursuant to CP&L's Corporate Nuclear Safety Program Policy Statement, it is a function of Senior Management to ensure that appropriate procedures and administrative controls are in place enabling operation of its nuclear units in compliance with applicable regulations. When CP&L determined that the procedures and administrative controls in place at Brunswick had not been sufficient to prevent this event from occurring, CP&L's senior management, in accordance with this policy, instituted the comprehensive corrective measures which are described in detail in CP&L's May 2,1983 response to the NRC and in the Brunswick Improvement Program.

(xt-xlvil) The issue of the turbine bearing failure that occurred in July 1961 on Brunswick Unit I has been exhaustively discussed in proceedings before the North Carolina Utilities Commission and the South Carolina Public Service Commission. The following CP&L witnesser discussed the turbine bearing failure NCUC Cases Witnesses Docket E-2, Sub 446 B. J. Furr Docket E-2, Sub 444 L. W. Eury, M. A. McDuffie, B. J. Furr, R. M. Coats Docket E-2, Sub 434 L. W. Eury Docket E-2, Sub 425 L. W. Eury

l Docket E-2, Sub 416 L. W. Eury, B. J. Furr SCPSC Cases Witnesses Docket 79-7-E L. W. Eury Copies of the transcripts and prefiled testimony for these hearings will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

(xlviii) A total of 2.26 man-rem was received in repairing the Brunswick turbine in 1981 as measured by self-reading pocket dosimeters.

Additionally, each individual's exposure was measured by thermoluminescence dosimeters. The exposure received is documented in the 1981 ALARA Job  !

Exposure Tracking Log.

(xlix) Given the need to repair the turbine, the radiation exposure could not have been avoided. Work in radiactively contaminated areas at Brunswick is performed under a Radiation Work Permit system. A Radiation Work Permit issued by Health Physics personnel establishes a prior assessment of radiation exposure levels, surface and airborne contamination levels, and protective equipment requirements for worker protection. Completed Radiation Work Permits will be made available for the Joint Intervenors' inspection at CP&L's Brunswick Plant upon request.

(1-11) The general nature of outage and modification work in any generating plant is such that there is a potential for some piece of equipment or i

j component to be damaged during the course of modification and/or repair. Such events would normally be documented through various sources such as equipment

maintenance records, inspection reports, and QA reports. Review of these various records systems to produce a list as requested would be burdensome and would not provide the kind of detail requested. Based on a general review of activities at l .

l

8 x

l Brunswick since 1981, A)plicants believe that the most significant event related to equipment damage was the Brunswick Unit I turbine bearing failure which is discussed in the testimony referenced in response to Interrogatory No.1-30(rXx1-xlvii).

While damage to equipment is not desirable, it isi inherent in the nature of the work regardless of the degree of planning and caution used.

Reasonable precautions are taken in the planning and conduct of Applicants' repair activities to prevent or minimize the potential for ' damage. IIowever, when damage to equipment occurs, appropriate action is taken to repair the damage and restore the equipment to St safe and proper operating condition.

(lii) CP&L is opposed to using capacity factor goals for establishing rates it may collect from its customers. It does not oppose capacity factor goals for the Brunswick Plant or any of its nuclear plants as an internal management tool, however. CP&L utilizes annual capacity factor goals for its nuclear plants as part of its corporate planning efforts. Such a goal, he'vever, is always subservient to an even more important objective which is to operate and maintain our nuclear units safely. At no time has the existence of capacity factor -

goals resulted in the unsafe operation of Applicants' nuclear plants.

Capacity factor goals are documented in CP&L's corporate and department goals, and performance with respect to those goals is monitored on a quarterly and annual basis.

ANSWER I-31:

Copies of portions of CP&L Minute Books covering Annual Meetings, Meetings of the Board of Directors, and Meetings of the Executive Committee of 1

the Board of Directors which concern the nuclear matters inquired about in Interrogatory No.1-31 will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. l

ANSWER I-32:

1 Copies of the requested documents for the period from January 1965 through March 1984 that have been filed with the SEC will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. In accordance with SEC rules and regulations, thesi filings are not made under oath.

ANSWER I-33:

i A copy of each prospectus or official statement related to the sale of (a) CP&L common stock, (b) CP&L preferred stock, (c) CP&L bonds, (f) CP&L nuclear plants or interest (s) therein, g., to NCEMPA, and (g) CP&L overseas .

finance notes will be made available to the extent possible for Joint Intervenors'

. inspection at CP&L's General Office upon request.

Generally, prospectuses or official statements are not prepared for (d)

CP&L notes, (e) CP&L commercial paper, (f) CP&L nuclear fuel trust (s), or (g) i CP&L nuclear fuel.

ANSWER I-34:

Set forth below is a listing of testimony and statements of the officers designated in response to Interrogatory No.1-34 to committees of the U. S.

Congress dealing with nuclear matters. The texts will be available for Joint Intervenors' inspection at CP&L's General Office upon request.

l DATE ITEM COMMITTEE / ORGANIZATION UNDER OATH 03/12/84 Response to Questions Subcommittee on Energy No Research and Production 02/09/84 Testimony Subcommittee on Energy Yes Research and Production 02/09/84 Summary Testimony Subcommittee on Energy Yes Research and Production l

l Committee on the Judiciary 03/02/83 Statement Yes

05/25/82 Statement Senate Agricultural Committee on Yes Rural Development, Oversight and Investigations 06/10/82 Statement Subcommittee on Energy, Yes Conservation & Power 10/21/81 Response to Senator James A. McClure and No Questions Senator Alan K. Simpson a

10/06/81 Statement and Summary Committee on Energy and Yes Statement Natural Resources 07/09/81 Statement Subcommittee on Energy Yes and the Environment 07/09/81 Summary Statement Subcommittee on Energy Yes and Environment 07/25/80 Statement Subcommittee on Energy Yes and Power 04/01/80 Statement Subcommittee on Energy Yes Research and Development 04/01/80 Summary Statement Subcommitt'ee on Energy Yes Research and Development i 03/14/80 Statement Subcommittee on Energy Yes and the Environment ANSWER I-35:

The Chairman / President, Mr. Sherwood H. Smith, Jr., has presented-testimony before committees of the U.S. Congress. Such testimony is identified in response to Interrogatory No.1-34. All such testimony was given voluntarily.

ANSWER I-36:

(a) Yes.

(b) 3004 Sandia Drive, Raleigh, North Carolina 27607.

(c) Yes.

(d) Yes.

(e) Yes. It has been CP&L's policy that its executives will retire at age 65.

(f) No.

(g) Mr. E. E. Utley.

(h) Yes.

(i) Yes.

(j) Mr. Jones has contracted with CP&L to perform various consulting functions in the area of corporate nuclear activity since his retirement in October 1,1982. Mr. Jones has been paid for his consulting work.

(k) No.

ANSWER I-37:

(a) Yes.

(b) It is unduly burdensome to review every document within those files to determine its content. By virtue of his position with the Company, it seems reasonable to infer that some of the documents relate to nuclear matters.

(c) As stated in (b) above, this would be unduly burdensome. It would be very difficult to segregate those items responsive to the interrogatory.

(d) No.

(e) Not applicable.

(f) Not applicable.

ANSWER I-38:

(a) Many departments within the Company are involved in the corporate decisions am,ociated with the planning of a new plant. The decisions regarding the planning of the Harris plant were made at the highest level of the Company. In 1971, when the Harris plant was announced, the following officers of the Company held positions having responsibilities with regard to the planning of the Harris plant: Shearon Harris, Chairman / President; J. A. Jones, Senior Vice President, Engineering and Operations; Sherwood H. Smith, Jr., Senior Vice

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l 1

President and General Counsel; R. S. Talton, Vice President, System Engineering and Construction; and Edward G. Lilly, Jr., Senior Vice President, Finance.

(b) CP&L contracted with the architect / engineer firm of Ebasco l

Services, Inc. to perform the detailed engineering and design of the Harris Plant.

The initial contract with Ebasco was signed by CP&L on September 1,1970. At that time, the persons in CP&L management who had responsibilities for the design of the Harris Plant were as follows: Shearon Harris, Chairman / President; Paul S. Colby, Senior Vice President, Operating and Engineering; J. A. Jones, Vice President, Power Supply; W. B. Kincaid, Manager, Power Plant Design; and Sam McManus, Manager, Nuclear Plant Engineering.

Due to the on-going nature of the plant design process and as a result of organizational changes within the Company, the following persons in CP&L management have also had responsibility for the design of the Harris Plant:

Sherwood H. Smith, Jr., Chairman / President; .E. E. Utley, Executive Vice President; M. A. McDuffie, Senior Vice President, Nuclear Generation; Alan B.

Cutter, Vice President, Nuclear Engineering & Licensing; and R. A. Watson, Vice i .

President, Harris Nuclear Project.

(c) A contract with Westinghouse Electric Corp. for the nuclear steam i supply systems (NSSS) was signed by CP&L on April 23, 1971. At the time the NSSS contract was signed, the following persons in CP&L management had responsibilities with regard to the contract: Shearon Harris, Chairman / President; J. A. Jones, Senior Vice President, Engineering & Operations; W. B. Kincaid, Manager, Power Plant Engineering & Construction; and Sam McManus3 Manager, Nuclear Plant Engineering.

(d) See response to subpart (b) above.

(e) CP&L has provided the construction management for the Harris Plant; however, the Company did contract with Daniel Construction Company on September 1,1972 to provide the necessary labor force. At the time the contract with Daniel was signed, the following persons in CP&L management had responsibilities for selecting the prime contractor: Shearon Harris, Chairman / President; J. A. Jones, Senior Vice President, Engineering & Operations; and W. B. Kincaid, Vice President, Power Plant Engineering & Construction.

(f) There have been numerous subcontractors involved in the Harris plant. The subcontractors identified in subpart (f) of Interrogatory I-38 were selected through the architect / engineer with approval by CP&L. Generally, the persons in CP&L management who have, over the duration of the project, participated in subcontractor selection for the Harris Plant were: Shearon Harris, Chairman / President; Sherwood H. Smith, Jr., Chairman / President; J. A. Jones, Executive Vice President; E. E. Utley Executive Vice President; M. A. McDuffie, Senior Vice President, Engineering & Construction; W. B. Kincaid, Vice President, Power Plant Engineering; Alan B. Cutter, Vice President, Nuclear Engineering;

! Sheldon D. Smith, Vice President, Power Plant Construction; and R. A. Watson, Vice President, Harris Nuclear Project.

(g) In 1974, following approval by the ASLB of an exemption for certain site work, the following persons in CP&L management had responsibilities with regard to on-going work at the site: Shearon Harris, Chairman / President; J.

A. Jones, Executive Vice President, Engineering, Construction & Operations; and .

l i

M. A. McDuffie, Vice President, Power Plant Construction.

(h) In December 1973, the Company requested an exemption from the AEC to allow certain site preparation activities. The exemption authorizing limited site work was granted in January 1974. At that time, the following

persons in CP&L management had responsibilities with regard to pecject licensing and site work at the Harris site: Shearon Harris, Chairman / President; J. A. Jones, Executive Vice President, Engineering, Construction & Operation; W. B. Kincaid, Vice President, Power Plant Engineering; Darrell V. Menscer, Vice President, i j

l Special Services; and M. A. McDuffie, Vice President, Power Plant Construction.

l (i) At the time the Company received a Construction Permit, the following persons in CP&L management had responsibilities with regard to 4

construction at the Harris site: Shearon Harris, Chairman / Chief Executive ,

Officer; Sherwood H. Smith, Jr., President; J. A. Jones, Executive Vice President; M. A. McDuffie, Senior Vice President, Engineering & Construction; and Sheldon f D. Smith, Manager, Power Plant Construction.

Due to the on-going nature of the plant construction activities and due l to organizational changes within the Company, the following persons in CP&L

! management have also had responsibility for construction at the Harris site: E. E.

l Utley, Executive Vice President, and R. A. Watson, Vice President, Harris Nuclear l

I

! Project.

l

{ (j) The Company announced cancellation of Harris Units 3 and 4 on j December 16, 1981. Decisions such as the cancellation of a generating unit i

require the participation of many departments within the Company. Decisions of i

j this nature are made at the highest level. At the time of the announcement, the j following executive officers of the Company had responsibilities with regard to l the decision: Sherwood H. Smith, Jr., Chairman / President; J. A. Jones, Vice i Chairman; Edward G. Lilly, Jr., Executive Vice President; William E. Graham, Jr.,

i Executive Vice President; and E. E. Utley, Executive Vice President.

(k) Harris Unit 2 was cancelled on December 21, 1983. The following

! executive officers of the Company had responsibilities with regard to the

?

i

i t

i cancellation of Harris Unit 2: Sherwood H. Smith, Jr., Chairman / President

• I Edward G. Lilly, Jr., Executive Vice President; William E. Graham, Jr., Executive i Vice President; and E. E. Utley, Executive Vice President.

(1) At this time, the executive officers of the Company who have I

responsibilities with regard to the Company's constuction program are as follows:

Sherwood H. Smith, Jr., Chairman / President; Edward G. Lilly, Jr., Executive Vice President; William E. Graham, Jr., Executive Vice President; and E. E. Utley, Executive Vice President.

The documentation "concerning" each of these decisions is extensive and was developed over a period of several years. Identifying all such documents would be unduly burdensome.

ANSWER I-39: _ ,,

(a) During the period that the Harris Plant was being designed, Mr. Talton was Vice President - System Planning. In that position, he was responsible for the design of the transmission system associated with the plant.

! He was also consulted about the type of cooling system that might be used for the i

, plant. The Company chose the cooling lake concept. The Company selected the present site .for the plant, in part, because it allowed a cooling lake to be constructed.

(b) CP&L does not have records available in a form that would enable Applicants to respond to Interrogatory No. I-39(b) without undue burden.

(c) Mr. Talton is employed as a consultant to CP&L. He is paid a fee by CP&L. His work involves negotiating with other entities for the possible acquisition by those other entities of interests in CP&L facilities.

1 (d) Yes, Mr. Talton did work for CP&L in negotiating the sale of an ownership interest in the Harris Plant to NCEMPA. The Purchase, Construction

! -4s-

1 i,

and Ownership Agreement between CP&L and NCEMPA contains a number of ,

provisions which express the understanding of the parties with respect to CP&L's completion of Harris Units 1, 2, 3 and 4, including Sections 2.1, 7.2, 9.2, 12.1, 25.1, 25.2, 25.3, 25.4. The Agreement will be made available for Joint 4

Intervenors' inspection at CP&L's General Office upon request.

l (e) Not at this time.

t (f) No.

4 (g) No.

4 (h) No.

1 (i) CP&L is not aware of any complaints or charges that CP&L or any i

agent or person working for CP&L mis epresented what CP&L was doing in acquiring land for the Harris plant. CP&L's acquisition for the Harris project began in June 1970 using an undisclosed agent. During that period of time no representation was made as to CP&L acquiring the land. Approximately 7,622 acres were purchased in this manner prior to the public announcement in April 1971.

The North Carolina Utilities Commission conducted a public inquiry in 1978-79 entitled "In the Matter of Investigation of Carolina Power & Light

! Company's Land Requirements, Acquisition, and Disposal at the Shearon Harris

' Nuclear Power Plant - Docket No. E-2, Sub 333." That proceeding is a matter of

) public record and sets forth therein CP&L's land acquisition policies or practices l

! for the Harris site. Any complaints relative to these policies or practices generally involved issues of market value for land or damages to land arising out of a taking of a portion thereof.

I

! CP&L maintains files of its land acquisitions for the Harris project and contacts with respective owners. Tnese files will be made available for Joint i

i Intervenors' inspection during regular business hours at their place of storage - ]

either at CP&L's General Offlee or CP&L's Warehouse in Garner, N.C., upon specific request.

(j) Yes.

" Carolina Power & Light Company v. Philip P. Ragan and wife, Mary Frances H. Ragan" 75 SP 353 - Wake County Clerk of Court's Office CP&L Attorney: Andrew McDaniel Attorneys for CP&L: Bailey, Dixon, Wooten, Mcdonald &

Fountain (Kenneth F. Wooten)

, Commenced: April 23,1975 Voluntary Dismissal filed: May 23,1975 This Court proceeding is a matter of public record (75 SP 353),

which record sets forth all hearings and dates.

" Carolina Power & Light Company v. C. P. Ragan and others" 75 SP 376 - Wake County Clerk of Court's Office CP&L Attorney: Andrew McDaniel Attorneys for CP&L: Bailey, Dixon, Wooten, Mcdonald &

Fountain (Kenneth F. Wooten)

Commenced: April 24,1975 Consent Judgment filed: November 16,1977 This Court proceeding is a matter of public record (75 SP 376),

which record sets forth all hearings and dates.

" Carolina Power & Light Company v. Irma R. Holland and others" 75 SP 377 - Wake County Clerk of Court's Office CP&L Attorney: Andrew McDaniel Attorneys for CP&L: Bailey, Dixon, Wooten, Mcdonald &

Fountain (Kenneth F. Wooten)

Commenced: April 24,1975 Judgment filed: May 24,1978 i This Court proceeding is a matter of public record (75 SP 377),

which record sets forth all hearings and dates.

" Carolina Power & Light Company v. Lydia C. Ragan and others"

.73 SP 375 - Wake County Clerk of Court's Office CP&L Attorney: Andrew McDaniel Attorneys for CP&L: Bailey, Dixon, Wooten, Mcdonald &

i Fountain (Kenneth F. Wooten)

Commenced: April 24,1975 ,

1

Consent Judgment filed: August 11,1977 l

l This Court proceeding is a matter of public record (75 SP 375), l which record sets forth all hearings and dates.

No CP&L attorney or attorneys for CP&L ever made any statement or argument in any proceedings named above that CP&L had not decided whether Harris would be a nuclear plant or a coal plant, or said any words to that effect.

CP&L adopted the title "Shearon Harris Nuclear Power Plant" on March 17,1971.

Nuclear fueled units were chosen because they were projected to be the most economical when compared to both coal and oil-fired units.

See the response to Interrogatory No.1-38(c) as to when CP&L ordered the Harris nuclear steam supply system.

CP&L received an Order Granting Certificate of Public Convenience and Necessity for Harris as a 4-unit nuclear plant from the North Carolina Utilities Commission, which was dated February 29,1972.

CP&L considered coal conversion in connection with the Harris 3 and 4 units cancellation study. Relevant documents will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

(k) (1-x) CP&L has a corporate policy on business conduct, contained in the Company's Supervisors' Manual, which states that "The Company is dedicated i to honesty, integrity, and impartiality in the conduct of its business both in fact and in appearance." As a basic guideline to this policy, Company employees are j not authorized to achieve any Company objective directly or indirectly through the violation of generally accepted business standards or the laws, rules, and regulations to which the Company is subject. Such policy would include truthfulness and accuracy of Company statements to all persons or business entities.

1 (1) Not to our knowledge.

(m) Yes.

February 22,.1980 - Brunswick Steam Electric Plant. Copies of statements released by CP&L to the media concerning the release will i

be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

(n) See response to Interrogatory No.1-39(m).

(o) Applicants are not aware of any employee having been fired for

! any of the reasons contained in Interrogatory No.1-39(o).

(p) The following incidents involved employee termination or a t

resignation where events with possible safety significance were investigated by CP&L. The Company is not aware of the exact reasons for those employee's resignation.

Date of Incident or Action Description of Incident Action Taken Plant .

prior to i/29/82 improper inspection of employee resigned Harris welds before action could be taken 4/82 suspected of improper employee resigned Harris initialing of seismic I while investigation inspection reports being conducted i

l prior to 2/3/82 evidence of use of cocaine terminated Harris i 5/83 improper performance of employee sent home; Robinson valve lineups resigned before -

further disciplinary l action could be taken 2/83 conviction of possession terminated Robinson of controlled substance off )

the job (on his own time) l (q) See response to Interrogatory No.1-39 (g). Applicants do not intend to make further information available due to its confidential nature.

i l * .

i

, , . - . - - - . , . - . __ - -_ _ , . _ , . _ . . , ~ ~ . . , . -

(r) Disciplinary actions related to NRC regulation violations are attached as Attachment I-39(r).

(s) Disciplinary actions related to known technical specification l

> violations are indicated with an asterisk (*) on Attachment I-39(r). Applicants are unable to determine which, if any, of the other disciplinary actions contained in

Attachment I-39(r) are technical specification violations without review of all documentation related thereto. Applicants have not performed such a review.

1 (t) CP&L has not taken disciplinary action against any employee of the rank of Vice President or higher due to management or safety problems at a nuclear facility. As indicated in response to Interrogatories I-13 and I-14, CP&L has modified its organization from time to time as appropriate to accommodate growth, to maintain and improve its organizational capabilities, and to develop organizations and personnel to facilitate future needs. As a result, reassignment

) of responsibilities of personnel at the rank of Vice President or higher have occurred but not specifically for the reasons stated in the Interrogatory.

(u) See response to Interrogaroy No.1-30(r-s).

) ANSWER I-40:

! (a-f) The issues raised in these questions were discussed extensively ,

i during the Harris Plant Construction Permit Remand Hearings (Docket Nos.

.1 50-400, et al.) which were held in March of 1979. Applicants' positions on these issues are set forth in the testimony of E. E. Utley, H. R. Banks, J. A. Jones, and

M. A. McDuffie in that hearing. Transcripts of-this testimony will be made available for' Joint Intervenors' inspection at CP&Us General Office upon request.

. (g) Between January 1,1979, and the present, there have been times when employee turnover at the Brunswick plant has been higher than Applicants would desire. As discussed in the response to Interrogatory No. I-47e(xil-xlii),

1

, . - - - - ~ ~,w , , -

. ~ , - - --

l

! l there have been periods when the staff levels were lower than CP&L considered l desirable. Applicants do not believe, however, that employee turnover at Brunswick has posed a threat to the safety of the Brunswick plant operation or reduced the margin of safety in Brunswick plant operations. Employee turnover at Brunswick is not considered to be a problem at the present time.

(h) It is CP&L's policy to maintain wage and benefits programs that l are competitive with neighboring utilities, with other industry within our service area and for certain positions within the nation. The maintenance of this

! competitive posture is essentialin recruiting and retaining the numbers of skilled personnel that are necessary to operate and maintain nuclear plants. In accordance with this policy, several enhancements have been made to CP&L's l f wage and benefit program since 1979. Significant changes are listed below:

1 l.

Foreman supplement pay was initiated in mid 1979.

2. Rate ranges have been adjusted for various classifications as necessary,to resolve salary compression problems fo,r foremen, engineers, health physics technicians, and operating personnel.

3. In mid-1980, a nuclear supplement was implemented for nuclear

plant personnel.

4. Reactor operator and senior reactor operator supplement pay has

} been reviewed and revised each year since 1977. The net effect of

, these reviews has been to maintain competitive salaries for these personnel.

5. Improvements have been made since 1977 in the insurance i

i program. These improvements have involved increased beste life coverage, increased contributory life coverage, the adoption of dependent life coverage for family life coverage, the l , .

implementation of a dental insurance program, and overall 1 reductions in employee costs for the benefit programs.

6. CP&L's policy with res&ct to moving expense reimbursement has also been revised several times since 1977. CP&L has maintained l

a policy that is consistent with the practices of other utilities and l

industry in its service area. These changes have facilitated the transfer of personnel within the Company and improved CP&L's recruiting posture for employees outside the Company.

7. Employee Relations personnel have been placed on-site to provide direct assistance in recruiting plant personnel.

Applicants believe that policies and improvements such as those listed above, have been effective in allowing Applicants to recruit and retain personnel necessary to safely operate and maintain all of their nuclear units. These improvements in the wage and benefit program were approved by senior company management. The growth in Applicants' staff, as illustrated by the response to interrogatory No. I-24, points to the success of these policies.

(i) Documents regarding employee turnover will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. Prior to 1982, data on turnover by classification was not routinely maintained, liowever, data by classification has been maintained to CP&L's Employee Relations Departments for 1982 and 1983.

l The Brunswick Site Personnel Director has participated in monthly l

Nuclear Plant Senior Management meetings since late 1980, information regarding turnover and other personnel related matters has been reviewed with Senior Management personnel during these meetings.

4

______.___.~___..__--_.m

J (j) As discussed in the Harris Remand Hearings, the NRC did have concerns with respect to personnel turnover at the Brunswick plant during the period from 1975 to 1977. The NRC's witnesses' transcripts from those hearings will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

Applicants are not aware of any specific NRC concerns with respect to the employee turnover at the Brunswick plant since the events discussed during the Harris Remand llearings.

(k) The report of A. Ronald Jacobstein, prepared for the NCUC Public Staff, dated February 1982, discussed staffing levels at the Brunswick plant (sce response to Interrogatory No. I-47c(xii-xill)).

The " Management Study of Carolina Power & Light Company" prepared for the North Carolina Utilities Commission by Cresep, McCormick, and Paget, Inc. dated December 1982, discussed staffing of operators at the Brunswick Plant. (Also see the response to Interrogatory No.1-68.)

(1-m) Applicants are not aware of any concerns expressed by anyone else with respect to employee turnover at the Brunswick plant.

(n) Applicants do not consider that there presently exists any problem with respect to employee turnover at the Brunswick plant. Applicants do, however, plan to maintain a polley of providing competitive wage and benefit programs as discussed in response to Interrogatory No.1-40(h).

(o-p) Strategies for recruiting, employment, compensation, and development of personnel are developed by senior management. As these strategies have been developed and implemented over the years, one may assume i that these have been recommendations proposed that were not adopted. The final strategies adopted by senior management were those that were deemed to be the e

most effective in allowing us to recruit,' employ, develop, and retain qualified employees at CP&L, including the Brunswick plant. A listing of any l

recommendations not adopted has not been maintained.

(q) CP&L management does not consider there is a problem with i employee turnover at Brunswick. The basis for this position is the fact that i

turnover for the Brunswick plant operating staff for 1983 was approximately 5.6 percent. Excluding clerical personnel, the turnover rate was 3.7 percent.

Applicants consider these turnover rates to be reasonable for an organization the j

size of the Brunswick plant.

I ANSWER I-41:

- The general design practice followed by CP&L in the design of Brunswick was to specify equipment to be compatible with the process fluids with l which the equipment or its parts would normally come into contact. Thus the l parts of equipment or components that were normally exposed to the brackish i

! cooling water (such as the circulating water side of the condenser and the service water side of the RHR heat exchanger) were specified to be compatible with that application. As indicated in our response to 1-30(p), design specifications for the Brunswick equipment are available for Joint Intervenors' inspection at CP&L's f General Offlee upon request.

l I Since startup of Brunswick Unit 2, the cooling water at the Brur.swick site has, however, caused a number of problems due to corrosion and/or fouling of equipment. Such problems were brought to the attention of Senior Management

! once they began to be identified. Senior Management has been very involved in .

1 I

the resolution of these problems. For example, in December,1975,in response to continuing corrosion problems being experienced at Brunswick, the metallurgical engineering staff of the Quality Assurance Engineering Section was commluloned d

. . l

to provide a detailed study of corrosion problems at Brunswick. Personnel.from this Section performed a comprehensive study during the first half of 1976. This l study entailed design reviews of components and systems against plant ,

l environments and extensive visual examinations of plant components which were accessible. Parts were examined while in operation and dissassembled when appropriate. The results of this study were reported in two reports issued in the fall of 1976. Copies of these reports will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. The studies identified problems associated with the operating environment, galvanic corrosion, crevice corrosion, material selection, stagnant areas resulting in oxygen concentration, coating failures, etc. The studies also included suggested corrective measures.

Based upon these early studies and our continuing experience at Brunswick, the most significant corrosion and fouling problems at Brunswick have been:

(1) Corrosion / erosion of condenser tubes (2) Corrosion of cement lined piping in the Service Water System (3) Fouling problems caused by shell growth in the service water and circulating water systems.

(4) Radwaste problems caused by leakage of brackish water which ultimately had to be processed via the radwaste system.

(5) Corrosion of equipment not designed for brackish water service but which came into contact with brackish water due to leakage from other equipment.

(6) Blockage of the RHR Heat exchanges due to the shell buildup.

I As a result of our initial evaluations and our continuing experience with the brackish water at Brunswick, corrective actions have been taken to

1 minimize problems due to corrosion and fouling at Brunswick. Corrective actions have involved changes in materials, equipment replacement, improved coatings, improved control of leakage, etc. as appropriate to resolve each problem. Some of the more significant corrective actions are:

(1) Condenser modification to replace the 90-10 copper-nickel tubes with titanium tubes and to install in integrally-grooved tube sheet. The titanium tubes are more corrosion resistent than copper-nickel and the integrally-grooved tube sheets provide increased protection against condenser leaks at the tube to tubesheet joints. This modification was completed on Unit 1 in 1983 and is currently in progress on Unit 2.

(2) Debris filters were installed on the circulating water system in 1980 and 1981. These filters prevent debris such as shells from getting to the condenser where they can cause tube corrosion.

(3) Portions of the service water piping have been replaced with more corrosion resistant material and a continuing program of inspections / replacement is in place.

(4) Changes have been made in the radwaste system to more efficiently process brackish water.

(5) A ' condenser tube cleaning system was installed in 1981. This system is designed to maintain condenser tube cleanliness.

(6) Provisions have been made to provide for differential pressure monitoring on the RHR heat exchanges to provide advance indication of shell bulldup which can result in blockage of the heat exchanges.

l 4

l

.U

Documentation regarding the problems discussed abora will be made available for Joint Intervenors' inspection at C P & L's General Office upon request. To the extent that problems associated with fouling and/or corrosion have resulted in any events reportable to the NRC, they would be discussed in the documentation provided in response to Interrogatory Nos.1-1 through I-8.

ANSWER 1-42:

CP&L did not review Mr. Jacobstein's report prior to its issuance to the Public Staff of the NCUC. CP&L initially was provided a copy of the report in a meeting with Mr. Jacobstein and representatives of the Public Staff. The report was in final form at that time, and no efforts were made to change any portion of the report. With respect to Item C, CP&L management has no knowledge of any present or former employee making any effort to prevent Mr.

Jacobstein from getting other consulting work, to have any of his consulting work terminated, or to have him fired or relieved of duties for any employer including the Public Staff.

ANSWER I-43:

1 Minor personnel contamination events involving construction workers have occurred at the Brunswick plant. These events are normally associated with maintenance on reactor systems containing radioactive material. Upon completion of work in a contaminated area, all persons are thoroughly monitored. If external contamination is found, the individual is directed to a l

personnel decontamination area where the contamination is removed from the skin l or personal article using wa m water and mild detergent.

In April 1980, two construction workers ingested measurable quantities of radioactive material while cleaning up a construction work area. The event was attributed to a build-up of contamination levels in the work area since the

last contamination survey, and a failure on the part of the workers to recognize the seriousness of causing dust to become airborne in a contaminated area. Once contamination was detected, the workers received a thorough external decontamination prior to receiving a whole body count. These counts indicated the presence of small amounts of radioactive materialin each worker. Subsequent whole body counts were made during the following days. Based up6n the results of these counts and utilizing the calculational techniques presented in the International Commission on Radiological Protection (ICRP) Publication 10, the 1 cumulative 50-year organ dose for the highest exposed individual was 1198 millirem to the gastrointestinal tract. The current CP&L annual administrative exposure limit is 4000 millirem.

As a result of this incident, the following corrective actions were undertaken:

1. The incident was reviewed with the IIealth Physics technicians to alert them to the possibility of contantination during future clean-up activities.

2. Additional radiation safety training was initiated for Brunswick contractor employees.

3. The location of the incident was decontaminated in order to sigificantly lower the contamination limits.

4. Additional Health Physics technicians were brought to the Brunswick site to increase job coverage in work areas.

5. A special radiation safety training course was developed for personnel performing decontamination and clean-up work in contaminated areas.

i

6. General Employee Training (GET) has been increased to 16 full hours (GET I and II) which includes dressing out and removal of protective clothing, monitoring for personnel contamination, and the use of portable radiation detection instruments. CP&L first-line supervisors who direct activities in contaminated areas or radiation areas are also required to attend a 40-hour (GET III) course on advanced health physics practice and knowledge.

The results of this investigation were documented in an Operating Experience Report and reviewed by the two individuals involved, the Plant Management Group, Plant Nuclear Safety Committee, and the Vice President-Nuclear Operations.

At Brunswick, contamination events are handled in accordance with procedure No. E&RC-0210 which is in the Plant Operating Manual. Appropriate notification of. management personnel is accomplished in a timely manner; however, logs of when management personnel are notified are not maintained. .

The management level to which reporting is made depends on the significance of the contamination event.

ANSWER l-44:

Coordination problems are inherent in any large undertaking such as the construction, operation, or maintenance of a nuclear power plant. During CP&L's experience with nuclear power, such problems have occurred in many of the areas referenced in this question. The Company does not maintain lists of such problems. To the extent that any coordination problem may have led to an event that was reportable to the NRC, it would be identified in the documentation provided in the response to Interrogatory Nos.1-1 through I-8.

The management response to coordination problems when they are -

identified is to take appropriate action to resolve the problem. The action required will vary depending upon the nature and significance of the problem and

! the organizational units involved.

One of the Company's primary tools for resolving coordination

< problems is the staff and project review meetings that are periodically held at

. Various levels within the organization up to and including Senior Management meetings. Such meetings, regardless of the level of personnel involved, provide

)

the opportunity for managers and supervisors to review the status of work, to interface that work with other personnel and organizations, and to discuss and resolve any coordination and interfacing problems that may be evidenced at the time.

Resolution of coordination problems, when identified, can range from clarifying work functions and job responsibilities to making organizational changes. For example, one of the objectives of the organizational changes at Brunswick in the fall of 1983 was to improve coordination among the operations,

! engineering, and construction organizations that were working at the site.

1

[ ANSWER I-45:

^

(a)(i-li) Yes.

I (b) Not applicable.

l (c) CP&L senior managers have been and continue to be involved in 1

identifying and ensuring effective training for all nuclear power plant personnel, including Shift Technical Advisors (STAS). As part of this involvement, CP&L has i

appointed a manager at the section level, who is responsible for effective

implementation and evaluation of nuclear plant personnel training. This manager reports directly to the Vice President - Operations Training & Technical Support.

. i i

^'

i l

In addition, senior management requires reviews of training programs by plant management, training advisory committees, and quality assurance, and l

requests periodic outside agency reviews (such as INPO) of training. Q A and INPO reviews are forwarded directly to the Executive Vice President - Power Supply, Engineering & Construction. Responses and follow-up actions are also documented to the same management. As a result of these reviews and reports, senice management is kept current with training programs, including STA training, and takes positive action to ensure effective training.

Specific management involvement with regard to Shift Technical Advisor Training is evidenced as follows:

1. By formal correspondence with the NRC, the Executive Vice President - Power Supply, Engineering & Construction, described the training and retraining programs of STAS at the Brunswick and Robinson plants. These programs were developed in accordance with the requirements of NUREG-0737, Item I.A.I.1., and were approved by the Nuclear Regulatory Commission (reference letters E.E. Utley to D.G. Eisenhut, December 31, 1980).

s

2. As further indication of management involvement in training for STAS, the Vice President of Nuclear Operations required that STAS be licensed and receive licensed retraining (reference memorandum from B.J. Furr to R.B. Starkey, Jr. and J.L. Willis, February 7,1983). This is a significant commitment that goes well beyond regulatory requirements.

3. Harris General Manager identified the STA trsining schedule for license training and also identified a review of STA responsibilities in relation to the license training program

i (reference memorandum J.L. Willis to B.J. Furr, SHNPP-83-104, j l

March 1,1983).  ;

l l Copies of these documents will be made available for Joint , ,

Intervenors' at CP&L's General Office upon request.

ANSWER l-46:

(a) Spills of the type identified in this Interrogatory, while not desirable, cannot be completely avoided during the operation and maintenance of 1

a power plant. Inherent in the planning and conduct of work at Applicants' power plants are provisions to prevent or minimize the potential for such spills and to l

take prompt corrective action should spills occur. This philosophy is illustrated in ,

the various plant procedures identified in the response to Interrogatory No. I-46(e).

I Maintenance of records of such events would depend on the i significance of the spill. To the extent that such spills are significant enough to

^

f be reported to the NRC or.the EPA, they would be identified in the LERs, reports, i

or other documentation referenced in response to Interrogatory Nos.1-1 through I

! l-8. With respect to equipment damage, see the response to Interrogatory No. I-1 i 30(r)(1).

(b) As stated in response to interrogatory No.1-46(a), spills are not f desirable, but cannot be totally avoided during the operation and maintenance of a i  !

5 power plant. Spills of various nature occurred during the 1981 turbine outage at Brunswick, however a speelfle listing of such events has not been compiled. The I occurrence of such events did not impact the critical path of the outage or result in radiation exposure of personnel beyond administrative or regulatory limits.

(c) Procedures and controls were in place at Brunswick prior to 1981.

l The following list identifies some of the administrative / procedural controls that i

62 -

l I exist at the plant. In addition, various other maintenance and operating f

procedures address prevention and control of splus. These procedures were in place prior to 1981 unless otherwise noted.

FP-6, Storage and Use of Hamardous Materials AOP-05.1, Liquid Radioactive Spills (1984)

Brunswlek Plant Water and Pouution Control Handbook Al-17, Plant Housekeeping l l

El-18, Main Condenser Tube Failure PN-1, Emergency Action for Spillage of Contaminants  ;

i E&RC-1400, Handung, Storage, and Disposal of Polychlorinated j Hiphenyls (PCBs) [

Al-48, Bulk Chemloal Control (1982) 1 RCI-06.1, Lleensee Event Reports and Speelal Reports (1983): Identifloation, Investigation, Preparation, and Submittal i RCI-08.5, NRC Reporting Requirements (1943) i Al-00, Plant Safety and Reuabluty Enhancement Through -

Consideration of Human Factors Al-09, Plant Nuclear Safety Committee Administration (d) Prevention and/or control of spitis is an inherent part of  !

Applicants' maintenance planning netivities and the conduct of maintenance activities. Thus, these items were considered in the planning of the 1981 Brunswick outage. Au personnel involved in the planning and/or conduet of maintenance activities are responsible for ensuring that suoh activities are conducted safely. Documentation of such plans to the extent that documentation was necessary or required would be in the maintenance procedures or other instructions governing the work.

l -u.

l

(e) Prior to 1981, the approach to outage planning at Brunswlok was to l utillae assigned outage coordinators who coordinated the planning of the outage l under the direction of the Superintendent - Operation and Maintenance (prior to [

1980) or the Manager - Maintenance (1980). In 1941, Applicants established a [

permanent outage planning orpnisation under the direction of the Direeter -

Planning & Scheduling who reported to the Plant General Manager. In early 1943, I the Director of Planning & Scheduling began reporting to the Vloe President -

Brunswick Nuclear Project and in early 1984 outage planning responsibility was i l

included in the Outage Management Section under the direction of the Manager - l t

Brunswick Nuclear Project - Datages.

l As evidenced by the abova discussion, there has been continual l t

l' upgrading of the organization responsible for outage planning at Brunswlok since i 1980. These changes relate in part in the experience gained during this period and ,

to the recommendations and JuggesLions of personnel responsible for outage ,

t management. l i

(f) CP&l/s practlee with respect to outage planning and scheduling is to plan niid setedule in a manner (he.t provides suffielent (ime to accomplish known work requ!rements while minimleing unit downtime.

Guluolines with respect to outage planning are contained in the  !

Company's Power Plant kiH;b61 sty Prograin whleh was implemented in 1979.

Guideunes ers also. liioluded in the Nuclear Operating Procedure NO-7.lf, -

Generating Unit Outage Neheduling. At Prwwwlok, rRnis e PPP-06.1," Outage Planning nr.d Control" provides general guldstice in this area. At Robinson, similar.

guidance is provided In' prueedure PP-1,1. In addition, expanded guidelines for Outage Plahning & Geheduling and Outage OrgentasOor.el guidelines were adopted in 1943 (this Infnemation is referenced in the response to interrogatory No.'l-fe).

j r

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• .* j l

l A generic discussion of CP&L's outage planning and scheduling i

l practices was included in a report filed with the North Carolina Utilities l

l Commission in February,1981 and in the following proceedings before the North t

Carolina Utilities Commission:

1981 N.C. Rate Case - Docket E-2, Sub 416 Testimony of L. W. Eury and B. J. Furr 1982 N.C. Rate Case - Docket E-2, Sub 444 Testimony of L. W. Eury, B.

J. Furr, M. A. McDuffie, R. M. Coats ,

(g) It is and has been the practice of CP&L to provide for the availability of necessary spare parts for each nuclear plant as part of the engineering, construction, start-up and initial operation of the plant. The general process that is used is as follows:

1. Obtain a recommendation for spare parts from Original Equipment Manufacturers (OEM).

2. Evaluate the recommendation based on expected operation, maintenance experience and cost considerations.

3. Determine the Company's spare parts requirements.

4. Obtain management approval.

5. Procure the material.

6. Receive the material, ensuring specifications are met.

7. Store the material until required for use.

l ,

The continuing availability of spare parts is ensured through the use of inventory control systems to record usage history and reorder the material as l

necessary, and to record changes to the materlal indicated by the OEM or by l CP&I/s maintenance, operations or engineering experience and requirements. The l' 1

-as- j

i actual technique of implementing this practice has improved with each new plant i

drawing upon the Company's growing nuclear plant experience.

l Robinson Unit 2 was a turnkey project through contractual arrangements with Westinghouse Corporation. Ebasco was the architect / engineer selected to assist in the engineering and construction of the plant. The availability of necessary spare parts was provided by the CP&L plant maintenance i

staff, reviewing vendor recommended spares and placing orders through CP&L's Purchasing Department.

Robinson's initial procurement of spare parts could be characterized as only essential parts. As operating experience has been gained, additional spare parts have been added as necessary. The availability of the Robinson plant demonstrates that essential spare parts were available as needed for the operation of that plant. All of the initial procurement at Robinson predates January 1, 1974.

At the Brunswick plant, CP&L was involved to a larger extent in the engineering, construction and start-up. Through contractual arrangements with i the architect / engineer, and the prime Nuclear Steam Supply System contractor, the availability of essential spare parts was assured. Recommended spare parts lists were obtained from vendors and reviewed by the architect / engineer and submitted to - CP&L. The plant staff had final review and approval of all i recommended spare parts. An additional feature of the Brunswick spare parts program was the development of an automated inventory system called Plant Parts Inventory (PPINV) which was used at the Brunswick plant to ensure' spare -

parts availability and inventory control. The contractual arrangements for the initial procurement of Brunswick predates January 1,1974.

m, # - y -y.- y -, yg-myy n~g- -

evw a . ~w y- w-

j In the case of spare parts for the Harris Plant, CP&Us active role has l increased in regards to both spare parts procurement and the management of the i construction effort. There are plant staff resources dedicated to determining I

which spare parts are necessary. CP&L Purchasing is handling the procurement of these parts. Harris Plant is utilizing the new, comprehensive, on-line Corporate Materials Management System (CMMS) as a tool for the management of its inventory.

In each of these processes, senior management is and has been intimately involved. This is evidenced by the contractual arrangements that require top management approval. Also the plant organizational structures and resources that are responsible for spare parts availability require senior management approval These practices apply to all the equipment indicated (i-xi) ,

and were in effect on all the dates indicated (dd-11). Practices and procedures for Robinson's (aa) and Brunswick's (bb) initial spare parts were utilized well before the earliest date (dd).

CP&L has several documents that illustrate the practices and procedures used to ensure spare parts availability at Harris (ce). These documents will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

(mm-nn) The procedures and practices are changed as necessary depending on experience, schedule, resources and other factors to ensure that spare parts are available in the most advantageous and cost-effective manner to CP&L. An example of a change in procedure was the replacement of the manual KARDEX inventory control system at Robinson and the batch automated PPINV inventory system at Brunswick with the new on-line . automated Corporate -

Materials Management System (CMMS). Procedures were changed to reflect the improved system. .

l l

In addition to the attention given to spare part availability.at each l plant site, CP&L is involved with other utilities in the Pooled Inventory i

Management System (PIMS) which will assure spare part availability while reducing the cost to individual utilities through the sharing of inventory management expertise as well as pooling the materials themselves. Documents related to PIMS will be made available for Joint Intervenors' inspection at CP&L's i General Office upon request.

(oo-pp). Some distinction may be made between spare and replacement parts in the industry for QA, financial, or other purposes, but with respect to the availability of parts (spare or replacement) for CP&L's plants, there is no distinction. CP&L ensures the availability of those parts necessary to operate and maintain plant systems and equipment without regard to other definitions that might be applied to those parts.

(h) CP&L utilizes contract personnel in its generating plants during.

periods of high maintenance activity (i.e., outages) ' to supplement its own workforce and to perform special work functions that require expertise not normally available within the Company (i.e., specialized testing and/or inspections).

Many of the work functions require highly skilled craftsmen, technicians, or professional personnel. CP&L routinely maintains contracts with various companies from which the Company can obtain the craft or professional personnel required. The fact remains, however, that there is not an unlimited ,

source of such skilled personnel and CP&L is thus in competition with other utilities and industries for these p'ersonnel.

This means that CP&L is not always able to obtain the quantities of personnel needed on the schedule that the Company would desire. CP&L w

d.

minimizes this problem to the extent possible through advanced planning, scheduling and/or work sequencing during an outage.

The work of contractor personnel at Company plants is coordinated by appropriate CP&L supervisory personnel If problems are experienced with the competence of any contractor personnel, appropriate action is taken. Action may range from counseling the individual involved, reassignment to other duties, removal of the individual from the site, or removal of the contractor from the site. The level of management involvement in such action will range from the responsible supervisor up to Senior Management depending on the particular problem or concern.

(j) CP&L routinely utilizes critical path method (CPM) scheduling techniques in the construction of nuclear plants and in the planning and conduct of plant outages. CP&L uses the CPM method because CP&L considers it to be the best available concept.

During construction or during an outage, frequent meetings involving key personnel are held to review schedule progress, any problems that have been identified, and to resolve any coordination problems that may have been experienced. In the case of nuclear plant outages, such meetings (plan-of-the-day) are generally held on a daily basis. Over the past several years, significant enhancements have been made in the Company's concepts for planning, scheduling, and coordinating plant outages and additional enhancements are expected in the l q

future. I l

CP&L does not agree that the use of CPM concepts has been a detriment to noneritical path activities. While it is not uncomraon for a task that was planned as a noncritical path activity to become critical path, the cause of such an occurrence is not normally the result of the scheduling concept.

Generally, such occurrences are due to unexpected and unanticipated delays in the noneritical path activity which cause that activity to take longer than originally planned.

Some problems of " interference" among critical path activities and/or competition for limited resources and equipment, such as QA/QC support, health physics support and cranes, are likely to occur in any major outage. Identification and resolution of such concerns is one of the primary reasons for the coordination or plan-of-the-day meetings discussed above.

ANSWER I-47:

(a) CP&L senior management does not directly establish engineering requirements of power plant equipment other than to assure, through the Power Plant Engineering Departments, that equipment is specified to meet regulatory requirements, CP&L engineering requirements, and accepted industry standards.

The Brunswick main steam isolation valves (MSIVs) were part of the General Electric scope of supply and as such were designed to meet primary system temperatures, pressures, flow rates, shut off leak rates, and specified maximum l closing times as analyzed and specified by General Electric.

The Brunswick MSIVs were built and certified to meet the following standards where applicable:

1. ANSI B31.1.0 and B16.5

2. ASTM (American Society for Testing Materials)

3. ASME B&PU Code Sections I, III, and VIII

4. Institutes of Electronic and Electrical Engineers f l

5. Pipe Fabrication Institute

6. National Electrical Manufacturers Association l i

(b) The following tests were performed on the Brunswick MSIVs by the l

manufacturer in the shop:

1. At 1000 psig and no flow, the valves were stroked to assure closing times between 3 and 10 seconds. l l

2. Leak testing both seated and back seated.

3. Hydrostatic testing. .

4. Tests performed during fabrication include radiographic, liquid dye penetrant, or magnetic particle examinations on castings, forgings, welds, hard facings, and oolts.

Details of these tests may be found in Section 5.4.5 of the Brunswick FSAR.

In addition, after installation at the plant, these valves were tested in place as part of the plant preoperational and start up program. Tests included hydrostatic and leak rate testing.

(cXi-v) CP&L agrees with the listing of MSIV failures in the Jacobstein report. CP&L also agrees that these events involved failures of the threaded connections that join the disc to the valve stem. Review of the MSIV failures also indicated that aggravated flow turbulence created by the specific piping configuration on some of main steam lines could have been a factor in the failure of the threaded connections.

Flow turbulence is routinely considered in piping designs; however there was no specific consideration given to turbulence as it related to stem / disc separation.

There have been no stem / disc separation failures of the Brunswick MSIVs since September 8,1981. The only significant problem associated with MSIVs since September 8,1981 was associated with valve stem galling. This i

problem was identified in November 1982 on Brunswick Unit 2 when a valve failed i

to open properly during unit start-up.

The problem was resolved by: (1) replacing or restoring the stems; (2) replacing the junk rings (junk rings are metal rings that serve as a support and guide for the valve stem, i.e., the valve stem passes through the junk ring as the i

valve opens or closes) with rings of a softer material that should minimize the potential for galling; and (3) revision of the MSIV valve packing procedure.

Documentation on this event will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

(vi-xi) Since there are no MSIVs at CP&L's Mayo Unit 1, it is assumed that the valves referred to in these questions are the Main Steam blending system isolation valves. These valves are installed in accordance with

, the boiler manufacturer's design drawings at an inclined angle with the operator off verticalapproximately 30 degrees.

1 During construction, there was some question as to whether the valves

should be installed in a vertical position. CP&L investigated and verified the l

acceptability of the valve orientation with both the boiler manufacturer and valve I manufacturer. These valves do not have to be installed in a vertical position.

! The valves were never cut out and reinstalled; they remain in their i

l original inclined position as designed. The valves have been in commercialservice f for over one year with no problems and CP&L has performed a complete valve i disassembly.for maintenance, again verifying the acceptability of the off-vertical

! orientation.

i The handling of this question of valve orientation is an example of l CP&L's good management practices. The question regarding the orientation of

! the valves was raised as part of CP&L's operations review of the plant and was l

pursued in accordance with established procedures for resolution of such concerns. CP&L ensured the acceptability of the valves by investigating the valve orientation prior to installation, verifying this position with the boiler and valve manufacturers, performing a complete valve disassembly prior to commercial operation, and has subsequently experienced over a year of successful operation of the valves without problems.

(xii-xiii) CP&L's management has carefully and continuously evaluated the staffing requirements of the Brunswick Plant. The steady growth of operating plant staff as illustrated in the response to Interrogatory No.1-24 is indicative of management's philosophy of providing sufficient resources to perform the work of the plant and to ensure that the plant is operated and maintained safely. ,

In hindsight, there have been periods when the staffing level at the Brunswick plant has not been at the level that Applicants would have desired in order to more effectively cope with the workload that existed at that time.

The period from 1975 to 1977 was one such period. The staffing levels that existed during that period, problems that existed with respect to staffing, and the corrective actions taken by Senior Management were reviewed in the Harris ASLB Remand Hearings (Docket Nos. 50-400 et al.) which were held in March of 1979.

! A second period when staffing level was less than desirable was the 1979 to 1981 period. During that period Applicants were confronted with a significant increase in regulatory requirements primarily resulting from the Three Mile Island accident. The net effect of this significant increase in regulatory requirements combined with . the on-going plant iniprovement and reliability programs that were underway at that time was to create a shortfall in staff resources and thus contribute to a backlog of work to be performed. In response to this situation, Senior Management provided for increased staffing.

l

)

In addition to the above, during the period of 1979-1983, the number of licensed operating personnel has been less than desirable. Sufficient personnel have been available to ensure safe operations and to staff the operating shifts in accordance with NRC requirements. We have not however, had the numbers of licensed personnel reqired to establish what we consider -to be l optimum shift rotation and training schedules. As indicated in the response to i Interrogatory No.1-68, this shortage has now been reduced to a level that we consider reasonable. We plan however, to maintain a strong emphasis on the recruitment and training of operators for Brunswick.

There are several basic principles of workforce management that i

Applicants have always attempted to follow with respect to staffing of their f plants. These are:

l 0 That productivity is not simply a function of the number of personnel assigned to a task; o Staff growth must be at a rate at which manpower can be

! properly absorbed and integrated into the existing structure; o That supervisory personnel must be well-trained, experienced and properly deployed to achieve high levels of efficiency; o That the safety of all personnel must be protected;  ;

l o That spans of control must be compatible with the nature of the work to be supervised; o That work planning must reflect priorities of management.

By following these principles, the staffing and organization at CP&L's plants have been modified in a logical manner to provide sufficient resources to accomplish the work requirements that CP&L currently has and those that reasonably can be expected for the future.

l (xiv) CP&L agrees that the significant ' increase in regulatory requirements that - resulted following the Three Mile Island accident, when combined with the on-going plant reliability improvem,ent efforts at the Bruriswick -

1 plant, created a backlog of backfit and maintenance work during the 1979 to 1981 time period.

(xv-xvi) CP&L has had and still has a backlog of backfit and maintenance work to be performed at the Brunswick plant. Whether or not this backlog of work is "large" is a matter of definition and interpretation. CP&L does not consider the present backlog of work to be unmanageable. The primary cause of the backlog of work at the Brunswick plant has been and continues to be increasing and changing regulatory requirements. In addition, the Maintenance Management System (MMS) prioritizes work according to its safety and power generation significance. This is indicative of good management in that the work backlog ensures full utilization of available craft labor while correcting material deficiencies on a priority basis.

l l

l Records of the backlog of MMS work have been maintained since the program's inception in March 1980. Formal records for any backlogs prior to that date do not exist.

With respect to plant modifications, all suggestions for improvements or items identified for evaluation by plant Engineering are collected by the Engineering Work Request System (EWR). This system categorizes, prioritizes, and stores these potential work items so they may be addressed in the order of their relative importance. Items of greater regulatory I or plant operation concern are addressed on a priority basis while those of negligible benefit or concern are held for future review. This reserve or backlog assures the full utilization of engineering resources.-

This orderly planning and scheduling process causes all significant projects to be budgeted, submitted for management review, and scheduled in the most efficient manner. It assures each project is properly integrated with overall 6

site needs and that the most effective use is made of financial and manpower resources as well as outage opportunities.

With respect to future years significant backfit work planned over the next several years is listed on the Brunswick Master Project Schedule. A copy of the current Master Project Schedule will be made available for Joint j

Intervenors' inspection at CP&L's General Office upon request.

ANSWER I-48:

Most of the items identified in Interrogatory No.1-48 may be considered to be important qualifications for safe management of a nuclear power plant. However, the context in which a particular qualification is considered determines how the qualification is important for safe management. Some of the qualifications listed are basic management practices; others are those which may be developed through experience or lessons learned over the years.

The only items listed which are in and of themselves indicative of poor management are those that imply intentional attempts to hinder or prevent safe management of nuclear plants. -

4 ANSWER I-49:

CP&Ils commitment to safe operation of its nuclear plants is illustrated in the Company's Conduct of Nuclear Operations Manual which, among other things, contains the Power Supply, Engineering and Construction Management Philosophy, the Corporate Quality Assurance Policy Statement, the Corporate Health Physics Policy Statement, and the Corporate Nuclear Safety Policy Statement. -

ANSWER I-50:

(a-f) The retaining wall was designed such that backfill of the Units 3 and ' 4 excavations would - neither affect ' the seismic response nor ' alter the structural analysis of the fuel bndling building (FHB).

l The retaining wall was designed by Ebasco Services, Inc. per the direction of the Manager - HPES and the design was released for construction in July 1983. Ebasco reports to the Manager - Harris Project Engineering Section.

As a result of NRC Staff reviews of the retaining wall design, settlement monitors will be provided sucli that CP&L may assure that settlement is consistent with design. Additionally, to ensure design adequacy over time, specimens of deadmen anchor tie rod material will be buried for future inspection.

By letter from CP&L to H. R. Denton of the Nuclear Regulatory Commission dated September 19, 1983, the NRC was provided additional information and the NRC requested further information in the Safety Evaluation Report (Section 2.5.5.6) which was published in November 1983. By letter to the i

Nuclear Regulatory Commission from CP&L, dated March 7,1984, CP&L provided further information requested in the Safety Evaluation Report.

(g-k) The items listed - hanger design, probabilistic risk analysis, riser and cable tray design, radiological assessment, site support and conduit supports - actually did not require additional engineering support. These were routine items to support the construction schedule which simply required more manhours to complete than was originally anticipated. Additional manhours for the scheduled activities were identified after the establishment of the 1983 budget. Thus, the work efforts required to accomplish these activities were additions to the budgeted scope of work. However, please note that these items were approved through normal approval channels and their accomplishment assured that the design schedule remained consistent with current construction activities.

4 Work on the conduit supports also involved routine work to support the construction schedule. Some additional conduit supports had been installed when, 1

. _-~ - . _ _ . . _ _ - . ._ ~.. . _. _ .u

I as construction progressed, it was found that supports were necessary in a few locations not called for in the original design. Applicants do not recall that problems, if any, with conduit supports were referred to in any LERs, noncompliances, nonconformances, etc., but will make such documents available for Joint Intervenors' inspection at CP&L's General Office upon request. The request for a list of nonconformances related to conduit supports in' the Harris containment building has been responded to by inclusion in the documents referred to in response to Interrogatory Nos.1-1 through I-5.

(1) The current schedule for engineering, procurement, construction, and testing activities is intended to achieve commercial operation of Harris Unit 1 in March 1986. As of September 30, 1983, construction was approximately four percent behind schedule, based on installed quantities. Weather-related factors and electrical design changes resulting from the NRC's Three Mile Island Action Plan are the primary reasons for construction progress being behind schedule.' As l

of December 31, 1983, construction was approximately $3% complete, based on i

installed quantities.

From the current stage of construction until commercial operation of Harris Unit 1, the construction scheduling and monitoring shifts from installed quantities to completion of systems and subsystems required to meet the remaining scheduled major milestones of cold hydrostatic testing, hot functinal testing, fuel loading, and commercial operation. CP&L schedules and monitors the release for testing of systems and subsystems which are required to support the major milestones. Some of the engineering, procurement, construction, and testing activities required to meet these major milestones are currently behind schedule; however, others are ahead of schedule.

1 i

l i

The first systems required to be tested and placed into service to support plant start-up are utility or support systems. These systems include electrical, compressed air, domineralized water, auxiliary steam, etc. They constitute the majority of the 282 subsystems scheduled for release through 4

1983. A cumulative total of 267 Release-For-Test items were turned over to the Operations start-up organization through the end of 1983. One of the primary  ;

4 reasons that some of the Release-For-Test items were delayed was cable tray revisions caused by the Three Mile Island mandated human factors review and the i

resulting modifications of the control room. Some of these modifications included fire barrier and seismic support relocations for the cable trays. Significant j management attention is being placed on recovery of the schedule in these areas, l>

Major systems and equipment tested and placed into service through 1983 includes

! electrical switch-gear and motor control centers, fire protection system, water l

~

treatment plant, demineralized water system, instrument and service air, waste neutralization system, auxiliary - boilers, chemical- feed system, process *:

- instrumentation cabinets, and nitrogen supply system.

Although some of the Release-For-Test items are behind schedule, CP&L believes the steps it is taking to accelerate activities in those areas simuld enable Harris Unit I to begin commercial operation in March,1986.

l The steps CP&L has taken. to accelerate activities include a

! restructuring of the Harris project organization. A vice president, who reports directly to the group executive for nuclear genere.tlon, was assigned full time to I the project site with direct line responsibility for all site functions with the <

I exception of quality assurance. Currently, the Harris Nuclear Project Department-a

is organized into five sections

engineering, construction, operations, project administration, and planning and controls. The Vice President, Harris Nuclear 4

I 79 1

i Project Department, has authority to direct and responsibility for all engineering, j

construction, start-up and testing, and operation and maintenance of the plant, i and he controls day-to-day site activities. Additional steps taken include the movement and consolidation of all engineering functions and responsibility to the i

- site. Also, the construction work force at the site has been expanded.

ANSWER I-51:

(a-e): Background information regarding the decision to conduct a comprehensive self-evaluation at the Brunswick plant is contained in the I

testimony of Mr. L. W. Eury before the North Carolina Utilities Commission in

! July of 1983 (Docket E-2, Sub 461) and in CP&L's May 2,1983 letter to the NRC.

Copies of this and other documentation will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. A copy of the i

! Brunswick Improvement Program (BIP) and CP&L's letter of trcosmittal which submitted that program to the NRC 'will also be made available. The specific j action items listed in the BIP illustrate the scope of the self-evaluation.

! CP&L senior management has followed the progress of the BIP very closely. NRC personnel also have closely followed the progress of the BIP through l

j frequent site visits and discussion with key personnel involved in the conduct of i

the BIP.

I in addition to the above, quarterly reports on the BIP status have been f provided to the North Carolina Utilities Commission beginning with Applicants' submittal of December 15, 1983. Also in April 1984 CP&L received a letter from the NRC indicating that CP&L had satisfied the requirements imposed by Confirmatory Order EA-82-106.

Based on our expeaience at Brunswick, improvement programs were

, l 2 also formalized at Robinson and Harris. Copies of these programs will be made i

available for Joint Interv9nors' inspection at CP& Ifs General Office upon request.

O .

1 (f-g) The reasons for the effort to upgrade Brunswick plant procedures I

were discussed in the testimony of Mr. L. W. Eury before the North Carolina.

i Utilities Commission in July 1983 (Docket E-2, Sub 461). A copy of the pertinent

{

pages from that testimony will be made available for Joint Intervenors' inspection i

! at CP&L's General Office upon request.

(h) The procedure rewrite effort undertaken as part of the BIP involved the review and revision of approximately 133 Operating Procedures,2700 Annunciator Procedures, and 121 Operational Periodic Tests. Due to the large i work effort involved, a consultant was used to provide additional personnel resources so that this project could be completed in a timely manner.

! (i) The procedure rewrite effort was conducted under the supervision and direction of a CP&L Project Engineer who was also a lleensed reactor operator.

(j) The procedure rewrite effort involved a multidisciplinary review of I

l the procedures prior to their approval. All of the procedures were determined to i

i be adequate prior to their approval (k) The procedure rewrite effort identified in the BIP involved l Operating Procedures, Annunciator Procedures, and Operational Periodic Tests.

[ Most other procedures at Brunswick, such as Maintenance Procedures, Fire Protection Procedures, etc., are also being reviewed and revised to improve j i

formats, quality, etc. These additional review efforts are not part of the formal i

BIP.

I The decision regarding the scope of the procedure review effort in the i

BIP was made by CP&L management.

(1) The operational procedure review was completed by the end of 1983 as scheduled.

4 l

(m) The operational procedure review referenced in the BIP has been completed.

c (n) Generally procedures are developed on a functional basis, i.e., ,

operations personnel develop operating procedures, maintenance personnel develop maintenance procedures, etc.

The CP&L Procedure Administration Manual establishes the criteria for procedure development, revision, and approval at its nuclear plants. A copy of this manual will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

(o) See response to Interrogatory No.1-51.(n).

(p) All procedures go through formal review and approval steps that involve various levels of supervision; thus no single individual can write, approve, or implement a procedure. Given this process, the question has no meaning.

(q) Not applicable.

(r) Procedures being used at Brunswick are considered to be adequate and in compliance with applicable NRC regulations when approved. If, at any time, a procedure is subsequently determined not to be adequate, the procedure is revised to make it adequate.

ANSWER I-52:

A copy of each and every report and any draft (s) in CP&L's possession by Management Analysis Company concerning CP&L's Corporate Quality Assurance Program, as referred to in Interrogatory No.1-52, will be niade available for Joint Intervenors' inspection at CP&L's General Office upon request.

ANSWER I-53:

CP&L's commitments and resolutions regarding- the MAC recommendations were submitted to the NRC by letter dated April 7,1983. A i

copy of this letter will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

l ANSWER I-54:

(a) Because of Management Analysis Company's reputation and experience with respect to evaluating, assessing and auditing quality assurance programs within the nuclear-related utility industry.

(b) CP&L's Executive Vice President for Power Supply and Engineering

& Construction Group, to whom the Manager - Corporate Quality Assurance Department directly reports.

Contract No. 82-NO-49, dated July 20, 1982 between Management Analysis Company and CP&L.

(c) C P & L's Corporate QA Department had been formed as a department in early 1981 by consolidating the QA/QC functions that had previously been performed by three separate departments within CP&L. CP&L's senior management desired to have an independent review and assessment of its overall quality assurance program in meeting short and long-range commitments 1

to provide more efficient and effective QA/QC within CP&L. This decision was not based on any inadequacies or problems with Corporate QA Department's handling of past Brunswick quality assurance problems but on a commitment and desire to identify opportunities for achieving basic improvements of a continuing and long-range nature in quality assurance performance within CP&L.

1 (d) Management Analysis Company was asked with respect to CP&L's Corporate QA to provide a management assessment of CP&L's programs and commitments in order to achieve improvements of a continuing and long-range 1 nature in CP&L's quality assurance performance.

There were no areas Management Analysis Company was prohibited from inquiring into concerning QA or QC.

ANSWER I-55:

It is CP&L's practice to keep information relating to the medical history of CP&L employees in the strictest of confidence. However, to CP&L's knowledge, none of the persons referenced in Interrogatory No.1-55 has been diagnosed or treated for psychosis or depression; nor has been unable to perform his duties because of psychological problems.

4 ANSWER I-56:

The MAC Report concerning methods for reducing outside demands on the Brunswick Plant Staff will be made' available for Joint Intervenors' inspection at CP&L's General Office upon request.

(a-d) An assessment of the MAC Report, including individual responses to recommendations, was provided to the NRC in a letter from Mr. P. W. Howe, Vice President - Brunswick Nuclear Project, to Mr. J. P. O'Reilly,- Director - U.S.

Nuclear Regulatory Commission. A copy of that letter willbe made available for Joint Intervenors' inspection at CP&L's General Office upon request.-

(e) Yes.

(f) Senior management has always been concerned that undue outside demands not be placed on the plant stalfs of operating plants. " Undue outside demands" refers to such matters as requests for assistance and information which tend to detract plant personnel from their primary responsibility of operating and l maintaining the plant.

1 (g) CP&L decided to have MAC do a study of outside demands on the Brunswick plant staff in September 1982. This study was conducted as part of the BIP. MAC was selected by CP&L management on the basis of its qualifications and experience. -

84 -

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ANSWEll I-57:

(a) A copy of the Shift Foreman Time Utilization Study will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. Documents that requested, discussed, or implemented the recommendations of this study will be made available for Joint Intervenors'-

I l inspection at CP&L's General Office upon request.

I An implementation schedule for addressing the recommendations in the Shift Foreman Time Utilization Study was developed as part of the BIP,(Item VII-4). On January 11, 1983, the initial completion date for the implementation plan and schedule was extended from January 1983 to March 1983 by the Plant General Manager with the approval of the Vice President - Brunswick Nuclear Project.

(b) Twelve.

(c) Ten.

(d) The Work Force Performance Development Section of CP&L.

(e) The Brunswick plant General Manager requested the study as part of the BIP.

(f) The plant General Manager and the Manager - Plant Operations.

(g) The plant General Manager and the Vice President - Brunswick Nuclear Project. ,

(h) Of the five recommendations made in the Task Analysis-Brunswick Operations Shift Foreman Report, two were not implemented. The.

documentation - discussed in Subpart (a) above discusses the basis for not implementing these recommendations.

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• gy 4- N

ANSWER I-58:

Turnover of the supervisory personnel at Brunswick during the period from 1975 to 1977 was discussed in detailin the Harris ASLB Remand Hearings which were held in March of 1979. CP&L witnesses in those hearings outlined the actions that had been taken to resolve the turnover problem. See response to j Interrogatory No.1-40. CP&L does not consider that there has been a problem with turnover of middle and upper management at Brunswick since the time period discussed in the Remand Hearings.

ANSWER I-59:

No, CP&L selects personnel to fill management positions that meet applicable Company and regulatory requirements for the position being staffed.

ANSWER I-60: -

(a) CP&L does not believe that there has ever been a period in which the size of the Brunswick plant staff was inadequate to operate and maintain the plant safely and adequately. As discussed in our response to Interrogatory No.

1-47(c)(xii-xiii), there have been periods during which the size of the plant staff was less than CP&L would have desired. During such periods, CP&L has 1

l established priorities to ensure that work important to the safety of the plant has been accomplished while deferring nonessential work to later periods.

(b) CP&L's program, practices and experience with respect to extended work weeks and overtime at the Brunswick Plant was reviewed on the record of the Harris Remand Hearings which were held in March of 1979. CP&L -

does not consider that there has been a problem with extended work weeks and/or the amount of overtime being worked at Brunswick since that time.

l ANSWER I-61:

Problems have been identified by the NRC to CP&L regarding the l

Brunswick Plant. These problems have been documented in NRC inspection '

i reports and the SALP reports, and have been replied to accordingly. These, in turn, have been addressed in response to Interrogatory Nos.1-1 through I-8.

ANSWER I-62:

(a) (i) On June 30, 1980, CP&L submitted comments to the NRC regarding the proposed amendments to the Commission's fire protection regulations.

(ii) In 1980 CP&L obtained a complete Safety Evaluation Report from NRC for compliance at Brunswick with the fire protection guidelines set forth in Appendix A to Branch Technical Position Auxiliary Power Conversion System Branch 9.5-1 " Guidelines for Fire Protection for Nuclear Power Plants

) Docketed Prior to July 1,1976," dated August 23, 1976. Subsequent to this, NRC significantly revised its fire protection criteria. CP&L has taken significant steps to implement these regulations as quickly as appropriate means can be identified. Significant fire protection measures currently installed at the 1'

Brunswick facility include a remote shutdown system; suppression for major safety-related components; wraps, barriers, and localized suppression for protection of safety-related cables in close proximity to each - other; a strengthened fire brigade; and a detection system that is in. compliance with Appendix R. CP&L is currently implementing Appendix R modifications to the

't Diesel Generator Building Hatch covers and installing Cable Spread Room suppression systems. With NRC's approval, CP&L has been conducting an Alternative Shutdown Capability Assessment (ASCA) which is due to be filed with the NRC on April 30, 1984. The Brunswick facility is currently equipped with a 4

87 -

1 very high level of protection against fires which will be even further enhanced by modifications which CP&L will make resulting from ASCA study.

(iii) The Court of Appeals for the District of Columbia Circuit l

held that the NRC's fire protection regulations had been validly promulgated.

(b) Relevant documents will be available for the Joint Intervenors' inspection at CP&L's General Office upon request.

ANSWER I-63:

(a) As a result of the ASLB decision, CP&L sub'nitted a Management Capability Report to the NRC for review and has continued to issue revised Management Capability Reports as appropriate.

(b) No.. CP&L has, however, made significant improvements in its management system since that time.

, ANSWER I-64:

) (a) Copies of CP&L responses dated May 2,1983 and July 27,1983 will be made available for the Joint Intervenors' inspection at CP&L's General Office upon request.

(b) Other documents detailing or discussing actions CP&L took in i response to this notice of violation will be made available for Joint Intervenors' J

inspection at CP&L's General Office upon request. A detailed summary of CP&L actions taken in response to this notice of violation is contained in the May 2, i 1983 response to the violation. In addition, a copy of the BIP submitted to the NRC on October 29, 1982 will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

ANSWER I-65:

A review of CP&L's files indicates that the response to Interrogatory. !

No.1-65 is no.

ANSWER I-66:

A system of reporting of installed quantities was implemented as bulk quantitles installation began at the start of construction in early 1978. Also random verification of installed quantities reports was implemented at that time. As the project progressed and mechanical and electrical systems installation became active, the procedure was expanded to also include collecting data on, and verifying quantities related to, these types of installations. A procedure was formalized in March 1982 and further updated in 1983.

This procedure was initially formulated in 1982 as a stand-alone document entitled " Quality Monitoring Procedure for SHNPP." In March 1982, the procedure was included in the Harris Construction Procedures Manual as an administrative procedure entitled " Quantity Survey." Copies of these documents as well as copies of forms used to report installed quantities of concrete, rebar, steel, hangars, ductwork, instruments, etc. will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

The system was put in place as a cost / productivity and schedule monitoring tool. It is normal practice' to implement such a system and did not require a specific " order." ,

Verification of quantities installed is accomplished from engineers' installation records for concrete placements, electrical pull cards, construction control system (computer tracking program) for piping and hangers (maintained by CP&L engineers), and visual verification. Some handwritten records have been maintained in files for the visual verifications. Verification records along with analyses of variance, percentage of quantity verified, and percentage of error in l

quantity reported are maintained. A summation of the bulk quantities installed and verification thereof is contained in the quarterly reports made by CP&L to

the North Carolina Utilities Commission. Copies of such reports will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.

ANSWER I-67:

l In August 1983 Applicants strenghtened their " project control systems" on the Harris project by restructuring that project's organization. Previously, operations, con'struction, and engineering had reported through their own separate i

company vice presidents. In 1983 these three sections were directed to report through a single vice president in order to facilitate communications and increase efficiency. In addition, two new sections were established out of the three previous ones - Project Administration, and Planning and Controls - for more effective operations.

ANSWER I-68:

(a) The report prepared by Cresap, McCormick, and Padgett (CMP),

will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. It contains all the recommendations CMP made pertaining to operating personnel at Brunswick. j l

(b) See response to I-68(a) above. A report discussing CP&L's response l to the CMP recommendation is being drafted and is scheduled to be complete in l May 1984. A copy of that report will be made available for Joint Intervenors' inspection at CP&L's General Office when complete.

1 (c) Yes.

(d) CP&L does not consider that there is a shortage of repair and maintenance personnel at Brunswick at this time.

(e) The Brunswick Operations group is considered to be fully staffed at the present time. At any given time, a few of the slots in the organization may be vacant'as the result of terminations or transfers until new personnel can be hired or transferred into the group.  !

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ANSWER I-69:

(a) The report prepared by CMP will be made available for Joint i

Intervenors' inspection at CP&L's General Office upon request. This report contains all of CMP's recommendations and considerations pertaining to 3

construction backlog at Brunswick.

(b) See response to Interrogatory No.1-69(a).

(c) A copy of a report discussing CP&L's response to the CMP i recommendation will be made available for Joint Intervenors' inspection at CP&L's General Office upon request.  ;

(d) See response to Interrogatory No. I-69(c).

(e) See response to Interrogatory No.1-47(xiv-xvi) and I-69(c).

) ANSWER I-70:

i Copies of the CMP report and CP&L's report describing actions taken l.

or planned in response to CMP's recommendations related to outage management  ;

4 will be made available for Joint Intervenors' inspection at CP&L's General Office i

I upon request.

I ANSWER I-71: <

(a) There is no formal experience profile for the Brunswick or Robinson 2 operating crews. As requested by NRC letter dated December 9,1983, 4

CP&L prepared an experience profile for its Harris operating crew and submitted i

the requested survey sheets by letter dated December 16, 1983. CP&L was not ,

requested to prepare information for Robinson 2 or Brunswick operating crews.

(b) CP&L has not begun to develop an experience profile for the i

Brunswick or Robinson operating crews subsequent to the meeting announced (as referred to) in Mr. John Hannon's (NRC) January 17, 1984, memorandum to j operating license applicants. The Harris ' experience profile was prepared prior to the January 17,1984 meeting notice. )

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l (c) CP&L did participate in the Jariuary 26, 1984 meeting with the i

i NRC Staff. .

i l (d) The following NRC' sad CP&L letters relate to the above matter

\ .

December 9,1980 NRC Ictter to CP&L 3

4 December 16,1983 CP&L letter to NRC

{

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• January 6,1984 NRC Generic Letter 84-02 l January 17,1334 NRC Meeting Notice t

i March 1,1984 NRC Melting Summary i

These documents y'lll' be made avaliable foe Joint Intervenors' (

)

j inspection at CP&L's General Office upon request. ,

ANSWER I-72_ . , l 4

i (a) For CP&L senior management, performance evaluations are made

? .

on a continuing basis by the pecticular executive's immediate superior. In the case

].

i of the President, the evaluntion is performed by the Board of Directors. Records  ;

l of evaluations are not kept. ,

(b) The Management Capability it[ port was originally written in 1979 and has been periodically rNised. The Managsment Capability P.eport submitted on January 10, 1984 is an updated version of the.Mari4gement Capability Report l

j updated and submitted on August 4,1983. The CP&L Nuclear. Licensing Section i

j has been the coordinator for ' updating tNs report. Appropriate individuals within j the applicable CP&L organizations review and revise the report during updating i and the revised report sections are transmitted back to the Nuclear Licensing i Section through the aporopriate organization managers. Identification of au the' l individual contributors to the Management Capability Report since 1979 has not i ,

j been maintained and it would be impracticable and unduly burdensome to attempt . .

l to make such identifications.

i -

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g e c.._.- -, _, . . m --

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(c) CP&L employees undergo a periodic review of their job performance. These performance appraisals are conducted by the employees' supervisors, i

(d) The technical personnel who are associated with CP&L's nuclear plants or who are members of the Corporate Nuclear Safety and Research Department are aware that they can take safety-related issues directly to senior management if they so choose. This has been orally stated by senior management on numerous occasions and is a part of written Company policy. Therefore, any individual who believes that the Vice President - Corporate Nuclear Safety and Research is not properly responding to his duties has a channel for bypassing this office in order to ensure that senior management is properly informed on safety Issues.

There have been no instances of communication in the above fashion with the Chairman / President or other senior management regarding a failure of the Vice President - Corporate Nuclear Safety and Research to respond satisfactorily to issues.

ANSWER I-73:

Applicants interpret this question to be referencing the Senior Management Oversite Function as described in Section 3.4 of the January l'384 Harris Management Capability Report.

Currently, CP&L senior management has retained the assistance of two consultants to assist in the Senior Management Oversite Function. These consultants are:

-Mr. L. F. Sillin, Jr.: Previously Chairman and Chief Executive Officer of Northeast Utilities; currently Chairman, Executive Committee, of Northeast Utilities.

l l

f I.

-Mr. G. C. Hurlbert: Previously President, Power Systems Company, Westinghouse Electric Corporation; currently President, GCH Management Services, Inc.

In addition to the assistance of these consultants, examination of the Senior Management Oversight Function has occurred in the following ways:

1. Examination of this function is inherent in the audits, reviews, and assessments conducted by the NRC. Documentation regarding these reviews would be contained in the documentation provided in response to Interrogatory Nos.1-1 through I-8.

2. The Management Analysis Company's review of CP&L's Corporate QA Program (see response to Interrogatory No.1-52).

3. The Institute of Nuclear Operations (INPO) reviews of Brunswick

! and Robinson.

4. Reviews of CP&L's Health Physics Program conducted by Dr. Ralph Lapp.

5. The External Review Panel Report (August 18,1982). See the response to Interrogatory No. I-51.

6. The Sol Levi & Associates report," Evaluation of Corporate Nuclear Safety Section," February 1984.

7. The 1982 management study of Carolina Power & Light Company conducted by Cresap, McCormick and Paget. (See response to Interrogatory No. I-26.)

Applicants believe that the Senior Management Oversight Function is properly implemented and provides the oversight required for Applicants' nuclear programs. When potential improvements in this function are identified, they are I evaluated and implemented if appropriate.

.\

. - . . , * ^\

,- , .. . - , , - , - , . , , + , - , , . -

ANSWER I-74:

Table 3.1 of the Management Capability Report contains information on all plant management and supervisory personnel includihg total work i

i experience and total nuclear plant experience. Applicants do not maintain the additional information requested in this Interrogatory in the form requested and assembling such information for all such persons would be unduly burdensome.

However, the information requested concerning individuals holding management-

) level positions in the Harris Plant Operations organization is contained in the l

following table:

Other Length of l Nuclear Plant Experience At Experience At Operating PWR l Job Title (excluding Navy) (excluding Navy)

Plant Manager San Onofre 1 year Manager - Plant Operation * (position vacant) -

Assistant to General Manager Brunswick -

. Manager - Technical Support Brunswick -

4 Manager - Maintenance - -

Manager - Operations Robinson 7 years Manager - Start-up Brunswick -

Manager - E & RC Seabrook, Vermont Yankee -

Director - Regulatory Compliance Robinson, Brunswick 5 months To Applicants' knowledge, none of these persons has been fired or disciplined in connection with work at any nuclear plant.

i ANSWER I-75:

4 (a) The purpose of the " degrees / person" figure in Table 3.2 of the Management Capability Report is to emphasize the fact that many CP&L l personnel have bachelor's and advanced degrees.

(b) Yes.

• CP&L is currently evaluating the need for this - position based on .the current Harris Nuclear Projection Organization. A decision to fill the position will not be made until our evaluations are complete.

,_ , . . - - - . _ ._- . . ~

(c-d) Table 3.5 of the Management Capability Report provides a complete breakdown by section and degree type of each group listed in Table 3.2.

The degree categories requested have been extracted from Table 3.5 and are provided as Attachment I-75(e-d).

ANSWER I-76:

A formal policy for administration of examinations was issued in 1980 in the Training Manual for Nuclear & Fossil Operations Personnel. These guidelines have been periodically updated and will be made available for Joint Intervenors' inspection at CP&L's General Offie upon request. Prior to publication of this formal policy, examinations were administered using precautions against cheating such as treating all examinations as " confidential," use of proctors, and physicalseparation of candidates being tested.

Selected examinations have been reviewed by CP&L management and the NRC. CP&L has discovered no evidence of cheating on~ examinations.

Some test questions used in CP&L training have duplicated old NRC questions. However, since the objective is to learn and relate on examinations knowledge and facts important to safe and reliable plant operation, it is not surprising that some information would appear on both CP&L and NRC exams. In fact, the NRC returns graded exams to the candidates to help correct weak areas. They also return a blank copy of the exam and an answer key to the utility. Although CP&L has never requested permission to use old NRC questions, there are no NRC rules that prevent use of these questions. In 1983, the NRC requested that utilities share with the NRC questions developed for use in training programs. This has resulted also in joint use of questions.

ANSWER I-77:

. Does not require an answer.

i l

AN5WER I-78:

(a) Reports to the Company's stockholders and to the SEC, and the l

FERC Form 1 Report are prepared under the direction of the Company's senior management.

(b) Organizational changes within the corporate structure have from time to time resulted in different senior level positions assuming different responsibilities. However, senior management's role with regard to these reports generally remains unchanged.

(c) Events of interest to shareholders are discussed in the Annual and Quarterly Reports to stockholders, including nuclear matters or other matters.

In addition to the Annual and Quarterly Reports to stockholders, the i

Company summarizes matters of interest that are discussed at the annual stockholders' meeting and reports this information to the stockholders. Copies of the Annual Reports, Quarterly Reports, and the Summaries of the Annual-Stockholders' Meetings dating back to 1964 or the first year of issuance if after 1964, to the extent available within the Company, will be made available for Joint Intervenors' inspection at CP&L's General Office upon request. Generally these.

reports provide information related to the Company's nuclear program and corporate management achievements.

(d) There is no record or recollection of an interview by Mr.

Sherwood H. Smith, Jr., or any member of Senior Management, with Mr. Mark i IIertsgaard.

(e) Applicants have transcripts or summaries of the following interviews with Mr. Smith which will be made available for Joint Intervenors'.

I mspection at CP&L's General Office upon request:

e

l

1. News and Observer, September 30,1982 I

2. NBC-TV News, January 12,1982

3. News and Observer, May 6,1982 l

4. NBC-TV, February 2,1984.

ANSWER I-79:

CP&L has received numerous awards and other recognition for the manner in which it and its various divisions conduct their activities. Those awards and other recognition which CP&L has received since 1972 are listed below.

Documents describing these items in more detail will be available for the Joint Intervenors' inspection at CP&L's General Office upon request:

L W. H. Weatherspoon Plant, CP&L all-time safety record, one million hours of work without a doctor-attended injury.

September 13,1983

2. Electric Institute 1982 Accident Frequency Award, lowest frequency rate of disabling work injuries (7th consecutive' year)

July 8,1983

3. Edison Electric Institute 1983 Man-hour Safety Achievement Award,3 million hours without a lost work-day accident (8th consecutive year)

July 8,1983

4. N. C. Department of Labor 1982 Man-hour Safety Award (5th consecutive year)

July 8,1983

5. N. C. Department of Labor 1982 Certificate of Safety Achievement (4th consecutive year)

July 8,1983 ,

I

6. N. C. Department of Labor Certificate of Special Recognition, W.

H. Weatherspoon Plant,1.7 million man-hours without a single lost-time injury May 20,1983

7. American Society of Mechanical Engineers, Outstanding Leadership Award, Mr. Sherwood H. Smith, Jr., CP&L Chairman and President May 17,1983

8. National Safety Council Award of Honor for 1982 May 13,1983

9. National Safety Council 1982 Public Utilities Safety Contest First Place Award (10th consecutive year)

, May 13,1983

10. S. C. Occupational Safety Council Award, lowest incident rate of lost-time accidents in 1982 ,

l May 10,1983

11. S. C. Occupational Safety Council Award, lowest incident rate of lost-time accidents in 1983 April 9,1984

12. S. C. Occupational Safety Council Award for II. B. Robinson 4

Plant,1982 safety record May 10,1983

13. Southeastern Electric Exchange 1983 Safety Performance Award 1 (llth consecutive year)

February 8,1983 99 -

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14. Southeastern Electric Exchange 1982 Fleet Safety Award February 8,1983

15. N. C. Utilities Commission-ordered audit by Cresap, McCormick

& Paget, Inc. found that "In many respects CP&L is one of the i

best-managed utilities that we have audited in the past several

years."

December 15,1982 1

16. Roxboro Plant, Units 3 & 4, 200,000 man-hours without a doctor-i attended injury

October 15,1982 i

17. State of South Carolina Award, H. B. Robinson Plant, 5 years without a lost-time accident September 2,1982 i

' 18. Edison Electric Institute Frequency Rate Safety Award for 1981 (6th consecutive year) ,

August 19,1982

19. National Safety Council Public Utilities Section Safety Contest Award for 1981 (9th consecutive year) 1 April 14,1982

! 20. National Safety Council Award of Honor for 1981 March 16,1982

21. Southeastern Electric Exchange 1981 Safety Performance Award (9th consecutive year)

January 29,1982

22. Southeastern Electric Exchange 1981 Fleet Safety Award (6th year)

January 29,1982

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23. Yeargin Construction C'ompany personnel, Brunswick Plant, over two million man-hours without a lost-time accident December 30,1981 1 24. Edison Electric Institute 1980 Frequency Rate Safety Award (5th consecutive year)

October 13,1981

25. National Safety Council 1980 First Place Award (8th consecutive year)

October 13,1981

26. W. H. Weatherspoon Plant, 600,000 man-hours without an on-the-job accident which required a doctor's attention June 24,1981

27. Southeastern Electric Exchange 1980 First Place Safety Award (8th consecutive year) i 1

April 8,1981

28. Edison Electric Institute 1979 Safety Award (5th consecutive year)

May 15,1980

29. Southeastern Electric Exchange 1979 First Place Safety Award (7th consecutive year)

May 15,1980

30. Named American Society of Mechanical Engineers Fellow, l Mr. J. A. Jones, chief operating officer l

February 20,1980

31. National Safety Council 1978 First Place Public Utilities Safety Award (6th consecutive year)

November 19,1979 ,

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32. Edison Electric Institute 1978 Safety Award (3rd consecutive year)

November 19,1979

33. U. S. Department of Energy First Place Power Plant Efficiency Award June 16,1978

34. Edison Electric Institute 1976 Frequency Itate Safety Award 4

November 30,1977

35. N. C. Utilities Commission-ordered audit by Booz, Allen &

Hamilton concluded that CP&L performs in a " cost effective" manner February 1,1977

36. Federal Power Commission Efficiency Rating (CP&L 3rd in the nation)

April 2,1976

37. N. C. Society of Engineers " Outstanding Engineering Achievement" Award, Mr. J. A. Jones, executive vice president March 5,1974

38. Electric Light & Power Magazine Outstanding Electric Utility of the Year for 1973 November 6,1973

39. All-time company annual safety record in 1971 by completing the year with only eight lost-time accidents January 20,1972

40. N. C. Department of Natural Resources and Community Development Certificate of Recognition for protection of the

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state's largest population of the endangered plant species, the I Cooley's Meadowrue February 29,1984

41. N. C. Department of Natural Resources and Community Development Certificate of Recognition for registration by CP&L of the Pee Dee Gabbro Slopes as a N. C. Natural Heritage Area l

March 9,1982 ANSWER I-80: ,

(a) CP&L does not routinely maintain such information; however, Applicants are not aware that any such persons has been indicted or tried on felony charges.

(b) CP&L does not routine:y maintain such information; however, Applicants are not aware that any such person has stood charges before a military court martial.

O (c) None of those persons has been Eonvicted of a felony or adjudged guilty by a court martial (d) Other than one person who nas convicted of underage possession of i alcohol, none of those persons has been convicted of a misdemeanor other than a-

! traffic offense.

i ANSWER I-81:

(a) Following ,is a list of reports regularly received by the i

Chairman / President, Sherwood H. Smith, Jr., from the Nuclear Generation, Fossil .

Generation and Power Transmission, and Operations Support Groups.

! REPORT FREQUENCY Daily Status Report . Daily i Unit Availability Report , Daily

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Daily Operating Report Daily Monday Morning Report Weekly Progress Pictures of Harris Construction Monthly Oral Report from Vice President of Corporate Approximately Nuclear Safety blannually Customer Minutes Out of Service Monthly System Load & Production Plan Quarterly Unit Capacity Factor, Output, and Availability Biannually (b - c) Mr. Smith reviews each report, with the exception of the Daily Status Report and the Daily Operating Report, and takes such action as is appropriate given the nature and content of each report. With respect to the Daily Status Report and the Daily Operating Report, a member of his staff reviews them and provides Mr. Smith with pertinent information from each report.

i ANSWER I-82:

It would require an excessive amount of time to identify with specificity every report and.other communications received by the Executive Vice President Power Supply, Engineering and Construction. A list of some of the more significant reports or communications regularly received by the Executive Vice President Power Supply, Engineering and Construction is presented below. In addition, reference is made to CP&L's Management Capability report, the Senior Management Oversite Section, for a discussion of the Senior Management Oversite function.

Daily Operating Report Daily Status Report Daily Unit Unavailability Report

- 104 -

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l Monthly and Quarterly Budget Status and Cost Reports Monthly, Quarterly, and Annual Personnel Reports 1 1

- Monthly, Bi-monthly, and Quarterly Safety Reports (such as LER Trend Analysis, ALARA Status, etc.)

Quarterly Status of Goals Quarterly Forced Outage Statistics Report Semiannual and Weekly Fuel Status Reports Quarterly Productivity Trends Report Monthly Power Interruptions to Customers Report Monthly Nuclear Operating Plan 1

Monthly Power Estimate Report

- Planned Unit Outage Schedule (as changes are made)

Monthly Minutes of Nuclear Outage Planning Meeting 4 -

QA Audit Reports as audits are completed Specified Department Monthly Activity Reports l -

Weekly Facility Automated Commitment Tracking System (FACTS) Management Report Nuclear Plant Projects' Monthly Report Weekly Nuclear Plant Status Report Monthly Senior Management Review Presentation Report i

Semiannual Compartative Performance Indicators Report Load / Energy Forecasts (annual or when updated)

Planned System Expansion for coming year Report (as updated)

Monthly Base Load Power Plant Performance Report Company Weekly INFO Briefs and News Releases (as necessary)

Industry Publications Magazines, Newsletters, Newspaper

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1 I

clippings (a) Frequency of repc-ts is as indicated in listing above.

(b) The action required is dependent upon the individual report.

(c) Meetings regularly conducted to review reports or communications:

- Monthly Nuclear Senior Management Meeting (attended by the Executive Vice President)

- Monthly Outage Planning Meeting (attended by the Executive Vice President)

(d) Minutes of meetings available from the Executive Vice President's office are:

Monthly Outage Planning Meeting (e) Formal followup procedures and logs are not maintained.

ANSWER I-83:

It would require an excessive amount of time to identify with

• specificity every report and other communications received by the Senior Vice President - Nuclear Generation. The following is a list of some of the more significant reports or communications regularly received by the Senior Vice President - Nuclear Generation:

Daily Operating Report Dcily Status Report Daily Unit Unavailability Report Weekly Reports from Group Managers i

Weekly Nuclear Generation Staff Meeting Minutes l

Weekly Facility Automated Commitment Tracking System (FACTS) l Management Report -

- 106 -

Weekly Construction Progress Reports Monthly Budget Status and Cost Reports Monthly Personnel Reports Monthly Safety Reports (such as bimonthly LER Trend Analysis, j monthly ALARA status, etc.)

Monthly Power Estimate Monthly Nuclear Operating Plan Planned Unit Outage Schedule Monthly Agendas for Project Review Meetings Specified Department Monthly Progress Reports Monthly Nuclear Senior Management Review Report Quarterly Status of Goals Master Project Schedules as Issued Exceptional Hours Report - Every Two Weeks QA Memos Documenting Reportable /Potentially Reportable items to NRC Nuclear Licensing Notices of incoming NRC and INPO Correspondence Company Weekly INFO Briefs and News Releases (as necessary)

Industry Publications - Wall Street Journal, Magazines, Newsletters QA Audit Reports - As Audits are Completed (a) Frequency is as indicated, (b) Action required is dependent upon the individual report, (c) Meetings regularly conducted to review reports or communications:

Weekly staff meeting with Group Managers (conducted and attended by Gro@ Executive)

- 107 -

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j Monthly project review meetings (attended by Group Executive) i Monthly nuclear senior management meeting (attended by Group l Executive) .

1 1 Monthly outage planning meeting (attended by Group Executive) i <

(d) Minutes of meetings available from the Group Executive's office 1

are:

i

Weekly staff meeting minutes Monthly nuclear senior management meeting minutes i

(e) There are no formal follow-up procedures. The secretary to Group Executive maintains a notebook of open action items due to the Group l Executive. As responses come in, she pulls the request fw action and attaches it i

to the responses if a copy is not already attached. One or two days before items i

are due, she calls the appropriate manager and reminds him of the due date. A ,

duplicate notebook is updated for and maintained in the Group Executive's 1 office. Formallogs are not maintained.

i i ANSWER I-84:

4

The Manager-Environmental and Radiation Control, the Environmental and Chemistry Supervisor, and the Radiation Control Supervisor of the Harris l

Plant Operations Section have

! a. No authority to order plant shutdowns, i 1

, b. The authority to recommend plant shutdowns. The final decision ,

l rests with the shift foreman. (The Manager-Environmental and Radiation Control

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has a direct communication channel to the Plant Manager on matters petalning to plant chemistry or health physics.)

i

! c. The authority to recommend specific power levels.

d. The authority and responsibility to report to individuals other than i

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their immediate supervisors in matters affecting plant operations,

e. The authority to request or order other information collection activities such as air quality or water sampling to verify that no harmful effects j are taking place. He could also order sampling of internal functions or primary systems.

1 ANSWER l-85:

The Vice President - Corporate Nuclear Safety and Research receives numerous reports and communications that originate from both outside of the Company and from within. Outside reports include NRC reports on unusual events, results of NRC studies or recommendations on technical issues, NRC SALP reports on other utilities, EPRI summary reports and abstracts from nuclear safety research projects, INPO reports on utility issues or INPO policies, INPO i significant operating experience reports, and miscellaneous technical reports from i

PWR and BWR Owners' Groups, the Edison Electric Institute, AIF Committees, i

and special EPRI groups such as the Nuclear Safety Analysis Center. Internally

! generated reports include monthly activity reports, system assessments on nuclear l

systems, quarterly reports on progress toward department goals, bimonthly LER trend analyses, bimonthly status reports on nuclear safety concerns and recommendations, bimonthly reports on NRC noncompliance, monthly ALARA status reports, quarterly minutes from the _ Nuclear Safety Review Board, l

' memoranda related to specialinvestigations conducted by all department sections, i and various administrative reports that cover budget status, personnel  !

complements, and professional personnel to secretary ratics.

Report frequency has been identified above in those cases where a i

j prescribed frequency is designated and other reports such as reactor system i . assessments are prepared and distributed upon completion of the designated 9

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l investigations. Those outside reports that specify recommended actions are i

handled as operating experience feedback items and are processed through the f OEF review mechanisms. The Vice President for Corporate Nuclear Safety and i

j Research may elect to initiate actions or recommendations from technical data in I

! other reports based upon his cognizance of what is important and necessary for plant safety. Internally generated documents typically specify follow-up actions

! and these are handled in accordance with defined department procedures.

3 i

Meetings involving department personnel or individuals outside of the department are held as required to resolve technical issues and with a scheduled frequency of 1

every two weeks with section managers for a technical overview. Presentations -

]

and discussions of nuclear safety issues with senior management occur at least quarterly with the Executive Vice Prendent, semiannually with the Chief i Executive Officer, and annually with the Board of Directors.

l ANSWER I-86:

Yes. nee a facility is operational a " key card" system maintains I access control. A card is inserted into the card reader. If the attempted entry is valid, the individual is admitted. The name and time of entry / exit are recorded in the computer memory and retained for a period of time.

ANSWER I-87:

1 i (a - c) Facility access information referred to in the response to l Interrogatory No.1-86 is not contained in any report or other written document l which provides an answer to this interrogatory.

4 (d) Because the data available is not in the form contemplated by r i Interrogatory No. I-87(a-c), Applicants assessment of the time spent at the Brunswick and Robinson by the groups inquired about is as follows: Both the Corporate Nuclear Safety Department and the Corporate Quality Assurance

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Department have staffs assigned to our nuclear plants on a full time basis.

Personnel from these organizations are in the plant on a routine basis as part of their job responsibilities. In addition to other time inside the plant, the managers

{

on the operating staff normally tour specific plant areas as a group on a weekly Msh.

ANSWER I-88:

I It is intended that upon commencement of operation, those individuals

)

i entering the protected area will be logged into the area. Logging will be l performed as described in response to Interrogatory No. I-86, with records j normally maintained for one year.

1 ~

ANSWER I-89:

(a - f) As set forth on page 2-24 of said Report, the " Manager -

QA/QC Brunswick and Robinson Plants and staff are responsible for . . . b. .

l.

l Reporting quality-related problems for correction." There are numerous methods t

l for the respective on-site QA/QC organization to re[iort quality-related problems

! to appropriate respective plant management. These methods range from informal 4

meetings to formal monthly reviews with the respective plant management as well j

as a series of written communications, including monthly reports of nonconformance activities and trends, written requests and responses for l

1 information, review comment sheets, and nonconformance reports.

I Depending on the method used to notify the respective plant

\

l management of significant quality-related problems, the distribution of these reports varies. Typically, the manager for the respective plant activity is notified i

i along with his counterpart in the QA organization. The manager's supervisor is also frequently notified. In order to formally resolve an identified nonconforming condition, it is necessary for appropriate corrective action to be identified, l - 111 -

l

implemented, verified and documented. Depending on the nonconformance, the time to implement the appropriate corrective action can vary from immediate on-the-spot correction to several months if a new programmatic system or series of l

procedures need to be generated.

CP&L maintains a permanent record of nonconformance reports, their resolution, and monthly trending reports at the respective Plants, which respective records will be available for Joint Intervenors' inspection at CP&L's Brunswick Plant and at the Robinson Plant upon request.

, ANSWER I-90:

Maintenance and modification work stoppage at both Brunswick and Robinson Plants have been imposed and r olved through the issuance of nonconformance reports without issuance of a formal stop work order. Any nonconformance report written for unacceptable work or work practices has the potential to stop progress on a job.

' CP&L maintains a permanent record of nonconformance reports, their l resolution, and documentation in connection therewith at the respective Plants, i

which respective reports are available for Joint Intervenors' inspection at CP&L's J

J Brunswick Plant and at the Robinson Plant upon request.

I i ANSWER l-91:

! The resolution of any nonconformance report becomes a part of the i

report which CP&L maintains as a permanent record. See the response to interrogatory No.1-90 for availability of records for inspection upon request.

ANSWER I-92:

Mechanism exists within CP&L's Corporate Quality Assurance Department and at the Brunswick and Rcbinson Plants to escalate to appropriate t

i levels of management any condition which cannot be resolved at a lower level.

l - 112 -

Any notifications to CP&L's Senior Management, the dates and individuals involved are contained in CP&L's permanent rt *ord of nonconformance reports filed at the respective Plants. See the response to Interrogatory No. I-90 for availability of records for inspection upon request.

ANSWER I-93:

i The Manager - QA/QC Harris Plant and staff have not had to impose

! their authority to stop work via the stop work authorization referred to on page 2.-

! 26 of said Report. The QA/QC Harris Plant section has resolved all identified conditions adverse to quality by utilizing less significant measures. Such measures i

include simply not signing the inspection document until conditions are in conformance with requirements, application of hold tags, or initiation of a i

nonconformance report. The Harris nonconformance control procedure provides I'

acceptable methods for identifying and controlling nonconforming conditions. The l

i procedure assures that all identified nonconformances are properly resolved and that any subsequent work will not prohibit any required inspections.

i ANSWER I-94:

i i Not applicable. See response to Interrogatory No.1-93.

i ANSWER I-95:

Not applicable. See response to Interrogatory No.1-93.

ANSWER I-96:

The referenced passage on page 3-7 of the Management Capability i I

Report allows members of the Corporate Nuclear Safety Section to. bypass l 1

department management and take concerns directly to senior management if they I

! believe that timely resolution is not being obtained within their own management j i i

! chain. This provision has never been exercised within the Company.

i i .

4 i - 113 -

i ,

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,m . - , . _ - *~ . , . - , , . . - - . - - . . _ . .

4

ANSWER I-97

A log of QA audits sent to a CP&L Executive Vice President is maintained by CP&L's Corporate Quality Assurance Department and will be made-available for Joint Intervenors' inspection at CP&L's General Office upon request.

ANSWER I-98:

" Concerns" and " findings" are terms used in quality assurance audit reports furnished CP&L's Senior Management. The " concerns" and " findings" are i set forth in said reports and represent nonconformances which require documented

{

corrective action for resolution. These reports will be made available for Joint i

Intervenors' inspection at CP&L's General Office upon request.

ANSWER I-99:

Monthly reports containing the status of quality assurance audits will .

be made available for Joint Intervenors' inspection at CP&L's General Office upon j request.

j ANSWER I-100:

(a) In order to achieve sound internal control, authorizing expenditures and making disbursements are separate functions performed . by different i

departments in the corporate structure. The disbursement responsibility is further segregated between a pre-audit and processing function in the Accounting l Department and a post-audit and disbursing function in Treasury. Basically, all departments have the responsibility for authorizing their respective expenditures;

! however, corporate procedures restrict the departments to pre-established approval limits for designated departmental personnel. The separation of duties

, and structured approval guidelines promote the integrity of t'he system and the proper utilization of funds.

' - 114 -

f

i The approval guidelines are broken into these broad expenditure 1

categories: those expenditures related to purchase order items that require specific supporting documentation and authorization to release payment; expenditures not related to purchase orders that have designated procedures for certain situations; and expenditures related to contractor's invoices. Both expenditures related to purchase orders, including capital items and those

resulting from contractual arrangements, are the culmination of elaborate authorization and approval procedures at the pre-obligation stage as well as specific approvals at the payment stage.

! (b) The Accounting Department prepares numerous expenditure reports for the other departments in the Company. These reports fall generally

! into three broad categories: generalized reporting, including operating information, capital reporting, including construction information, and specialized i reporting. These categories represent standard reporting resulting from cyclical processing as well as special ad hoc reporting.

Those reports in the general category are sent to all departments and cover such information as operating statements, cost control data, budget versus actual comparisons and detailed transaction reports by responsible unit. For those i

areas where it is important to operations, such additional information as project reports or vehicle usage and maintenance reports are also provided.

Those reports in the capital category are sent to all departments having activity involving capital items. This category covers such reports as l

necessary to provide 1) . compliance with regulations in identifying construction costs by units of property, and 2) sufficient data on current cost of construction projects in progress for internal management. These reports -include such l

information as summary reports by construction point and major project reflecting 9

- 115 -

budget versus actual comparisons, administrative and general expense allocation per project, furniture and fixture reports as well as detailed audit trial reports.

Those reports in the specialized reporting category are sent only to those respective departments that need the information. These repo'rts reflect

)

detailed listings or summarizations of specific expenditures or transactions which are relevant to the departments' specific needs. This category would include regularly produced reports such as invoices processed relative to a specific location as well as any ad hoc reporting. The Accounting department provides required financial data to all departments as needed.

(c) The corporate procedures for expenditures are set up such that the justification process for said expenditures are internal to the respective department and group. Each group executive sets the justification criteria for the departments within his group. This justification process occurs prior to the Company's incurring the obligation, b before the purchase order is issued, the item is purchased, the contract is signed or the individual is hired. Final departmental approval for the expenditure occurs only after the proper justifications have been made.

This the day of May,1984.

u/ <, M c E. m Samantha Francis Flynn jf Associate General Counsel Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 l

l

- 116 -

i 1

)

3 Attorneys for Applicants: 1 Thomas A. Baxter John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbtidge 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Dale E. Hollar H. Hill Carrow Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 t

- 117 -

- - ~ _ - ~ - . - . .. . . _ _ . . _ - _

((

l 1 Attachment 1-16 Commercial operating dates:

Robinson 2 - March 7,1971

! Brunswick 1 - March 18,1977 Brunswick 2 - November 3,1975 Following is a list of off-line outages at each of the Brunswick and Robinson l nuclear units for the years 1978 through 1983. Included on this list is a designation of the l outage type. The key to this list is as follows:

~

F = Forced S = Scheduled / Maintenance j SP = Scheduled / Planned

! A Forced Outage is defined as the occurrence of a component failure, or other

,I condition, which requires that the unit be removed from service immediately or up to and l

j including the very next weekend. A Maintenance Outage is the removal of a unit from

} service to perform work on specific components which could have been postponed past f the very next weekend. This is work done to prevent a potential forced outage and which i

could not be postponed from season to season. The Planned Outage is the removal of a 4

unit from service for inspection and/or general overhaul of one or more major equipment l

groups. This is work which is usually scheduled wellin advance.

1 l

1 d

?

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1 I .

i BRUNSWICK UNIT 1

(

i OFF-LINE OUTAGES

! 1977*

1 l Date/ Time Date/ Time Mrs./ Min.

Off On m T Duration _ Reason I 1. 03/18:1045' 03/19:0643 F 19:58 Rx scram - during a pres-i sure regulator failure j test at 95% Rx power on i APRM !!i flux level.

1 2. 04/01:2203 04/05:1521 M 89:18 Rx scram - the Rx scrammed i during startup test #27/8.2-4 load reject test at full

power.

3. 04/06

1457 04/08:0622 F 39:25 Rx scram - control operator j reset recirc pump run back i too quickly causing the Rx

to scram on Rx Hi flux level.

1 i

4. 04/27:1141 07/07:0541 F 2,242:00 Rx scram - generator ground caused turbine trip and Rx scram.

5.'07/07:0644 07/07:0707 F :23 Relay maintenance personnel l tripped generator pri. ,

i lockout relay which j removed generator from the grid.

! 6. 07/08:0005 07/08:0022 M :17 Generator was removed from grid to perform l

' overspeed trip test on turbine.

l 7. 07/08:0045 07/08:2237 F 21:52 Generator was removed from grid in order to degas and

. rebalance the rotor.

8. 07/17:1059 07/18:1627 F 29:28 Generator was removed from '

the grid due to high drywell Icakage through the floor '

drain, i l

9. 07/22

2045 07/25:0402 F 55:17 Hanual Rx shutdown - unit was  !

j manually scrammed to investi-gate drywell floor drain leak-age.

( (Commercial Operation - March 18.

SYSTH7-Q-1 ,

t .

I l

BRUNSWICK UNIT 1 l

( OFF-LINE OUTA0ES 1977*

l ,

Date/ Time Date/ Time Mrs./ Min.

Off On h Duration Reason

10. 07/28:1112 08/10:1140 F 312:28 Scram - operator error while t performing PT 2.1.22 (pri. ,.

containment isolation system steam line).

11. 08/12:2242 08/13:1715 F 18:33 Main turbine trip and generator was separated from grid to clean a ground on #6 lift pump piping.

12. 08/14:1520 08/15:0243 F 11:23 Reduced power in order to clear a ground on #6 lift pump piping.  ;

13. 08/28:2125 08/29:1128 F 14:03 Power was reduced due to a [

steam leak in turbine building.  !

14. 09/16:0953 09/17:0419 F 18:26 Rx scram - operator error l

( '

caused condensate booster pump low suction and Rx scrammed low water level.

15. 09/30:2229 10/06:0650 M 128:31 Rx scram - startup test #25 MSIV full closuee at full l power.  ;

16. 10/08:0631 10/08:2049 F 14:18 Generat ,r was removed from

! grid to clean A-S & A-N r l waterbnxes.

l

17. 10/14:1736 10/16:2238 F 53:02 Shut Jown due to high drywell lea'4 age through floor drains.

18. 10/29:0109 10/30:1319 M 37:10 Rc shutdown to repair steam lei.5 on v51ve and repair main generator .suto, voltage regu-lator.

19. 11/13:0037 11/26:2141 F 333:04 Rx scram while performing PT 1.3.2 recirc pump seals failed, replaced both rectre pumps.

! 12/02:2341 12/04:2045 F 45:04 Unit shutdown to repair l ( 20.

• reactor feedw. ster pump IA.

SYSTM7-Q 2 i

l c

I l

l I

i BRUNSWICK UNIT 1 1 0FF-LINE OUTAGES 1977*

Date/ Time Date/ Time Mrs./ Min.

Off On Tyge Duration Reason

]

j 21. 12/16:0645 12/17:1129 F 28:44 Rx scram during ECCS test, '

i power lost to Unit #1 EMC

system, loss of E2 bus; blown j fuse.

i j 22. 12/21:1102 12/23:0723 F 44:21 Rx scram - cperator was reducing

power with recirculation pumps

! low water level caused scram, t

j 23, 12/31:2316 12/31:2400 M 144 The drywell was de-inerted to

! make an entry to add oil to l 1A recirc pump.

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• 1 i

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! t i

a i

)

i J

i l,

I i

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l hYSTM7-Q.3 t t

BRUNSWICK UNIT 2

{ OFF-LINE OUTAGES 1977 Date/ Time Date/ Time Hrs./ Min Off On Type Duration Reason

1. 01/02:0500 01/02:1934 F 18:44 Rx Scram while performing PT 40.25 (Turbine control valve test).

2. 01/07:1255 01/08:1148 F 22:53 Rx Scram - Technician error while performing PT 1.1.4 caused a Group I isolation and scram.

3. 02/02:2354 02/06:0132 F 73:38 Manual shutdown to repair a burned drywell drain pump motar.

4. 02/14:0825 02/17:1858 F 82:31 Rx Scram - off line at 544 MWe when high exhaust hood temp.

was received.

5. 02/23:1448 02/24:0807 F 17:19 Rx Scram - B Feedwater pump

( tripped - A F.W. pump was operating at minimum. speed.

6. 04/05:2259 04/07:0138. F 26:39 Rx Scram - Loss of instrument air caused loss of condensate booster pump supply pressure.

7. 04/15:2150 05/06:2210 M 503:20 Rx Scram - Shutdown for

-routine maintenance'and modi-fication of 2A recire. pump.

8. 05/07:1132 05/08:1349 F 26:17 Rx Scram - FW pump and booster pump trip, causing low water level and Rx Scram.

9. 05/21:2209 05/22:1653 F- 18:44 Rx Scram - Operator error while performing P.T. 40.2.5 control valve test. .I

10. 05/31:0936 06/02:0304 F 41:28 Rx Scram - Mechanic error while cleaning EHC duplex oil filters.

11. 06/02:2127 06/03:0547 F 8:20 Rx Scram ; Spurious upscale on 2C Radiation monitor caused by man climbing on cable tray.

(~ 9 SYSTM7-Q-4 g e

BRUNSWICK UNIT 2 OFF-LINE OUTAGES l 1977 j Date/ Time Date/ Time Mrs./ Min Off On Tyge Duration Reason

12. 06/14:2324 06/15:2328 F 24:04 Rx Scram caused by heater drain deaerator level oscillation.

13. 07/11:0202 07/12:0330 F 25:28 Scram - Loss of lube water to CW pumps due to shells in lube water lines.

14. 07/15:1038 07/18:1455 F 76:17 Rx Scram - A spurious signal (Hi turbine exhaust temp.) caused a turbine trip.

15. 07/19:2047 07/20:0605 M 9:18 Generator was removed to investigate reason for trip on 7/15.

16. 07/31:1347 08/01:1026 F 19:14 Scram - Technician error while performing P.T. 2.1.26

( (Main steam line low pressure).

17. 08/15:1114 08/17:0235 F 39:21 Rx Scram - I&C error while performing P.T. 3.1.5.

18. 08/17:0435 08/21:1525 F 106:50 Generator was removed due to.

High Chlorides in the main condenser.

19. 09/04:0610 09/05:0720 F 25:10 Rx Scram - The generator auto, voltage regulator out of service due to loss of turbine-building cooling.

20. 09/08:2047 09/09:1018 F 13:31 Rx Scram - Rx Feedwater pump control oscillation caused Rx to Scram.

21. 09/10:0105 12/26:1717 P 2585:12 Manual Scram - shutdown for a 54-day refueling and maintenance outage.

22. 12/26:2359 12/31:2400 F 120:01 To correct steam leak on the MS Bypas valves and problems with IIPCI system speed control.

l .

SYSTM7-Q-5

ROBINSON UNIT 2 0FF-LINE OUTAGES ,

1977 Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

1. 01/11:1701 01/11:2015 F 3:14 Manual reactor trip following loss of MCC-6.

2. 01/24:1826 01/24:2220 F 3:54 Reactor trip due to Hi pres-

surizer press.

3. 01/25:1148 01/25:1508 F 3:20 Turbine trip caused by loss of "B" inverter.

4. 02/05 02/17 F 278:62 "C" RCP high leakage.

5. 02/18:1814 02/20:0352 F 33:38 I'nspect #2 turbine generator for insulation failure.

6. 03/23:1333 03/24:1930 F 29:57 E.H. Governor valve failed -

shut causing Rx trip.

7. 03/25:2310 03/27:0113 M 26:03 Repair turbine trip block.

8. 04/24:1924 04/30:2342 F 148:18 Loss #1 seal leakoff indica-tion on "C" RCP.

9. 06/17:2222 06/18:1938 M 21:16 NRC startups.

10. 08/17:0904 08/17:2020 F 11:16 #3 steam generator high steam line AP safeguard trip, while testing aux feedwater pump valve V214C.

11. 08/23:2339 08/24:0702 F 7:23 4B F.W. heater - repair tube leaks.

12. 09/29:2300 09/30:0854 M 9:54 To repair tube leaks in 4B heater.

13. 10/05:1621 10/05:1855 F 2:34 Turbine trip - High level "B"

' steam generator, loss of instrument Buss 2.

14. 10/26:0643 11/24:2140 F 710:57 '

Failed packing in valve RHR-750 and failure in. Bit.

15. 12/19:1028 12/19:1247 F 2:19 Overtemp. Delta temp.~ trip while performing periodic ..

k. test. ..

SYSTM7-Q-6

ROBINSON UNIT 2 OFF-LINE OUTAGES ,

1977 Date/ Time Date/ Time Hrs./ Min.

. Off On Type Duration ' Reason

16. 12/19:1251 12/19:1305 F :14 Trip - due to #3 steam generator Hi level while recovering from a previous trip.

(

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f l- SYSTM7-Q-7 l

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- ~

BRUNSWICK UNIT 1 0FF-LINE OUTAGES January throuch December 1978 Date/ Time Date/ Time Hrs / Min Off On Type Duration Reason

1. 01/01:0000 01/01:0428 S 4:28 High oxygen level in drywell.

2. 01/13:1111 01/15:1948 F 56:37 condenser hotwell drain line leak <

3. 01/19:2246 01/22:1530 S 64:44 Steam leaks on several valves.

4 02/04:0102 02/05:0610 S 29:08 Clean condenser.

5. 02/13:0042 02/27:0004 F 335:22 Severalswitchyardbreakerstrippq causing generator trip and reactes scram.

6. 02/27:1635 02/28:2045 S 28:10 Safety relief valve repair.

7. 03/13:1644 03/15:0735 F 38:51 Spurious signals in main steamling leak detectors caused reactor scr6

8. 04/,04:0849 04/06:1315 F 52:26 Reactor scram caused by reactor pressure spike.

9. 04/07:2237 04/08:0557 S 7:20 Clean strainer and replace stator cooling filters.

10. 04/08:1301 04/09:0017 F 11:16 Loose fuse caused main steam line isolation valves to close, and a reactor scram.

11. 04/30:1527 05/01:0655 F 15:28 Reactor scrammed due to reactor feed pump trip.

12. 05/01:1502 05/03:0023 F 33:21 Safety relief valve. repair.

13. 05/03:0618- 05/03:0644 S :26 Turbine overspeed trip test.

14. 05/19:2153 05/24:0640 F 104:47 Reactor recirculation pump seals replacement.

15. 05/27:2255 05/28:0630 S 7:35 ' Excessive leaks in drywell equip-ment drain cank.

16. 06/27:0221 06/28:1235 F 34: 14 Master turbine trip caused by higi vibration signal.

17. 06/29:0908 06/29:1935 F 10:27 Reactor scram caused by turbinec

, step valve elesure.

1 1

(cont.)

BRUNSUICK UNIT 1 0FF-LINE OUTAGES-Januarv throuch December 1978 Date/ Time Date/ Time Off Hrs / Min On Tjjr ge Duration Reascn

18. 07/26:1052 07/27:1406 F 27:14 Reactor scram initiated by low water level scram inscruments.

19. 07/23:0316 07/28:1509 F 11:53 Reactor scram due to -low water level.

20. 08/08:2022 08/09:0917 F 12:55 ProblemswithMasterTripSolenoj Test resulted in turbine trip ane reactor scram.

21. 09/24:2346 10/01:0236 S- 146:30 Drywell snubber inspection.

22, 11/02:1321 11/03:0727 F 18:06 Loss of condenser vacuum.

23. 11/11:1110 11/12:1547 F 28:17 High reactor vessel cenductivity.

exceeded Technical Specification

-limit for operation.

24, 11/17:2058 11/20:0128 S ~52:30 Inspection of the reactor recirculation system inlet nozzle safe-ends to the reactor vessel.

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a l

, BRUNSWICK UNIT 2 OFF-LINE OUTAGES January throuch December 1978 Date/ Time Date/ Time Hrs / Min Off On Type Duration Reason

1. 01/01:0000 01/01:2025 F 20:25 Steam leaks on MS bypass valves.

2. 01/02:1019 01/03:0822 F 22:03 Low reactor water level.

3. 01/06:0941 01/09:1900 F 81:19 Reactor scram due to false low reactor water indication.

4. 01/17:1316 01/18:0559 F 16:43 Turbine and generator t-ip due to control circuit ground.

5. 01/31:1145 02/01:1348 F 26:03 EHC pressure spike causing reac:o Scram.

6. 03/05:0821 03/06:0900 F 24:39 False low reactor water indicatio

7. 03/13:1251 03/14:1411 F 25:20 Main turbine and feed pump turbin trip.

8. 03/23:1137 03/24:0924 F 21:47 Reactor feed pump controller fail ure.

9.

. *f 03/24:1739 03/25:0035 F 6:56

\

Main turbine trip due to generato ground signal.

10. 03/26:1710 03/26:2150 F 4:40 Main turbine trip due to generatot ground signal.

11. 03/23:1219 03/28:1822 F 6:03 Main turbine trip due to generatot ground signal.

12. 03/29:1410 04/04:1412 F 144:02 Mainturbinetripduetogeneratog ground signal. l

13. 04/09:0807 04/09:2237 F 14:30 -

230 KV bus lock out causing turbig trip.  ;

t

14. 05/17:2027 05/18:1903 F 22:36 230 KV bus lock out causing turbid trip.

15. 05/23:0853 05/23:2157 F 13:04 Pressure transient en reactor vess level instrunents.

( 16. 06/02:2356 06/11:2232 S 214: 36 j Investigate and repair generator hydrogen Icak.

~

l (cont.) BRUNSWICK UNIT 2 0FF-LINE OUTAGES Januarv throuch December 1978 Date/ Time Date/ Time Hrs / Min Off On Type Dur,1 tion Reason

17. 06/11:2232 06/22:0537 F 247:05 Excessive coolant temperatures in the pump seal ecoling syste=.

18. 07/03:0052- 07/06:1353 F 85:01 Reactor scram due to hi;h flux level spike.

! 19. 07/18:1240 07/19:1250 F 24: 10 Reactor scram due to AP.~C! upscale trip.

20. 08/18:2034 08/22:0623 S 81:49 High dryvell floor drain leakage.

21. 09/06:2034 09/24: 1134 S 423:00 High condensate conductivity.

i

22. 11/06:1337 11/14:1438 F 193:01 Generator lockout due to loss of excitation.

23. 11/30:1129 12/01:0701 F 19:32 Reactor trip due to low reactor-vessel water level.

4 4

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I ROBINSON IINIT 2 OFF-LINE OUTAGES January throuch December 1978 Date/ Time Date/ Time Hrs / Min Off On Type Duration Reason

1. 01/13:1912 01/15:1052 F 39:40 Main steam isolation valve (MSIV) failed closed.

2. 01/27:2210 02/01:2210 F 120:00 High vibrations on reactor coolan:

pump.

3. 02/01:2210 04/23:1934 SP 1941:24 Planned refueling and maintenance.

4 04/24: 1146 04/24:1701 F 5:15 High turbine vibrations.

5. 04/25:1509 04/25:1813 F 3:04 MSIV solenoid coil failure.

6. 07/10:0621 07/15:0045 F 114:24 High pressurizer pressure.

7. 07/16:0605 07/17:0620 F 24:15 Failure of "A" station batterJ.

8. 07/31:1022 07/31:1551 F 5:29 Reactor coolant pump trip.

9. 08/01:1505 08/01:1947 F. 4:42 Steam generator high level alarm.

10. 09/21:2009 09/29:1918 F 191:09 Steam generator tube leak.

11. 10/16:0746 10/16:1044 F- 2:58 Steam'line pressure transmitter

~

~ failure.

1 4

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BRUNSWICK UNIT 1 0FF-LINE OUTAGES 1979 Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

1. 01/12:2322 4/16:2317 SP 2255:55 Scheduled maintenance and refueling outage.

2. 4/17:1049 4/17:1256 S 02:07 The unit was removed from service-to perform a planned test on the turbine overspeed devices.

3. 4/17:1458 4/19:1S39 F 51:41 Reactor high pressure trip due to the turbine runback.

4. 4/19:2300 4/19:2315 S 00:15 The unit was removed from service to repeat the electrical backup overspeed portion of the turbine overspeed trip test.

5. 4/20:0112 4/20:0205 S 00:53 The unit was retired to repeat the electrical turbine overspeed test.

6. 4/20:1148 4/20:1232 S 00:44 The unit was retired to repeat the turbine electrical backup overspeed test.

7. 5/01:0658 5/04:0220 F 67:22 Reactor trip due to indicated APRM upscale thermal trip signal.

8. 5/26:0247 6/10:1508 SP 372:21 Inspection and modification of pipe supports.

9. 7/18:2330 7/19:1709 -F 17:39 Average Power Range Monitor flow was biased upscale, which caused a reactor trip.

10. 7/28:1433 7/29:0358 F 13:25 Reactor tripped on a false low reactor water level signal. '

11, 8/04:1558 8/05:0715 F 15:17 Reactor trip on high neutron flux indication.

12. 8/09:0719 8/09:2310 F 15:51 Reactor-trip on high neutron flux' indication.

13. 8/19:1425 8/20:0224- F 11:59 Reactor transient .in level instruments caused a reactor trip. *

.~

BRUNSWICK UNIT I (Continued)

('

0FF-LINE OUTAGES 1979 Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

14. 9/08:0750 9/17:0642 S 214:52 Hydraulic snubber (shock absorber) inspection required by NRC Technical Specifications.

15. 10/08:0913 10/09:0326 F 18:13 Reactor trip on low water level indication.

16. 10/19:0051 10/24:2124 F 140:33 The reactor tripped on a main steam line high radiation signal.

17. 11/05:0733 11/16:0621 F 262:48 Reactor trip due to reactor water low level.

18. 11/20:1330 11/29:1628 F 218:58 Reactor trip due to temporary loss of power to the emergency busses.

19. 12/01:2158 12/05:0504 F 79:06 To repair recirculation pump valve e

leaks.

20. 12/12:0057 12/20:2356 S 214:59 Hydraulic snubber inspections, modifications required by NRC in response to the TMI incident, and recirculation pump seal work.

21. 12/21:0548 12/21:0755 F 02:07 To test and repair safety relief valve modifications made during the previous (December 12-20) outage.

I

BRUNSWICK UNIT 2 0FF-LINE OUTAGES 1979 Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

1. 01/29:1135 01/30:0118 F 13:43 High steam line pressure spike.

2. 02/04:2052 02/05:0357 F 07:05 Recire pump runback and reactor high pressure spike.

3. 03/02:2322 05/19:0715 SP 1854:53 Scheduled maintenance and refueling outage.

4. 05/19:1447 05/19:1557 S 01:10 The unit was removed from service to perform a planned test on the l

turbine overspeed trip device.

5. 05/21:1130 05/22:1912 F 31:42 Reactor trip.

6. 05/23:0717 05/23:2108 F 13:51 Reactor trip on low water level indication.

( 7. 05/25:1909 06/12:0612 SP 419:03 Inspection and modification of pipe supports.

8. 06/12:1309 06/13:0622 F 17:13 Reactor trip due to main steam isolation valve closure indication.

9. 06/29:2249 07/05:0442 S 125:53 Hydraulic snubber inspection required by Technical Specifications.

10. 07/19:1316 07/21:0649 F 41:33 Replacement of main steam safety relief valve.

11. 07/31:0423 08/03:0732 F 75:09 Turbine and reactor trip on loss of .

condenser vacuum.

12. 08/31:2347 09/06:2149 S 142:02 Hydraulic snubber.(shock absorber) inspection required by Technical.

Specifications. l

13. 09/07:0449 09/08:0220 F 21:31 Steam leak in main steam line' drain valve.

14. 09/12:1415 09/13:1512 F 24:57 Nuclear service water leak.

15. 09/14:0743 09/15:0050 F 17:07 ' Reactor trip due to load reject indication.

BRUNSWICK UNIT 2 (Continued) 0FF-LINE OUTAGES 1979 Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration , Reason

16. 09/22:0311 09/22:1533 S 12:22 Scheduled maintenance on reactor core instrumentation.

17. 11/19:0852 11/21:1226 F 51:34 Reactor trip due to nuclear system false high pressure signal.

18. 12/25:2345 Through the S 144:15 Hydraulic snubber inspections and end of the modifications required by the NRC year. in response to the TMI incident.

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ROBINSON UNIT 2 0FF-LINE OUTAGES 1979 Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason .

1. 01/06:0924 01/07:2317 F 37:53 Feedwater control malfunction.

2. 01/07:2320 01/08:0438 F 05:18 Feedwater control malfunction.

3. 02/06:1328 02/07:0032 F 11:04 A containment high pressure signal resulting in a turbine trip.

4. 02/21:1029 02/21:1323 F 02:54 "B" steam generator high level trip.

5. 04/11:2042 04/17:2400 F 147:18 "B" steam generator leakage exceeded Technical Specifications.

6. 04/18:0000 07/21:2221 SP 2277:21 Scheduled maintenance and refueling outage.

7. 07/22:1151 07/22:1922 F 07:31 To balance the turbine and to perform turbine overspeed

, trip test.

8. 07/23:1103 07/23:1825 F 07:22 Oil leaks in the turbine Electrohydraulic Control System (EHC).

9. 08/16:1121 08/16:1935 F 08:14 False high pressure signal j

1 which resulted in a reactor trip.

10. 08/16:2332 08/17:1020 F 10:48 Nuclear Instrumentation System (NIS) Overpower reactor trip.

11. 09/04:2255 09/05:2207 S 23:48 Threat of Hurricane David

12. 09/23:0318 09/23:1247 F 09:29 Reactor trip on a "High Pressurizer Pressure"' indication.

13. 09/30:0845 10/01:0205 F 17:20 Cleanup and evaluation of an oil fire in "C" reactor coolant pump bay.

14. 11/02:2055 11/03:0842 S 11:47 Unit shutdown to balance titrbine.

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ROBINSON UNIT 2-(Continued) 0FF-LINE OUTAGES 1979

15. 12/13:1555 12/13:1907 F' 03: 12 Turbine trip and reactor trip due to high water level in'"A".

steam generator.

16. 12/22:0324 12/22:0906 F 05:42 Turbine and reactor trip during periodic test.

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l BRUNSWICK UNIT I -

0FF-LINE OUTAGES 1980 Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

1. 03/23:0043 03/24:2018 F 43:35 Reactor trip due to high reactor water level.

2. 03/26:1545 03/28:0723 F 39:47 Drywell leakage.

3. 03/31:1310 04/03:0250 F 61:40 Reactor trip due to low reactor water level.

4. 04/05:0108 04/06:0721 F 30:13 Turbine trip.

5. 04/08:0450 C4/13:0927 F 124:37 Turbine trip.

6. 04/15:1231 04/17:1500 F 50:29 Turbine trip. -

7. 04/26:2325 04/27:2009 F 19:44 Drywell leakage.

( 8. 05/26:1518 08/22:1400 SP 2110:42 Refueling scheduled maintenance and unscheduled regulatory tests,.

l inspections, and analyses.

9. 08/25:1721 08/28:0433 F 59:12 Reactor coolant conductivity.

10. 09/12:1538 09/15:1430 S 70:52 Inspect a generator bearing.

11. 10/14:0111 10/15:2015 F 43:04 The reactor scrammed when steam flow in main steam lines exceeded preset flow limits.

12. 12/28:1453 Through the S 81:07  : Snubber inspections and feedwater end of Decem- heater maintenance, ber 1980

(- - -.

l BRUNSWICK UNIT 2 0FF-LINE OUTAGES 1980 Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

1. 12/25:2345 01/05:1021 S 250:36 Hydraulic snubber inspections 106:21-Jan. and modifications required by 144:15-Dec. NRC in response to TMI incident.

2. 01/07:2300 01/10:0254 F 51:54 Indication of safety relief valve leakage.

3. 02/13:0951 02/15:1820 F 56:29 Reactor trip during periodic test.

4. 03/01:0244 09/17:1205 SP 4808:21 Refueling required modifications, scheduled maintenance, and unsche-duled regulatory tests, inspections and analyses.

5. 09/17:1513 09/17:1524 S 00:11 To perform a turbine overspeed trip test.

6. 09/19:1030 09/22:0704 F 68:34 Reactor scram for which no cause could be determined.

7. 09/23:1438 09/26:1935 F 76:57 Drywell floor drain leakage in excess of Technical Specifications limits.

8. 10/11:1014 10/13:1625 F 54:11 Reactor scrammed when high neutron flux in the reactor exceeded Average Power Range Monitor (APRM) setpoint.

9. 10/28:0749 10/29:0636 F 22:47 High reactor water level caused a trip of the main turbine resulting in a reactor scram.

10. 11/13:0056 11/14:1143 F 34:47 Loss of the Reactor Protection System power supply.

11. 11/15:1750 11/16:0603 F 12:13 The unit was taken out of service to repair a leak in the recirculatio1 system for the heater drain pumps.

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i BRUNSWICK UNIT 2 (Continued) 0FF-LINE OUTAGES 1980 1

Date/ Time Date/ Time Mrs./ Min.

Off On Type Duration Reason

, 12. 11/18:0724 11/19:2051 F 37:27 The reactor scrammed due to a turbim trip.

13. 12/05:2258 12/13:1857 S 187:59 The unit was taken out of service to repair tube leaks in a feed-water heater.

14. 12/16

0956 12/19:0651 F 68:55 Reactor scram due to low condenser

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vacuum.

j 15. 12/26:1026 12/30:2140 F 107:14 Reactor tripped on low water level.

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t ROBINSON UNIT 2 0FF-LINE OUTAGES 1980 4

Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

1. 03/14:2357 03/28:0929 S 321:32 Steam generator tube leaks.

2. 04/13:2246 05/02:1551 F 448:05 Reactor coolant pump seal failures.

3. 05/17:1839 05/18:0836 F 13:57 Adjustment of reactor trip setpoints-

4. 05/22:0748 05/22:1030 F 02:42 Reactor trip.

5. 06/10:0007 06/10:0231 F 02:24 Reactor trip.

i

6. 06/10:1715 06/10:2204 F 04:49 Loss of condenser vacuum.

7. 07/07:1147 07/16:2244 F 224:57 Steam generator tube leak.

i

8. 08/08:2207 10/25:0049 SP 1850:42 Refueling and scheduled main-

} tenance.

, 9. 10/25:0932 10/25:1151 S . 02:19 To perform a turbine overspeed trip test.

i

10. 10/25:1459 10/25:1828 F 03:29 ' Disconnected grounding strap

' on the generator grounding trans former.

11. 10/25:1839 10/26:0151 F 07:12 The reactor tripped due to low water level in "B" steam generator coincident with steam flow-feedwater flow mismatch.

12. 10/26:0155 10/26:0421 F 03:26 High/High level in "B" steam generator.

13. 11/02:1538 11/02:2337 F 07:59 Reactor trip caused by low water level in "A" steam generator coincident with steam flow-i feedwdter flow mismatch.

14. 11/07:1005 11/07:1649 F 06:44 Loss of condensate and feedwater pumps.

l 9 -

I ROBINSON UNIT 2 (Continued) 0FF-LINE OUTAGES -

1980 Date/ Time Date/ Time Hrs./ Min.

t Off On Type Duration Reason

15. 11/15:2251 11/16:1724 S 18:33 High turbine vibration. - i

16. 11/27:1421 12/12:1153 F 357:32 Valve packing leak.

17. 12/12:2002 12/14:1240 F 40:38 Valve p'acking. leak.  !

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BRUNSWICK UNIT 1

• OFF-LINE OUTAGES 1981 Date/ Time Date/ Time Hrs./ Min.

Off On Tm Duration Reason

1. 12/28:1453 1/6:2347 S 143:47(Jan.) Snubber inspections and feedwater Dec. incl. 224:54 heater maintenance.

2. 1/20:1143 1/22:0424 F 40:41 Indication of low water level in the vessel tripped the reactor.

3. 1/30:0347 1/31:1726 F 37:39 Reactor scram due to loss of reactor feed pump "A."

4. 2/12:0915 2/13:0858 F 23:43 Reactor scram due to loss of condenser vacuum.

5. 2/24:1349 2/25:0305 F 13:16 High oxygen concentration in the drywell.

6. 3/29:2153 4/9:0913 F 251:20 High pressure trip signal.

7. 4/17:2312 9/23:1939 SP 3811:27 Scheduled annual outage.

8. 9/24:0255 9/25:0659 F 28:04 Turbine trip.

9. 10/1:1522 10/3:0621 F 38:59 Turbine trip.

10. 10/29:1634 10/31:2137 F 53:03. Reactor tripped on low water level.'

11, 11/14:0218 11/14:0630 S .4:12 ~ Unit was removed from service to investigate abnormal resistance readings on the: generator. hydrogen seals.

12. 11/15:0041 11/19:0204 F 97:23 ' Failure of turbine stop valve switch

13. 12/2:0724 12/4:1750 F 58:26 Valve packing ~1eak.

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i BRUNSWICK UNIT 2 0FF-LINE OUTAGES 1981 Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

1. 01/07:0737 01/11:0921 F 97:44 Reactor scrammed on low water level in the vessel.

2. 02/14:0843 02/22:0629 S 189:46 Main steam isolation valve repair.

3. 02/24:1811 02/26:0150 F 31:39 High oxygen concentration in the drywell.

4. 02/26:0830 02/27:0638 F 22:08 Reactor scram due to large power spikes.

5. 02/28:1633 02/28:1846 F 2:13 To test main generator instrumenta-tion and control.

6. 03/05:0552 04/10:1521 F 873:29 The unit was shut down when periodic testing of accessible

() hydraulic snubbers indicated a high failure rate.

7. 04/11:0322 04/11:1322 F 10:00 The unit was manually shut down to comply with Technical Specifica-tions concerning operability of safety systems.

8. 04/12:1301 04/17:1819 S 125:18 The unit was manually shut down when levels of conductivity and chlorides exceeded limits prescribed by Technical Specifications.

9. 04/17:2126 04/18:0506 F 7:40 The unit was manually shut down when.

levels of conductvity exceeded limits prescribed by Technical Specifications.

10. 05/03:0525 05/04:0227 F 21:02 Valve packing leak.

11. 05/06:0541 06/08:0704 F 793:23 Restricted water flow through residual heat removal heat exchangers.

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BRUNSWICK UNIT 2 (Continued) 1 Date/ Time Date/ Time Hrs./ Min.

Off On Type Dura tion Reason

12. 06/10:1020 06/11:2352 S 37:32 Excessive temperature differential between recirculation loops A and B.

13. 06/22:2151 06/28:0745 F 129:54 Recirculation pump failure.

14. 07/02:0153 07/03:1041 F 32:48 Main steam isolation' valve (MSIV) failure.

15. 07/11:0545 07/12:2158 F 40:13 Reactor scram on turbine trip.

16. 07/18:1143 07/27:2304 F 227:21 Unit removed from service to repair two MSIV's.

17. 08/04:1947 08/07:1527 F 67:40 Reactor scrammed due to low condenser vacuum and turbine trip.

( 18. 10/23:1541 10/30:0446 F 158:05 Scheduled snubber inspection.

19. 11/2:1431 11/3:1601 F 25:30 Reactor tripped on high water-level.

20. 12/18:1704 12/21:0214 F 57:10 Repair valve controls.

21. 12/26:1711 12/26:2351 S 6:40 Unit was removed from service to replace .a gasket on the moisture-separator reheater drain tank.-

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ROBINSON UNIT 2 0FF . TINE CUTAGES 1981 Date/ Time Date/ Time Hrs./ Min.

Off On Type Dura tion Reason

1. 01/24:2345 01/25:1700 F 17:15 Feedwater heater tube leak.

2. 01/29:0641 02/01:1715 F 82:34 Manual shutdown due to loss of oil from the turbine Electro-Hydraulic Control System.

3. 02/01:1906 02/01:2229 F 03:23 Reactor trip due to a steam flow, feed flow mismatch coincidenta:

with low steam generator level.

4. 02/02:1505 02/02:1822 F 03:17 Reactor trip due to a steam flow, feed flow mismatch coincidental with low steam generator level.

5. 02/02:2043 02/04:1430 F 41:47 Reactor trip due to a steam flow, feed flow mismatch coincidental with low steam generator level.

6. 03/22:1345 03/23:0111 F 11:26 Manual shutdown due to incorrect rod position of Rod N-9.

7. 04/21:1515 04/21:2041 F 05:26 Reactor trip due to a steam flow, feed flow mismatch coincidental with low steam generator level.

8. 04/21:2139 04/22:0614 F 08:35 The unit was taken off line to repair heater drain valves.

9. 05/16:0303 06/11:1704 S 641:01 Scheduled steam generator tube inspection.

10: 06/19:1711 06/20:0446 F 11:35 Manual scram when turbine load was shed.

11. 06/20:1049 06/20:1829 F 07:40 Instrument bus electrical spike.

12. 07/10:12:55 07/10:1626 F 03:31 Reactor coolant leak into containment.

13. 07/30: 1502 09/02:0830 F 809:28 Steam generator tube leaks.

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ROBINSON UNIT 2 (Continued)

Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

14. 09/25:1750 09/27:0618 F 36:28 Inoperable control rod bank.

15. 09/28:2122 09/28:2350 S 02:28 Manual shutdown to troubleshoot and repair the manual turbine control circuitry.

16. 10/16:0122 10/16:1034 F 09:12 Generator exciter cooler service water tube leaks.

17. 11/6:2050 11/19:1837 S 309:47 Scheduled maintenance.

18. 11/20:1655 12/3:0615 F 301:20 Steam generator tube leaks.

19. 12/3:0638 12/3:2310 F 16:32 Reactor tripped on high steam generator level.

g ( 20. 12/6:0645 12/6:1746 S 11:01 Unit was retired to inspect feedwater regulator valve.

21. 12/6:1751 12/6:2102 F 3:11 Reactor tripped due to a steam flow, feed flow mismatch coincidenta with low steam generator level signa

22. 12/7:1426 12/7:2141 F 7:15 Reactor tripped on low-level in steat generator.

23. 12/16:2243 12/17:1755 F 19:12 Oil leak in the Electro-Hydraulic Control (EHC) System.

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BRUNSWICK UNIT 1 0FF-LINE OUTAGES 1982 Hrs./ Min.

Date/ Time Off Date/ Time On Type Duration Reason 1982

1. 02/05:2115 02/14:0721 202:06 S Scheduled snubber inspections.

2. 02/18:1154 02/20:2207 58:13 F Stuck control valve.

3. 04/19:1239 04/20:0440 F 16:01 Reactor scrammed due to loss of 125/150 V DC power.

4. 05/05:0728 05/06:0907 F 25:39 Condenser vacuum switch failure.

i75' 06/01:1015 06/05:2000 F 105:45 Turbine tripped on low condenser vacuum indication.

6. 06/07:2127 06/09:1030 F 37:03 Reactor scrammed when all Main Steam Isolation Valves (MSIV) closed.

7. 06/28:0200 06/29:0947 F 31:47 Undervoltage on auxiliary power distribution system.

8. 07/10:1415 07/11:1429 F 24:14 Turbine trip resulting from defective instrument in Electro-Hydraulic Control (EHC) system.

9. 07/16:2224 10/17:2225 2232:01 F Local leak rate testing.

10. 10/21:2238 10/25:2057 F 94:19 Turbine tripped during routine test, causing reactor to scram.

11. 12/11:0134 Remained off SP 502:26 I Refueling and scheduled through the through maintenance.

end of December December

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I BRUNSWICK UNIT 2 0FF-LINE OUTAGES 1982 Hrs./ Min. '

Date/ Time Off Date/ Time On Type Duration Reason 1982

1. 1/13:1236 1/15:0305

) F 38:29 Reactor scram due'to recirculation pump overspeed.

2. 1/16:1638 1/17:1742 F 25:04 Reactor tripped on turbine load rejection.

3. 1/20:0852 1/28:2152 F 205:00 Reactor tripped when level 1 switches were disturbed.

4. 02/03:1516 02/05:0320 F 36:04 Reactor scrammed on main steam line high radiation indication j 5. 03/13:1901 03/14:1837 F 23:36 Reactor scrammed on reactor coolant low-level

_ _ _ imdication signal.

6. 04/24:0048 10/03:1257 3899:0'9 '

SP Refueling and scheduled

. maintenance.

7. 10/03:2012 10/03:2102 00:50 S Turbine overspeed trip test.

8. 10/13:2016 10/18:0356 F 175:40 Leak in heater drain system.

9. 10/24':1339' 10/25:0510 S 15:31

' The unit was removed from service to troubleshoot and repair the -

primary system pressure sensor, .

.which had caused the Reactor

, m Racirculation Pump "A" to trip.

10. 10/28:0538' 12/05:1101 S 918:23 Uott was removed from service to repair Traversing Incore.

., Probe "A."

11. 12/22:1206 12/24:0453 F 40:47 Powe'r/ load imbalance.

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l ROBINSON UNIT 2 0FF-LINE OUTAGES 1982 l

Hrs./ Min.

Date/ Time Off Date/ Time on Type Duration Reason l 1982 1

1. 02/26:2306 08/15:1448 SP 4070:42 Refueling and scheduled naintenance.

2. 08/15:1505 08/21:0240 F 131:35 Low steam generator water level.

l

3. 08/21:0313 08/21:0913 F 06:00 High steam generator water level.

] 4. 08/21:0925 08/21:1726 F 08:01 High steam generator water level.

I

5. 08/22

1707 08/24:0123 S 32:16 Turbine overspeed trip. test.

4

6. 08/25:2228 08/25:2242 00:14 S Turbine overspeed trip test.

7. 09/05:1529 09/06:0104 i

F 09:35 Reactor tripped due to a steam

)

flow, feed flow mismatch coin-cidental with low steam generator j level signal.

8. 09/07:0413 09/07:2256 F 18:43 Unit was removed from service to l isolate a stuck open letdown i

! relief valve in the chemical and volume control system.

9. 09/09:1245 09/13:0925 92:40 F Low steam generator water level.

10. 09/21:1349 09/21:2117 07:28' F Reactor tripped due to a steam flow, feed flow mismatch coinci-( dental with . low steam generator level signal.

11. 10/22:2251 -10/24:0459 S 30:08 1 Scheduled maintenance.

12. 11/29:1512 12/01:1733 F- 50:21 High sodium. levels in the secondary system.

i 13. 12/31:0227 Remained off F 21:33. Low steam generator water '1evel.,

j through the through l

end of December December- '

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1 Brunswick Unit 1 Off-Line Outages January Through December 1983 Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

1. 12/11:0134 08/26:1436 SP -

6204:02 Total Refueling and 5701:36 Jan- scheduled August maintenance 502:26 Dec.

2. 08/27:0155 08/28:1514 S 37:19 Turbine ~overspeed trip test

3. 08/28:1830 08/29:0547 S 11:17 Turbine overspeed trip test

4. 10/18:0126 11/18:0858 SP 752:32 Planned maintenanc:

cutage

5. 11/25:2110 11/28:0539 F 56:29 Unidentified leaks in the drywell

( i. 12/22:0810 12/25:1827 F 82:17 Reactor. scram L

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Brunswick Unit 2 Off-Line Outages January Throuch December 1983 Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

1. 01/03:0233 01/04:0842 F 30:09 Main Steam Isolatig Valve (MSIV) closus signal

2. 02/03:0233 02/15:2310 S 308:37 Scheduled maintenat

3. 04/08:1839 05/09:-1649 SP 741:10 Electrical and mechanical tie-ins to the Augmented Cff-Gas System (AC@

4. 05/16:2108 05/19:0757 F 58:49 Feactor tripped on false signal from Main Steam Line Rad tion Monitor

5. 06/02:1833 06/06:0035 F 54:02 Power / load imbalan@

' 6. 06/20:1316 06/26:0413 F 134:57 High reactor water-level

7. 07/30:1836 08/11:1837 F 288:01 High drywell floor drain leakage

8. 08/31:2226 09/03:0516 F 54:40 High Average Power Range Monitor Signs

9. 09/03:1534 09/04:0905 F 17:31: High drywell floor drain leakage

10. 11/02:0251 Remained off- SP

• 1437:09 Planned maintenanc@

line through-out December l

• Outage ended 01/05/84: 0725 Total duration: 1540:34 L -.

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Fobinson Unit 2 Off-Line Outages Januarv Thrcuch December 1983 Date/ Time Date/ Time Hrs./ Min.

Off On Tvce Duration Reason

1. 12:31:0227 01/01:1321 F 34:54 Low steam generate 13:21 Jan. water level 21:33 Dec.

2. 01/07:2346 01/09:0055 F 25:09 Feedwater heater tube leaks

3. 02/18:0725 02/18:1653 F 09:28 Excessive vibratioc on "B" component cooling water pumpi

4. 03/23:1109 03/24:0555 F 18:46 . Low steam generatod water level'

5. 04/01:0642 04/02:0645 F 24:03 Feedwater heater tube leaks (n 04/02:1454 04/04:1701 F 50:07 Oil leak in the Electro-Hydraulic ,

Control (EHC) Systq

7. 04/19:2209 04/21:1205 F 37:56 Loss of Electro-Hydraulic Control (EHC) System oil pressure.

8. 04/24:1728 04/25:0311 F 09:43 Inoperable Service Water Booster.

Pumps (SWBP)

9. 04/29:0105 05/28:0124 SP 696:19 -Scheduled maintenaa and steam generatos inspection

10. 06/22:1653 06/22:2333 F 06:40 Reactor-coolant system. leak

11. 07/28:0446 07/29:0312 P 22:26 Valve leakage in t LAuxiliary Feedwater-Pump

,12. 09/05:1050 09/21:0159 F 375:09 . Steam generator tubd

( leak

13. 11/03:0453 12/08:1357' F '849:04 Steam generatorntub l inspection.

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Rcbinson Unit 2 (continued) i i Off-Line Ou ges

January Throuch December 1983 4

Date/ Time Date/ Time Hrs./ Min.

Off On Type Duration Reason

' 14. 12/08:1415 12/08:2155 F 7:40 Feedwater regulate:-

valve inoperable i

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Attachment I-18 l

Following is a list of the planned outages which occurred at each of the Company's l nuclear generating units over the period 1978 through 1983. Included on this list is the outage duration as scheduled at the start of the outage. For those outages with actual durations exceeding the scheduled durations, a brief explanation of the extension is provided.

Brunswick Unit 1 Actual Scheduled Duration Duration Year (HRS: MINS) (HRS) Reason 1979 2255:55 1680 The outage was extended to include replacement of core spray piping.

1980 2110:42 1768 Extension of the outage was required due to unplanned and unscheduled inspection, analysis, and repair of the control rod drive system pipe hangers and pipe supports; NRC requirements to test control rod operation under " scram" r

1 conditions; NRC required inspection of l

i core spray piping; and unanticipated delays with other maintenance activities.

I 1981 3811:27 1752 Extension was required to repair damaged I turbine-generator bearings.

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1 1982/83 6204:02 4704 Extensions of the outage were incurred during the major activities portion of the schedule, prior to reactor start-up, in reassembling the reactor vessel and conducting hydrostatic tests of the' vessel and associated systems; and in completing operability tests and periodic tests associated with the major plant and system modifications which had been made to that point. Further delays were encountered after reactor start-up with the nuclear instrumentation system, rod sequence control system, 480 volt safety-related breaker system, and control rod drive leakage.

1983 752:32 502 The outage was extended due to the need to make repairs to pipes, - delays associated with periodic tests .of batteries, and additional seismic support modifications identified as being needed'

- after the outage started.

Brunswick Unit 2 1979- 1854:53 1512 The outage was extended due to unanticipated repairs on generator O

t r- -t t w= e- a--- e

hydrogen seals, increased control rod drive maintenance, nuclear instrumentation repairs, and core spray piping replacement. )

l 1980 4808:21 1728 Extension of the outage was required due I to unanticipated delays experienced with I the torus modification activities and duc l I

to unplanned and unscheduled inspection, analysis and repair of the control rod drive system pipe hangers and pipe supports.

1982 3899:09 1680 The outage was extended to perform additional testing of primary containment isolation valves and to complete a comprehensive review of Technical Specification test requirements.

1983 741:10 288 The outage was extended to repair Reactor Isolation Penetration valves which failed a periodic test performed during the outage, investigate Main Steam Isolation Valve (MSIV) control problems, and to replace a failed transformer.

i I 1983/84 1540:34 1008 The outage was extended due to failure of one of the eight battery banks to successfully pass a periodic test required for startup.

i Robinson Unit 2 1978 1941:24 1080 Inspection of the low pressure turbines

revealed the need to replace the turbine rotors. The outage was extended to allow for procurement and installation of replacement rotors.

i 1979 2277:21 1008 The outage was extended to replace pipe fittings in the steam generator feedwater system. The need for replacement of the fittings was determined from radiographic i inspection which revealed cracks in the

' fittings after a similar problem had been identified in other nuclear plants, i

1980 1850:42 768 The outage was extended to complete steam generator inspections and tube repair, and to finish modifications to the fire protection system.

i w . . - . .-. -. ,,r. .

1982 4070:42 2304 The outage was extended to repair reactor coolant pumps based on problems discovered during performance of the Ten-Year In-Service Inspection and primary system leaks which developed during heat-up.

I 1983 696:19 552 The e cage was extended due to an-ancrease in the number of tubes requiring plugging and various miscellaneous delays that were required in order to correct problems identified during heat-up and start-up.

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Attachment I-24, 1 of 2 '(gr Staffing Levels Brunswick Plant (CP&L Operating Personnel Reporting to the Plant General Manager)

July 78 79 80 81 82 83 Year-End

• • Minsger/ Superintendents 3 -

5 7 8 8 5

• Engineering. 33 36 36 39 84 97 tOperations 77 115 109 130 133 195

" Maintenance 125 177 192 271 278 328

'* Administration 55 62 63 63 90 91

• F&RC 49 49 75 75 131 135 Regulatory Compliance- 11

• Stcrt-up N/A N/A- N/A N/A N/A N/A

• NS & QA' 7 24 26 N/A N/A N/A

• Plcnning & Scheduling 5 10 N/A TOTAL 349 -468 -508 591 734 862 Actual 294 378 432 521 701 830

• Functional subunits include authorized Supervisors, Foremen, Specialists, Engineers, Technicians, Clerks if

,rpplicable to subunit.

'** Includes-Hanagers, Superintendents, Directors.

4RMC-I-1

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P O O V Attachment I-24, 2 of 2 s

Staffing Levels Robinson Plant (CP&L Operating Personnel Reporting to the Plant General Manager)

July 78 79 80 81 82 83 I

• • Manager / Superintendents 1 1 4 4 4 7

'eEngir.eering 26 26 25 25 27 54

• 0perations 66 66 85 85 97- 87

• Meintenance 71 71 95 95 98 126  ;

• Administration 20 20 28 28 39 72 r

• E&RC- 34 -34 36 36 50 56

• Start-up C'

• KS & QA 5 5 19 19 ,,

• Planning & Scheduling 2 6

.,10TAL 223 223 292 292 317 '408

. Actual 186 196 .237 265 298 354

.*Func'tional subunits. include authorized Supervisors,' Foremen, Specialists, Engineers, Technicians, Clerks if' applicable to subunit.

• • Includes-Managers, Superintendents, Directors.

4RMC-I-21 '

7

/

v' Jun: 1979 Name: SHEARON HARRIS Business Address: Carolina Power & Light Company P. O. Box 1551 Attachment 28 A Raleigh, North Carolina 27602 Education: Completed High School in Beaufort, North Carolina A.B. from Wake Forest University (1936) .

LL.B. from Wake Forest University (1938)

Honorary LL.D. from Wake Forest University (1978)

Principal Business: Chairman of the Board, Carolina Power & Light Company Other Business Affiliations:

PRESENT: Director of Wachovia Bank & Trust Company and Wachovia Corporation Director of Durham Life Insurance Company Director of General Motors Corporation Director of United States Steel Corporation PAST: From 1939 until 1957, when he joined CP&L, he practiced law in Albemarle, North Carolina.

HISTORY AT CP&L: Associate General Counsel in 1957 President 1963 Vice President 1960 Chief Executive Officer 1969

. Member of Board 1961 Chairman of the Board 1970 General Counsel 1962 ,

Record of activity and leadership in business, professional, civic and military organizations:

PRESENT:

Chairman, Executive Committee, Chamberof Commerce of the United States Director, North Carolina Foundation of Church Related Colleges Director, Executive Committee, North Carolina Citizens Association Member, The Business Council sd -Director, Edison Electric Institute Trustee, Committee for Economic.Developmc.nt .

Vice Chairman, Board of Trustees, Meredith College Member, Listed Company Advisory Committee, New York Stock Exchange Director, Research Triangle Foundation of North Carolina U$ P -Member, Policy Committee, Business Roundtable Member, North Carolina Council of Management and Development PAST:

Principal Clerk in the North Carolina House of Respresentatives - 1941 and 1943 Representative from Stanly County to the North Carolina House of Representatives - 1955 President, North Carolina Citizens Association President, Southeastern Electric Exchange Chairman, Chamber of Commerce of the United States Chairman and Director, Electric Power Research Institute Chairman, Edison Electric Institute Chairman, National Association of Electric Companies Director, National Association of Manufacturers Trustee, Wake Forest University Recipient of Religious Heritage of America Award Parliamentarian for the North Carolina Baptist State Convention Holder of the Bronze Star and Legion of Merit citations for service in the European Theatre during World War II Family: Married to the former Helen Finch Morgan of Albemarle. They have three daughters:

Miss Sarah Harris of Hollywood, California; Mrs. Jennie H. Bell of Durham; and Miss Susan-

' Harris of R,aleigh, North Carolina.

1

Ul0 GRAPHICAL INFORMhilG June, 1983 SHERW000 H. SMITH, JR.--CHAIRMAN / PRES 10ENT/CEO CAROLINA POWER S LIGKT COMPANY Positions Held at CPSL Chaotman/ President /CEO, Matj, 1980; Attachment 28 B Pres.ident/Chicf Administrative Officet, Decembet, 1976,  ;

Execu,tive Vice Presidott - Adminis.tration,1974; l Member of Board af OLtcetork,1971; Senior Vrce P.tesident/ General Counsel,1971; Associate General Cowtset,1965.

Prior to joining CPSL in 1965, ptacticed law in Charlotte and Raleigh, N.C. (1960-1965).

Carrent Elceltic Utility industry Activities Oitector/ Executive Commrttee membet, Edison tleeltic Institute; Director / Executive Comnittee member, Atonic Industrial Forum, Inc.;

Directo.1/ Executive Committee member, Secretary /Treasatch, Sou,theastern Eteettic Reliabilitij Cowicil; Director, Ametican Nueteat Enetgy Cowicil; Oltector, United States Committee on Enetgy katreness; Director, Scatheastern Eteettic Exchange; Mcmber, Polict) Comnittee on Governmental Affaiu, Edison Electtic Institute.

Othet Activities P.tes ent:

Volwtteet State Chaitman, United States Savings Bonds Program; Vice Cha.vunan, Mietoelecttonics Center of North Carolimt; Vice Chaltatn, Boatd of Trustecs, Rex Hospital, Raleigh, N.C.;

Vice Chairman, Centtal Selection Committee, Morehead Schotats, University of N.C.;

DiAcetor, Basiness Foundatwn of North Carolina; Oitector/ Executive Committee member, Second Vice Chaitman, North Carolina Citi;: ens for Busin:

6 Industry; Oltector, Durham Life Insatance Compant) S Datham Corpwtation; OLteetor, United States Na.tional ComnLttee, World EneAgy Conference; DLtecto.1, Wachovia Bank & Trust Company and Wachovia Corporation; Director, Research Triangte Founda. tion of North Carolina; Dircetor/ Member, Raleigh Rotartj Club; Trustee, indepatdent College Fund of North Carolina; Trustee, Z. Smith Retjnolds Foundation, Winston-Salem, N.C.;.

Member, President's Council for International Yoath Exchange; MembeA, American Nuclear Society; Member, Energy ComnLttee, Chambet of' Commerce of .the United States;

, Membet, UnLted Negro College Fund's National Corporations Comnittee; Member, North Carolina Cowtcit of Management S Development; Member, Execu,tive Comnittee, The Educational Founda, tion, Inc. ,- UNC-Chapel Hill, N.C.;

Membet, Chris t Episcopal Chutch, Raleigh, N.C.

' Past:

ChaL1 man, American Nuclear Enetgij Cowtsil:

Chaitatn, Raleigh Civic Center Authorittj; Chaitntn, North Carotina Heart Association; President /Ditector, Greater Raleigh Chambet of Commerce; President, Basiness Foundation of North Carolina; Ptesident, Rehab.iLitation and Cerebral Patsy Centet of Wake County;

'irector of Manpower, GoveAnor's Ef fielency Stadt) Commission; Director, United Way of Wake Countij; DiAcetor, Rateigh 80ys

• Club; Member, Polict) ComnLttee, The Business Roundtable; Member, Governor *s Energy Crisis Studtj Commission.

Education

• A.B. Ocytee and J.D. Ocgtce with Iwnors from nie univeuity of North Carolina at Chapel Hitp where he was a member of Phi Beta Kappa and a Marchead Schotat.

Fanlly Martied to the former Eve Hargrave of Lexington, N.C. They are parents of three daughtets.

Attachment 28 C 2

PLANT VISITS t

Sherwood H. Smith, Jr.

PLANT 1981 1982 1983 BRUNSWICK July 24 January 27- January 26 August 25 February 25-26 March 18

October 12 April 23 April 26 December 17 June 18 July 6 July 15 August 13 September 15 October 28 J

i j HARRIS May 28 January 28 June 29 February 15 July 13 June 21 ROBINSON September 2 June 11 1

I

i i

l Attschment 28 D BIOGRAPHICAL INFORMATION E. E. UTLEY Executive Vice President Power Suppiv and Engineering & Construction EDUCATION & TRAINING College: Louisburg College and N. C. State University Courses: Massachusetts Institute of Technology " Nuclear Plant Design & Operation Course" Georgia Institute of Technology "Public Utility Executive Course" Edison Electric Institute " Executive Management Program" PROFESSIONAL SOCIETIES & INDUSTRY ORGANIZATIONS American Society of Mechanical Engineers North Carolina Society of Engineers The Raleigh Engineers Club American Nuclear Society (National)

American Nuclear Society - Eastern Carolinas Section National Society of Professional Engineers Professional Engineers of North Carolina Association of Edison Illuminating Companies - Member of Committee on Power Generation Southeastern Electric Exchange - Member of Engineering & Operation Division Executive Committee American Nuclear Society - Corporate Organization Member Atomic Inudstrial Forum - Corporate Organization Member Institute of Nuclear Power Operations - Corporate Representative and Chairman of INPO's Evaluation & Assistance Division Industry Review Group EXPERIENCE Joined CP&L in 1951 in the Operating & Engineering Department. In 1959 appointed Superintendent of the W. H. Weatherspoon Plant. In 1963 appointed Superintendent of the H. F. Lee Plant. In 1965 appointed Superintendent of the Roxboro Plant. In 1966 promoted to Production & Results Engineer in the General Office. Responsibilities in that position included the general supervision of the operation and maintenance bf steam electric generating plants and the procure-ment of coal. In 1968, nam 4d Manager of Production, and to previous responsibilities was added the general supervision of the Company's

~

hydroelectric generating plants. These functions and the System Operations Section were combined to form a separate department of the Company on May 1,1970, and then became Manager of, Generation

& System Operations Department. This department was reorganized in 1972 and became the Bulk Power Supply Department. In September 1972, named Vice President of the Company. On January 1, 1977, the Bulk Power Supply Department was restructured into three departnents, forming the Power Supply Group. At that time, appointed Senior Vice President and head of the Power Supply Group. In May-1979 named Executive.Vice President. On June 1, 1979, a reorganiza-tion of the Company's Operations Groups resulted in being placed in charge of.the Power Supply & Customer Services Groups. In April 1980 named Executive Vice President Power Supply and Engineering _

& Construction. At the present time, this is composed of the Nuclear Generation, Fossil Generation & Power Transmission, &

Operations Support Groups and the Coroorate Quality Assurance, Corporate Nuclear Safety & Research, and Brunswick Nuclear Project Departments.

4/84 4.

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M. A. McDuffie Attadiment 28 E

) Senior Vice President Nuclear Ceneration 4

Date of Birth: September 8, 1924 I. Education A. B.S. Degree in Civil Engineering from N. C. State University - 1948. '

II. Experience

, A. 1948 - 1952

1. Ebasco Services Incorporated, New York, N. Y.

a. 1948-1949 - Instrumentman, then acting Party Chief on con-struction of Lumberton S.E.P. - Units 1 & 2, 88,000 KW Installation.

b. 1949-1950 - Party Chief on construction of Lumberton S.E.P. -

4 Units 1 & 2, 88,000 KW Installation.

c. 1950-1952 - Construction Supervisor on construction H. F.

Lee S.E.P. - Unit 2, 66,000 KW Installation.

B. 1952 - 1955 -

1. News & Observer, Raleigh, N. C.

a. Reporter C. 1955 - 1970

1. Ebasco Services Incorporated, New York, N. Y.

4 a. 1955-1956 - Office Engineer on construction of Cape Fear S.E.P. - Unit 5, 125,000 KW Extension.

i'

b. 1956-1958 - Field Engineer on construction of Cape Fear S.E.P. - Units 5 & 6, 281,000 KW Extension.

c. 1958-1960 - Construction Engineer on construction of H. B.

] Robinson S.E.P. - Unit 1, 182,000 KW Installation.

d. 1960-1962 - Resident Engineer on construction of H. F. Lee j S.E.P. - Unit 3, 250,000 KW Extension.

! e.

' 1962-1964 - Construction Superintendent on construction of

' Asheville S.E.P. - Unit 1, 190,000 KW Installation.

f. 1964-1965 - Construction Superintendent on construction of Roxboro S.E.P. - Unit 1, 375,000 KW Installation.

1 l  !!. A. McDuffie *

{ g. 1965-1966 - Project Superintendent on construction of Roxboro i i

S.E.P. - Units 1 & 2, 1,025,000 KW Installation.

h. 1966-1968 - Project Superintendent on construction of H. B.

j Robinson S.E.P. - Unit 2, 700,000 KW (e) Nuclear Installation.

1. 1968-1970 - Construction Manager supervising construction of

} Fossil and Nuclear steam electric stations and

. switchyards on East Coast.

4 J D. June 1970 to Present

1. Carolina Power & Light Company, Raleigh, N. C.

I a. Employed as Manager of Construction in the Power Plant Design

] & Construction Department.

i b. September 1, 1973 - Promoted to Manager, Power Plant Construc-tion Department.

j c. December 5,1974 - Promoted to Vice President, Power Plant Construction Department.

l 1

d. June 24, 1976 - Promoted to Senior Vice President, i

1 Engineering & Construction.

1 e. August 1983 - Senior Vice President, Nuclear Gene, ration III. Professional Societies i

A. Registered Professional Engineer in State of North Carolina j B. Registered Civil Engineer in State of South Carolina i C. North Carolina Society of Engineers i D. Raleigh Engineers Club

{ E. National Society of Professional Engineers i

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j Revised 9/8/83

RESUME I. Name - James M. Davis, Jr. ^ **"

II. Position - Senior Vice President - Operations Support

, III. Date of Birth - May 9,1936 IV. Education and Training B. S. Degree in Mechanical Engineering, North Carolina State University, Raleigh. NC - 1958 V. Experience A. Companies (other than CP&L) and Military Experience

1. July 1958 - August 1961 - Reserve Officer in U. S. Air Force.

! 2. September 1961 - September 1965 - Test Engineer in the Experimental Engineering Department of Pratt and Whitney

Aircraft, East Hartford, Connecticut.

B. Carolina Power & Light Company i

1. September 1965 - February 1968 - Employed as a Heating and Cooling Engineer in the Special Services Section of the Marketing Department.

2. February 1968 - November 1970 - Assistant to Director in the l Rates and Regulation Department.

I

3. November 1970 - December 1976 - Assistant Director in the Rates and Regulation Department.

4. December 1976 - June 1979 - Manager of Rates and Service j Practices Department.

5. June 1979 - December 1980 - Vice President of Fuel and Materials Management Group.

6. December 1980 - August 1983 - Senior Vice President of Fuel and Materials Management Group.

7. August 1983 - Present - Senior Vice President of Operations Support Group.

VI. Professional Societies. Status of Registration, and Industry Organizations A. North Carolina Society of Enginearn - Director, District II Professional Engineers of North Carolina National Society of Professional Engineers American Nuclear Society North Carolina Chapter of the Health Physics Society The Raleigh Engineers Club B. Registered Professional Engineer - North Carolina - 1967 C. EEI/ Utility Nuclear Waste Management Group - Chairman, Steering Committee Hazardous Waste Subcommittee of the Solid and Hazardous Waste Management Planning Committee of Triangle J Council of Governments Technical Advisory Committee on Low-Level Radioactive Waste of the Governor's Task Force on Waste Management

, . James M. Davis, Jr.

YEAR SEMINAR OR COURSE / SOURCE 1966 National Warm Air Heating and Air Conditioning Association Instructor Training Course 1968 PUR GUIDE /Public Utilities Reports, Inc.

1968 Utility Training Program /Ebasco Services Incorporated.

1973 GENCO/CP&L.

• 1973 Speed Reading / North Carolina State University, Raleigh, NC.

j 1978 Adversary Interviewing Workshop /Reddy Communications.

1978 Executive Ef fectiveness Course /American Management Association,

, Atlanta, GA.

1979 BWR Fuel Conference / General Electric, Wilmington, NC.

1979 North Carolina's Energy Future: Policy Research Alternatives /

American Association for the Advancement of Science, Raleigh, NC.

1980 Assertiveness Training for Managers Course /American Management Association, Atlanta, CA.

]

1980 BWR Operating Familiarization Course / General Electric, Tulsa, OK.

i 1980 Fuel Cycle Conference '80/ Atomic Industrial Forum, New Orleans, LA.

1980 Radwaste Management Seminar / Catalytic, Inc., Philadelphia, PA.

l 1980 & 1981 The Outlook for Coal Conferences /The Energy Bureau, Inc. ,

l Arlington, VA.

1981 Negotiating and Administering Coal Supply Agreements / Coal Age-McGraw Rill, Atlanta, GA.

, 1981 Executive Conference - State, Federal, Nuclear Interface, American Nuclear Society, Monterey, CA.

, 1981 Future Uncertain: North Carolina and the Problems of Hazardous Wastes / Duke University Program in Science, Chapel Rill, NC.

1981 Light Water Reactors Course / North Carolina State University, Raleigh, NC.

1981 Managing Low-Level Radioactive Waste Workshop /American Hospital Association, Chicago, IL.

1981 Nuclear Power Assembly, Washington, DC..

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i i James M. Davis , Jr. , Continued i

YEAR SEMINAR OR COURSE / SOURCE l

{ 1983 "On Leadership" Executive Seminar, Levinson Institute, i Cambridge, MA.

}-

l 1983 Executive Management Program, EEI, Hershey, PA. l 4

l 1984 General Employee Training (GET)

Level I: Plant Indoctrination Level II: Radiation Protection J

} 3/84 i

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l E. E. UTLEY - NUCLEAR PLANT VISITS - 1982 l

l ROBINSON PLANT DATE PURPOSE March 5 Senior Management Review April 14 Senior Management Review May 21 Senior Management Review June 30 Senior Management Review August 27 Exit Meeting - INPO Emergency Preparedness Review & Assistance Visit

September 2 Senior Management Review November 3 Senior Management Review December 16 Senior Management Review BRUNSWICK PLANT DATE PURPOSE January 21 Senior Management Review February 18 Senior Management Review April 8 Senior Management Review May 27 Senior Management Review July 8 Senior Management Review July 21 Meetings re

NRC enforcement action July 26 Meetings re: NRC enforcement action July 30 Meetings re: NRC enforcement action August 13 Meeting of Safety Review Panel August 30 QA videotape at plant September 1 Senior Management Review September 15 Board of Director's tour and meeting October 13 Senior Management Review November 17 Senior Management Review November 18 GE/CP&L Meeting HARRIS PTANT DATE PURPOSE April 6* Senior Management Review June 29* Harris INPO Evaluation Exit Meeting July 13* Senior Management Review l August 25* Senior Management Review September 21 Project Review - Site October 22* Senior Management Review November 2* Executive Review November 11* Senior Management Review

?

December 7* Senior Management Review

• Meetings held at Harris Energy & Environmental Center

l

. Attachmsnt 28 a E. E. UTLEY - NUCLEAR PLANT VISITS - 1983 i

ROBINSON PLANT DATE PURPOSE January 13 Senior Management Review February 18 Senior Management Review April 20 Senior Management Review May 20 Senior Management Review May 27 QA Exit Meeting June 16 Senior Management Review July 6 Senior Management Review August 9 Senior Management Review September 15 Senior Management Review October 11 Senior Management Review November 30 Senior Management Review BRUNSWICK PLANT DATE PURPOSE January 5 Meeting regarding NRC enforcement action January 6 Meeting regarding NRC enforcement action January 21 Meeting regarding NRC enforcement action February 4 Senior Management Review March 9 Meeting with Charnoff (Shaw/Fittman)

March 10 INPO Exit Meeting (Brunswick Evaluation)

March 18 NRC Meeting April 14 Senior Management Review April 26 NRC Meeting April 29 QA Exit Meeting May 5 Senior Management Review June 9 Senior Management Review August 3

• Senior Management Review September 14 Senior Management Review October 12 Senior Management Review October 13 NRC Meeting November 17 Senior Management Review November 29 GE/CP&L Meeting-December 8 Senior Management Review HARRIS PLANT DATE PURPOSE January 12

• Senior Management Review January 28

• Meeting with NRC - re: Harris Self-Initiated Eval.

February 3

• Senior Management Review March 1

• Executive Review ,

April 12

• Senior Management Review May 3

• Senior Management Review June 2

• Senior Management Review June 24 Presentation on Hctris Operational Program July 12

• Executive Review August 2

• Senior Management Review September 1

• Senior Management Review October'4

• Senior Management Review November 8

• Executive Review December 6

• Senior Management Review December 14

• Review Presentation for Harris ACRS Meg.

• Meetings held at Harris Energy & Environmental Center

b e,

Attachment I-39(r)

NRC VIOLATIONS Shearon Harris Nuclear Power Plant Date of Response to Notice Summary of of Violation Incident Action Taken Tests were improperly performed Concrete Compressive

) 11/17/81 on concrete cylinders due to Testing certification excessive loading. for the technician involved was rescinded until the technician passed both oral and written exams.

3/25/82 Weld inspector failed to identify Employee responsible report deficiencies because he did was removed from pipe not see them. weld inspection, pending reinstruction.

t 4/23/82 Weld inspector either overlooked or Employee responsible arbitrarily failed to reject defects was removed from pipe in welds weld inspection and is no longer employed by CP&L.

j Date of Incident 4/83 performed and inspected own work counseled prior to 7/29/82 improper inspection of welds employee resigned before action could be taken 4/82 suspected of improper initialing of employee resigned while seismic I inspection reports investigation being conducted 4/21/83 unsatisfactory performance of weld certification invalidated, inspections retraining, retesting . and recertification required 12/82 unsatisfactory performance of weld certification rescinded; inspectiens recertification required.

Warning given.

prior to 2/3/82 evidence of use of cocaine terminated j 3

2/84 Failure to comply with work suspension (probation) procedure

i j H.B. Robinson Unit 2 i

, Date of i ,

Response to Notice i of Violation i

7/26/78 A chain holding up a radiation area Employee involved was sign had broken loose from the wall reprimanded and counseled.

I and a Radiation ControlTechnician

! was instructed to submit a trouble J

ticket for the repair of the chnin.

The technician failed to perform this task.

8/22/79 Individuals entered the reactor Employees were counseled.

containment, which was a locked,

! high radiation area, without i entering their names on a valid I radiation work permit.

i 2/5/80 Fire protection program states that All parties involved were j every connection from a yard main made aware of the incident to a building be equipped with a and cautioned to prevent l post indicator valve, and large further occurrence.

yard main systems must be provided

with sectional controlling valves at I appropriate points. However, the yard main connection to the Auxiliary Building interior fire hose system was not provided with a post indicator

!, valve and a post indicator sectional control valve was not provided for the i northeast portion of the water main i

loop. This was a result of an FCR

! (field change request) made by -

Construction that was disapproved

! by Engineering but the change was

{ actually made.

s 11/12/80 Field documents used to verify the Employees involved were as-built for safety-related system cautioned and counseled.

ISO-RC-4 did not have any records of inspection of clearances for the wall penetrations.

7/30/81 An Auxiliary Operator was climbing Employee involved was in the overhead piping in the Boric reprimanded.

Acid Evaporator Room wearing only.

shoe covers and gloves instead of anti-contamination clothing which were required.

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. - . _ _ ,_ _ _ _ _ . _ _ _ _ _ , _ - ~ _ , _ . . _ __ ._ _ _ , . ,

4 .

t 1/29/82 An individual was observed in the Employee involved was Boric Acid Evaporator Room without reprimanded.

a dose rate survey instrument.

6/17/81 Radiation surveys of the hot leg Employees involved were compartment inside Steam Generators cautioned as to the A, B, C performed 9/17/80 were not importance of retaining maintained or preserved. all survey documentation.

9/10/81 Changes were made in the Gas Employees involved were Calibration step of procedure RCP-1, cautioned.

without prior review by Plant Nuclear Safety Committee or approval  ;

by the General Manager.  !

12/22/81 An operator failed to follow valve Employee involved was lineup procedure OP-38A for counseled regarding the positioning of valve RHR-764 from seriousness of improper locked open to locked shut position performance of valve lineups.

4/15/82 Equipment control polley was not Employees directly involved implemented in that Local Clearance were admonished.

and Test Request 113 listed incorrect auxiliary feedwater system valves for the maintenance performed, and clearance was canceled without opening the isolation valve for a local suction pressure gauge.

12/2/82 QA audits were not performed within Employees (CQA) responsible the 24 month frequency were counseled by the Corporate QA, not by the HBR management.

3/4/83 Various Fuel Shuffle procedures were Employee involved had not implemented during the 12/26- disciplinary action taken 12/28 fuel movement against him involving loss of pay. The employee's Shift Foreman was counseled.

6/22/83 Disposal of I gallon of liquid Employees responsible were waste containing licensed material admonished and counseled.

by way of Chem-Nuclear Systems,Inc.,

SC, who was not authorized to receive liquid waste Date of incident 2/83 failure to follow plant periodic increase in pay procedures deferred for 6 months

~_ ._ __ . _ -- _ _ _. _

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4 improper pseformance of valve employee sent home; resigned 5/83 before further disciplinary lineups j

' action could be taken  :

noncompliance with administrative - t counseled 3/83 procedures failure to sign out on R.'W.P. . counseled 2/83 2/83 conviction of possession of terminated controlled substance off the job (on his own time) failure to follow procedure. counseled 2/83 Sodium hydroiden 3 aupply' valvo left out of position.

2/10/83 failure to follow plant procedures periodic pay increase deferred for 6 months failure to implement all aspects of counseled; required 1/11/83 special procedure for moving spent to review special fuel in spent ft.el pit procedure and administrative requirements for procedures compliancel 2 days suspension without pay.

2/19/84 Violation of H.P. procedures I week without pay 2/19/84 _ Violation of H.P. procedures I week witicut pay

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Brunswick Steam Electric Plant  ;

Date of Response to Notice of Violation 9/20/78 Individual was observed not wearing Employee involved ,

the required protective clothing as was counseled on I specified. importance of radiation control techniques.

Employees involved 3/12/79 After an individual had received an exposure in excess of 5 rem (whole were counseled on body), Licensee failed to submit value of prcmpt a written report within 30 days. submittals.

4/2/79 Reviewers failed to notice out of Employee involved specification stroke time for valve was counseled.

F046 during RCIC Pump and Valve Operational Test. t 7/24/79 Two Auxiliary Operators without lab Employees involved coats entered a contamination area were counseled by the in the Reactor Building which required Shift Foreman.

lab costs for entry.

10/25/79 QA Test results had discrepancies Employees involved that had not been identified by were cautioned about Licensec's review process, seriousness of not recognizing and evaluating ..

deficiencies.

i 12/20/79 A fire protection sprinkler and stand- Employees involved pipe system for the No. 3 Diesel Cencrator were counseled regardit was isolated and the continuous fire watch the proper actions to was not stationed. take.

1/13/81 Valve lincup verification documentation Appropriato corrective showed that locked valve PT46.1, RCIC, or disciplinary actions and HPCI turbino exhaust manual stop for employees were check valvos were verified open, when taken 'two Shift in fact both were closed. Foremen roccived no nucicar license suppicment pay for one weck; two Auxiliary Operators given one

, , day off 'with no pay.

e e

k____..__.___.__.__

12/30/80 Scmpling and annivaio of cirborne Involvsd RC&T tsch- I particulate radioactivity was nicians were counseled.

inadequate: 40% of total particulate i activity in Reactor Building roof vents were not identified.

2/3/81 Training requirements for BSEP QA . Appropriate employees Surveillance Personnel, which had were enunseled.

not been revised since 9/75, referenced procedures that no longer existed and did not cover more chan 25 standards and procedures that were then a part of QA Control.

12/18/81 Various vent monitors were found to be Technicians responsi-inoperable due to lack of maintenance. ble were counseled.

7/1/81 Approval requirc=ents for temporary Employees involved changes made to procedures RC-ER-12 were counseled.

and RC-ER-18 were not met.

8/26/81 As a result of operator error, the Disciplinary action reactor mode switch was taken out of was taken with the the refueling mode, placed in startup, employees infolved.

and controlled withdrawal commenced with- Letter of' reprimand the A-loop RHR torus suction valve shut. placed in-file for one year period.

10/30/81 Radiation llazards Survey concerning All three employees repair of a valve was inadequate, involved were counseled causing a worker to exceed dose and disciplinary action limit, was taken - one employet was given two weeks off without pay; two employees were assigned to Caswell Beach Pump-ing Station.

10/6/81 Two employees were. observed in posted Employees involved radiation areas without proper dress, were counseled.

10/12/81 An inadvertent release of approximately Employee involved 300 gallons of liquid waste from the was counseled.

"B" floor drain sample tank without prior sampling for gross activity- .

Temporary changes to PT-A3 Rev. O and Operations ecployees OP-50.1 Rev. 13 were approved by Plant -were cautioned.

Nuclear Safety Committee in 16_and 17 days instead of the required 14 days from implementation date.

11/2/81 Inoperabic instrumentation channel :All Senior Reactor was not placed in the tripped = ode Operators were

-within one hour of determination _ .cpunseled as well as that this instrumentation could not ILC ' periodic testing-be calibrated._ personnel.

u ~-

1 o

11/30/81 Temporary change to Liquid Radioactive Operations employees -

Waste Processing System Procedure was were cautioned. .

not reviewed although it remained in effect through August 1981. ,

3/11/82 A primary coolant sample taken at Employees involved 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> exceeded .2 UCi/ gram dose were counseled, equivalent I-131, and the subsequent samples required once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> were not taken.

8/16/82 Reactor vessel water level low Employees involved instrumentation (transmitter), required were counseled, by Technical Specifications, was inoperable. However, trouble ticket was prepared, stating that the trans-mitter was not required by Technical Specifications.

4/30/82 Shift Foremen failed to complete an Employees involved Event Evaluation Check Sheet or make were counseled.

entry in the Shift Foremen's log when informed that the Standby Liquid Control heat tracing circuits were inoperable.

7/2/82 1A-1 battery charger was momentarily Two operators not positioned as per clearance responsible were procedure, and service water vital counseled, header crosstie valve was not positioned as per operating procedure.

8/5/82 Contrary to Technical Specification 6.8.1(a), Regulatory Guide 1.33 Technician involved was counseled.

Appendix A was not implemente'd in that safety-related equipment mainte-nance instruction was not correctly performed. '

6/24/83 Reactor Water Cleanup System was not Senior Reactor Operator isolated, as required by Table 3.3.2-1 was removed.from Item 3.a, within one hour.

licensed duties for two weeks and during that time was counseled.-

i i

t _ x- --

8/11/83 Unit 2 augmented off-gas system was On-shift personnel out of service and the air ejector 4xcluding radioactive off-gas monitors were inoperabic, yet waste and fire protec-a reactor shutdown was not initiated. tion) were immediately counseled. One-Control Operator was removed from licensed duties with loss of license supplement pay.for 14 days. Approximately 10 Shift Operating Supervisors, Shift Foremen, and Control Oncrators involved were given verbal repri-mands evidenced by meno to their files.

8/4/S3 A representative air sample was not The Health Physics collected in an individual's breathing Technician involved zone while he was splitting radioactive was been counseled.

waste bags containing material with unknown contamination levels and radiation levels of 30 mrem /hr.

Date of Incident or Action 2/12/83 use of unapproved procedure in 5 days suspension loading cask without pay and written reprimand 12/81 failure to adhere to established 3 days suspension -

health physics procedures without pay -

9/81 failure to adhere to established 3 days suspension health physics procedures without pay.

3/83 two radiation safety ' violations letter placed in file I within 60 days- with performance evaluation review to be made in 6 months 4/83 allowed an employee to sign ,

letter placed in file verification sheet for a periodic test performed by another 4/83 Improper clearance - failed to' one cay suspension .

_ L.

exercise supervisory overview without pay, letter of reprimand included in file 3/17/83 improper review of periodic test letter of caution 3/17/83 failure to sign off a step of a written reprimand periodic test 7/81 allowed worker to exceed calculated 2 weeks suspension stay time resulting in over- without pay exposure 10/15/81 Radiation safety violation. counseling False information about age.

12/20/82 failed to have QC verify letter of cleanliness of hold point reprimand 2/5/83 improper attention to procedures letter placed related to waste casks in personnel file for i year 8/81 , Level 2 radiation safety violation I day suspension '

without pay and I day training with health physics.

12/82 failure to do required testing in letter of reprimand time specified on diesel generator 4 1/83 failure to enter into action suspension of license pay statement as required - Technical for 2 weeks Specifications violation 2/83 failure to perform safety related 5 day suspension without activity in accordance with pay procedure 5/83 failure to maintain awareness of power plant status removed from contol floor-e u _ _;

January 10, 1984 Failed to exercise management Letter of reprimand.

control and demonstrate job responsiveness; three incidences. ,

January 10, 1984 Falsified time associated Two (2) days suspension with procedure completion. without pay.

January 25, 1984 Failure to accurately complete Memo to personnel file.

calculation associated with PT.

January 26, 1984 Procedural noncompliance; Memo' to personnel file.

improper work authorizations.

January 27, 1984 Deviation from procedure. One (1) day suspension without pay.

January 31, 1984 Procedure violation. One (1) day suspension

- without pay.

February 2, 1984

• Failure to accurately Memo to personnel file.

resear'ch information and misrepresented conditions through negligence.

k March 5, 1984 Uonconservative interpre- Memo to personnel file.

tation of Tech Specs resulting in failure to initiate a LCO.

March 8, 1984 Lost 0.27 uCi source thru Memo to personnel file, negligence and failed to follow sign out procedure.

March 22, 1984 Poor judgement and Memo to personnel file.

failure to notify super-vision of occurrence resulting in airlock seal

, damage.

March 23,.1984 Failure to maintain Memo to personnel file.

attention to detail resulting in improper LCO handling /cicarance.

April 11,1984 Valving error resulting in one (1) day suspension reactor scram; demonstrated poor judgement in sur-veillance and communication. I i

t

=

i Nbrch 8,1984 ! Fa11ure to follow control Two days off without pay and a

-procedure on Q-list weld rods letter of reprimand.

. resulting in a nuclear plant procedures report.

March 19,1984 Violated two health physics First violation - written reprimand, rules related to moving tools Second violation - two days off to an uncontaminated tool without pay.

Toom.

February 15, 1984 Worked on equipment prior 2 days without pay; written to preparation reprimand I

9

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t

i l

Attachment I-50 l

RETAINING WALL DESIGN DOCUMENT LIST l Ebasco Drawings: CAR-2167-G-2194 CAR-2167-G-2195 CAR-2167-G-2196 Associated DCN's and FCR's DCN-550-lll8 Rev. 2 DCN-550-Il40 DCN-550-ll20 Rev. 2 DCN-550-1120 FCR-C-4380 FCR-C-4413 FCR-C-4416 FCR-C-4438 Rev. 2 FCR-C-4472 FCR-C-4475 FCR-C-2185 FCR-C-4368 FCR-C-4494 Rev.1 FCR-C-4567 FCR-C-4583 FCR-C-4599 FCR-C-4536 FCR-C-4654 FCR-C-4350 FCR-C-4383

Attachment I-75 (c) & (d)

HNP RNP NELD NPL NSSS BNP CNS COA -

BS MS PhD BS tlS PhD BS MS PhD BS MS PhD BS MS PhD, BS MS PhD BS MS PhD BS MS PhD Nuclear Engineering 20 8 11 2 14 4 1 1 1 21 6 10 7 2 1 2 Physics 4 3 1 1 1 1 I 6 1 3 Thermodynamics' Eng. Systems Science Systems Engineering i NAT FOSS OTTS FUEL MCNT OPS

• BS MS PhD BS MS PhD BS MS PhD BS MS PhD Nuclear Engineering 5 3 14 15 1 Physics- 4 10 2 Thermodynamics. 1 Eng. Systems Science Systems Engineering 1 0 Ops '& flaintenance Section Only

( 9785JIIEl ev)

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

, AND NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY )

) Docket Nos. 50-400 OL (Shearon Harris Nuclear Power Plant, ) 50-401 OL Units 1 & 2) )

I AFFIDAVIT OF E.E. UTLEY County of Wake )

)

State of North Carolina )

E. E. Utley, being duly sworn according to law, deposes and says that he is Executive Vice President - Power Supply, Engineering and Construction of Carolina Power & Light Company; that the answers to Interrogatories on Joint Contention 1 (Management Capability) contained in " Applicants' Answers to Joint Intervenors Interrogatories and Request for Production of Documents to Applicants on Joint Contention I (First Set)" are true and correct to the best of his information, knowledge and belief; and that the sources of his information are officers, employees, agents and contractors of Carolina Power & Light Company.

hhU 'LM E. E. Utley >

' Sworn to a d subscrib d fore me thi day of ,1984.

V g Notary Public My commission expires: ,14[] /M4~

.g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

. BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1

In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL

)

(Shearon Harris Nuclear Power Plant, )

Units 1 & 2) )

APPLICANTS' RESPONSE TO JOINT INTERVENORS' REQUEST FOR PRODUCTION OF DOCUMENTS (JOINT CONTENTION 1)

Pursuant to 10 C.F.R. S2.741(d), Applicants hereby respond to Joint Intervenors' Request for Production of Documents as contained in " Joint Intervenors' Interrogatories and Request for Production of Documents to Applicants on Joint Contention I(First Set)"

by stating that the documents identified in Applicants' Answers to Joint Intervenors' ~

Interrogatories and Request for Production of Documents to Applicants on Joint.

Contention I (First Set) will be made available to the Joint Intervenors for inspection and copying in the following manner:

The requested documents will be . made available at the corporate _ offices of .

Carolina Power & Light Company,411 Fayetteville Street Mall, Raleigh, North Carolina, 27602. The documents will be made available during Carolina Power & Light Company business hours (or such other mutually agreeable time). Appointments to inspect the documents may be arranged by telephoning Hill Carrow at 836-6'839, at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> -

before the requested inspection. Applicants will maintain the requested documents assembled in Carolina Power & Light Company offices available for inspection by the Joint Intervenors, for a reasonable time (13., through June 1,1984), after which they will be returndd to their place of origin.

,. . , - . - . - . . , , . . . - y , ,

o Inspected documents which the Joint Intervenors wish to have copied will be reproduced by Carolina Power & Light Company on a schedule compatible with other demands for duplicating equipment. A Carolina Power & Light Company employee will be available during the inspection in order to receive any requests for copying. Copies of such documents will then be furnished to the Joint Intervenors upon payment of 7 cents per page, to meet Carolina Power & Light Company's cost of reproduction.

u n el~ w

/ V Samantha Francis Flynn d CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Attorneys For Applicants:

Thomas A. Baxter, Esquire John H. O'Neill, Jr., Esquire Shaw, Pittman, Potts & Trowbridge

1800 M Street, N. W.

Washington, D. C. 20036 *

(202) 822-1148 Richard E. Jones, Esquire Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Dated: May 1,1984

P r

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL

)

(Shearon Harris Nuclear Power Plant, )

Units 1 & 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Answers to Joint Intervenors Interrogatories and Request for Production of Documents to Applicants on Joint Contention I (First Set)" were served this 1st day of May,1984 by deposit in the United States mail, first class, postage prepaid, to all parties on the attached Service List.

This the 1st day of May,1984. f

! n

/Simantha Francis flynn iY w Associate General Counsel

/

Carolina Power & Light Company Post Office Box 1551 -

Raleigh, North Carolina 27602 (919) 836-7707 Attorneys for Applicants:

Thomas A. Baxter John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517

-. . ~ . - -

• 1 1

I SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of North Carolina U. S. Nuclear Regulatory Commission 307 Granville Road Washington, D. C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright . M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U. S. Nuclear Regulatory Commission Post Office Box 12643 Washington, D. C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U. S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D. C. 20555 Mr. Wells Eddleman Charles A. Barth, Esquire 718-A Iredell Street Myron Karman, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U. S. Nuclear Regulatory Commission Thomas A. Baxter, Esquire Washington, D. C. 20555 John H. O'Neill, Jr., Esquire Shaw, Pittman, Potts & Trowbridge Docketing and Service Section 1800 M Street, N.Vf.

Office of the Secretary ~ Washington, D. C. 20036 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Phyllis Lotchin 108 Bridle Run Mr. Daniel F. Read, President Chapel Hill, North Carolina 27514 Chapel Hill Anti-Nuclear Group Effort Bradley W. Jones, Esquire 5707 Waycross Street U. S. Nuclear Regulatory Commission Raleigh, North Carolina 27606 Region 11 101 Marietta Street Dr. Linda Little Atlanta, Georgia 30303 Governor's Waste Management Board 513 Albemarle Building Robert P. Gruber 325 Salisbury Street Executive Director Raleigh, North Carolina 27611 Public Staff North Carolina Utilities Commission Mr. Steven Crockett, Esquire Post Office Box 991 Atomic Safety and Licensing Raleigh, North Carolina 27602 Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555

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