ML20235K190

Forwards Draft NRR SALP Input for Plant Covering Util Licensing Activities for Nov 1985 - June 1987,for Review. Performance Rating of Category 2 Assigned.Comments Received by 870717 Will Be Incorporated in Final Rept

ML20235K190
Person / Time
Site:	Brunswick
Issue date:	07/10/1987
From:	Sylvester E Office of Nuclear Reactor Regulation
To:	Rossi C, Shao L, Varga S Office of Nuclear Reactor Regulation
References
NUDOCS 8707160195
Download: ML20235K190 (7)

Text

__

D D 5/1g <f JUL 101987 MEMORANDUM FOR: Steven A. Varga, Director DISTRIBUTION:

Division of Reactor Projects I/II (Docketef11e4 NRC PDR Lawrence C. Shao, Director Local PDR Division of Engineering G. Lainas and Systems Technology E. Sylvester P. Anderson Charles E. Rossi, Director PD21 r/f Division of Operational Events Assessment Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Jack W. Roe, Director Division of Licensee Performance and Quality Evaluation James G. Partlow, Director

. Division of Reactor Inspection and Safeguards THRU:

Elinor G. Adensam, Director Project Directorate II-1 Division of Reactor Projects I/II FROM:

Ernest D. Sylvester, Project Manager Project Directorate 11-1 Division of Reactor Projects I/II l

Enclosed is a draft of NRR's SALP input for Brunswick Steam Electric Plant, Onits 1 and 2 covering Carolina Power & Light Company (CP&L) licensing activ-

]

ities for the period from November 1, 1985 through June 30, 1987. The report is based on inputs provided by NRR reviewers and observations by NRR project management during their interactions with CP&L during the SALP period. A per-formance rating of Category 2 has been assigned by the NRR SALP evaluation effort for the current licensing period.

Please review the draft assessment and provide any comments you feel are appro-priate. All comments received by July 17 will be considered for incorporation in the final report. Due to the short time available for comment, please pro-vide your comments directly to the Brunswick Project Manager, Ernie Sylvester, at XZ1952.

l The NRC SALP Board meeting for Brunswick is sched led for August 19, 1987.

Ernest D.

vester, Project Manager Project Directorate 11-1 Division of Reactor Projects I/II

Enclosure:

Draft NRR SALP Report LA:PD21:DRPR PM:PD21:DRPR D f 2 jd'RPR PAnderson ESylvester/dsf EAdeJ(sam D

7/ /87 7/t /87 7/ p'87 8707160195 870710 PDR ADOCK 05000324 P

PDR 1

j

v 1

f[

f

. UNITED STATES g.

g NUCLEAR REGULATORY COMMISSION re '

Ij WASHINGTON, D. C. 20655 JUL 101997.

I MEMORANDUM'FOR:

Steven A. Varga, Director Division of Reactor Projects I/II i

1 Lawrence C. Shao, Director'

)

Division of Engineering j

and Systems Technology 1

i Charles E. Rossi, Director Division of Operational Events Assessment Frank J. Congel, Director Division of Radiation. Protection and Emergency Preparedness O

~

Jack W. Roe, Director-Division of Licensee Performance and Quality Evaluation.

James G..Partlow, Director Division of Reactor Inspection and Safeguards THRU:

Elinor G. Adensam. Directo j

Project Directorate II-1

)

Division of Reactor Projects I/II I

FROM:

Ernest D. Sylvester, Project Manager Project Directorate 11-1 Division of Reactor Projects I/11

.i Enclosed is a draft of NRR's SALP input for Brunswick Steam Electric Plant.

I Units 1 and 2 covering Carolina Power & Light Com)any (CP&L) licensing activ-ities for the period from November 1, 1985 througi June 30, 1987. The report is based on inputs provided by NRR reviewers and observations by NRR' project management during their interactions with CP&L during the SALP period. -A per-formance rating of Category 2 has been assigned by.the NRR SALP evaluation effort for the current licensing period.

Please review the draft assessment and provide any comments you feel are appro-priate.

All comments received by July 17 will be considered for incorporation in the final report. Due to the short time available'for comment, please pro-l vide your comments directly to the Brunswick Project Manager Ernie Sylvester, i

at X24952.

The NRC SALP Board meeting for Brunswick is scheduled for August 19,L1987.

Q Ernest D. Sylvester, Project. Manager Project Directorate 11-1 Division of Reactor Projects I/II'

Enclosure:

Draft NRR SALP Report

l OFFICE OF NUCLEAR REACTOR REGULATION INPUT FOR SALP REPORT CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 l

i 1.

Licensing Activities (November 1, 1985 to June 30,1987)

The basis for this appraisal was the licensee's performance in support of licensing actions (amendment requests, responses to generic letters and other actions) which have been reviewed and evaluated by the staff during the rating period. The subjects involve include the following:

Generic Reviews Appendix R to 10 CFR 50 Hydrogen Recombiner, Generic 1.etter 84-09 Diesel Generator Reliability, Generic Letter 84-15 Mark I Drywell Vacuum Breakers, Generic Letter 83-08 Breaks in BWR Scram Systems IGSCC Inspection Programs, Generic Letter 84-11 Plant-Specific Reviews Visual Weld Acceptance Criteria l

Core Spray System Amendment Control Rod Block Instrumentation Amendment RCIC Steam Line Isolation Time Amendment Chlorine Detection System l

Appendix J Exemption Hydrogen Water Chemistry Preimplementation Test i

Core Reloads The licensee's management demonstrated active participation in licensing activities and kept abreast of current and anticipated licensing actions.

Management control and oversight of licensing activities was generally i

satisfactory. The licensee's management has adopted a computerized i

scheduling system that provides management excellent control over the scheduling and prioritization of licensing' activities initiated by the NRC staff.

This awareness of scheduling control is evident in the bi-monthly licensing action review meetings held with the NRC staff. Conse-quently, commitments to NRC requirements and responses to requests for information are usually implemented on time, and when conditions preclude prompt implementation or response, a justification for the delay is provided.

l The licensee's management is committed to a program to clarify and simplify the Brunswick facility Technical Specifications to minimize oper-1 ator error and increase equipment reliability.

However, a weakness has 1

been noted in the coordination between on-site management and licensing management with regard to translating the schedular needs of the plant l

1 into a schedule for resolution of the associated licensing activity.

In addition, the licensing management has not consistently assured that the evaluations provided in accordance with 10 CFR 50.91 are adequate to clearly justify the no significant hazards considerations determinations accompanying amendment requests.

The licensee's management and staff generally demonstrated sound techni-cal understanding of issues involving licensing actions. The licensee has developed on-site expertise to approach licensing actions from a pro-bablistic risk assessment (PRA) perspective in an attem?t to increase margins of safety in the functioning of plant systems. The plant-initi-ated PRA studies have identified deficiencies in the design of a safety-related ventilation system and prompted further licensee studies to up grade the system. While the licensee brings considerable technical exper-tise to bear in resolving NRC staff concerns, some of the' licensee sub-mittals lack the necessary information for review by the NRC. That is, while the licensee staff usually shows a good understanding of the tech-nical issues and applies a conservative approach to their resolution, the technical arguments used to justify the licensee's position are frequently not communicated in a thorough and clear manner.

The licensee keeps abreast of industry approaches to the resolution of generic plant safety issues and demonstrates an awareness of programs at other facilities. This has been accomplished through membership in all major utility advisory and owners' groups.

Licensee management has been represented in leadership positions in many of these groups. The licensee has taken the initiative in the resolution of many multiplant safety issues. Where appropriate, the licensee either adopts methods of resolution promulgated by industry-supported groups, or proposes alter-nate methods of resolution. Where a plant-specific alternate method of compliance has been proposed, the licensee has occasionally not provided thorough technical arguments to justify the alternate approach, as indi-cated, for example, by the difficulties involved in the resolution of the hydrogen recombiner issue.

The licensee was generally responsive to NRC initiatives as evidenced by programs for improvement of the facility Technical Specifications and the use of probabilistic risk assessment to improve safety at the Brunswick facility. The use of hydrogen water chemistry was tested by.the licensee in response to the NRC program to reduce intergranular stress corrosion cracking at boiling water reactor facilities. The licensee has demon-strated a readiness to support NRC review of licensing issues by pro-viding additional information on an expedited basis. The licensee has developed an integrated schedule (long-range plan) to assure that plant modifications required by NRC regulations are implemented on a high-pri-ority basis, and that other modifications to improve safety are scheduled appropriately.

In general, the licensee works expeditiously to resolve safety issues in a timely manner.

The size of the licensing staff is more than adequate to support licensing activities. The licensee has assigned a principal engineer to supervise Brunswick licensing activities and continues to provide a licensing staff

)

l member at the site. The creation of an onsite licensing engineer position l

has not eliminated concerns related to coordination of site licensing requirements with corporate office licensing activities. And, while the-licensing staff displays a wide knowledge in various technical disci-l plines, a weakness is evident in the training provided to the licensing staff relative to an understanding of the regulatory process, particularly with regard to the application of the standards in 10 CFR 50.92 for the determination of no significant hazards considerations in amendment 1

requests.

i With regard to the reporting of operational events, less direct information is available for an NRR evaluation than for the other criteria discussed above. However, it has been observed that the Licensee Event Report (LER) program at Brunswick is at least adequate. With few exceptions, l

LER submittals are made on a timely basis and contain detailed information i

on the event description and event evaluation.

No basis exists for an NRR evaluation of the criterion related to enforce-ment h.istory in the functional area of licensing activities.

2.

Conclusion and Recommendations An overall performance rating of Category 2 has been assigned by the NRR l

SALP evaluation effort for the current rating period in the functional area of licensing activities. No definite trend in performance has been apparent over the rating period in this functional area. NRR recommends that the CP&L licensing staff be offered training in the regulatory process and safety issues commensurate with that already available in the areas of plant technology and operations.

3.

Other Functional Areas In the NRR review of LER, a significant number of events has been caused by maintenance activities in which personnel errors and procedural deficiencies have caused undesirable transients and equipment malfunc-tions.

However, during an NRR maintenance survey conducted on-site in January 1986, no significant problems were found in the Brunswick main-tenance program.

In the functional area of plant operations, NRR staff members have found the plant to be in good order with respect to clean-liness and housekeeping during site visits.

No basis exists for an NRR evaluation in other functional areas.

I

\\

l l

RECORD OF MEETINGS AND OFFICIAL DOCUMENTS l

1.

NRR/ Licensee Meetings Licensing Activity Review - Raleigh 12/4/85 Hydrogen Recombiner/ Integrated Schedule - Bethesda 1/14/86 Licensing Activity Review - Raleigh 1/16/86 Licensing Activity Review-Bethesda 2/26/86 Unit 2 Reload - Bethesda 3/18/86 Licensing Management - Bethesda 3/19/86 Licensing Counterpart Seminar - Bethesda 4/10/86 Licensing Activity Review - Bethesda 4/22/86 l

Licensing Activity Review - Bethesda 5/20/86 Licensing Activity Review - Bethesda 7/15/86 Unit 2 IGSCC Program - Bethesda 7/16/86 Licensing Activity Review - Bethesda 9/19/86 Fire Barrier Penetration Seals - Bethesda 10/15/86 i

IGSCC Repair (Pipelocks) - Bethesda 11/3/86 Licensing Activity Review - Bethesda 2/4/87 Hydrogen Recombiner - Bethesda 3/18/87 I

Licensing Activity Review - Bethesda 4/16/87 Licensing Management - Bethesda 5/7/87 Licensing Management - Bethesda 6/4/87 2.

NRR Site Visits Licensing / Plant Status Review 12/5/85 Maintenance Survey 1/13-17/86 Unescorted Access Certification /Long Range Plan 11/19-20/86 Licensing / Plant Status Review 6/15-16/86 3.

Comission Briefing None 4.

Schedular Extensions Granted None 5.

Reliefs Granted ISI Relief - Class I Valves 12/19/85 l

6.

Orders Issued

]

i Denial of Equipment Qualification Schedular Extension-11/15/85 i

1

7. -

Exemptions Granted Exemptions from Sections III.G and J of Appendix R 12/30/85

)

Exemptions from certain requirements of Appendix J 5/12/87 8.

Emergency Technical Specification Changes

.l Unit 2 RCIC Valve Operation Time 6/10/86 I

l 9.

License Amendments Issued Unit 1 - 17 issued Amendment 93 to 109)

Unit 2 - 19 issued Amendment 118 to 136) l l

l l

l l

6 i