ML20044C166
| ML20044C166 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/12/1993 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| EA-92-075, EA-92-75, NLS-93-075, NLS-93-75, NUDOCS 9303180226 | |
| Download: ML20044C166 (6) | |
Text
.'
CD&L Carolina Power & Light Company P. O. Bon 1551 + Ra6eigh. N. C. 27602 I
March 12, 1993 R. A. WATSON SERIAL: NLS-93-075 Senor Vice Presusent Nuclear Generation Mr. James Lieberman Director, Office of Enforcement United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 REPLY TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (EA 92-075) l Mr. Lieberman:
On February 10,1993, the Nuclear Regulatory Commission issued Notice of Violation (EA 92-075) for the Brunswick Steam Electric Plant, Units 1 and 2. Details of the underlying NRC inspections are provided in inspection Report Nos. 50-325/92-10 and 50-324/92-10 dated April 29,1992.
Carolina Power & Light Company (CP&L) hereby responds to the Notice of Violation. Enclosure 1 to this letter provides CP&L's reply to the Notice of Violation in accordance with the provisions of 10 CFR 2.201. Also enclosed is a check payable to the Treasurer of the United States in the amount of Two Hundred Twenty Five Thousand Dollars ($225,000.00).
Please refer any questions regarding this submittal to Mr. R. C. Godley at (919) 457-2412.
Yours very truly, bi f./
R. A. Watson GMT/gmt (nts93075.wpf)
Enclosures l
cc:
Mr. S. D. Ebneter Mr. P. D. Milano Mr. R. L. Prevatte R. A. Watson, having been first duty sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light "Y'
l Qg?
?
v My commission expires:
,2p g
pf,pn I
PDR j
,,,, N CD
ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62 REPLY TO NOTICE OF VIOLATION VIOLATION:
During an NRC inspection conducted on March 30 - April 10,1992, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (57 FR 5791, February 18,1992), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),42 U.S.C. 2282, and 10 CFR 2.205. The particular violation and associated civil penalty are set forth below:
l 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requirec that measures be l
established to assure that conditions adverse to quality such as failures, malfunctions, l
deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective I
action taken to preclude repetition. The identification of the significant condition and the corrective action taken shall be documented and reported to the appropriate levels of management.
i Contrary to the above, the licensee failed to adequately establish or implement measures to l
promptly identify and correct deficiencies with emergency diesel generator room masonry walls, a significant condition adverse to quality. Specifically, on February 13,1987,a licensee engineer identified and documented in a memorandum that certain bolts installed to seismically qualify emergency generator room masonry walls were inadequately installed.
Measures undertaken to fully identify and correct the deficiencies with the walls were inadequate. The failure to take adequate corrective actions, and hence the violation, continued until April 1992 when, after quest oning by NRC inspectors, the licensee i
determined that widespread deficiencies existed resulting in the shutdown of both units on April 21,1992.
This is a Severity Level 111 violation (Supplement 1).
Civil Penalty - $225,000 l
RESPONSE TO VIOLATION:
A.
Admission of Violation:
l Carolina Power & Light Company admits this violation.
El-1
I l.
8.
Reason for Violation t
in February of 1987 Technical Support engineers documented potential problems with anchor bolts in the angle support pieces used for seismic qualification of the masonry block walls of the Emergency Diesel Generator (EDG) Building. The site Engineering Department was requested to evaluate the acceptability of the angle support bolting. The various methods by which the construction contractor had mis-installed the bolts were not known at that time, creating the impression that many more bolts were properly installed than actually were. By April of 1988 a second request was initiated for an appropriate scope of inspection. This request was not acted on and in Septemoer of 1989 the request was resubmitted to the Engineering Department. Early in 1990, in an effort to establish the as-built condition of the bolts, a feeler gauge inspection was conducted. This inspection was later discovered to be inadequate in that several methods of bolt mis-installation are not detectable using feeler gauDes. This resulted in the number of defective bolts again appearing more limited than the findings of the more comprehensive inspection performed in 1992. The engineering evaluation and calculations completed in December of 1990 that l
found the conditions to be acceptable were based on what is now known to be non-conservative field inspection data. This erroneously allowed the walls to be considered short-term qualified and repair / redesign recommendations to restore long-term acceptability were prepared. The design was issued in April of 1991, but resolution of field construction l
concerns delayed the reissue until February of 1992.
i 1
in April of 1992 the NRC challenged the validity of the inspections underlying the calculations used to determine the adequacy of the bolts. The calculations had assumed that the bolts which passed the feeler gauge inspections were validly installed, but this was not adequately field verified. This concern prompted a comprehensive inspection of EDG Building masonry block wall botting and revealed wide-spread instances where the wall i
supports had not been installed per the design drawings. Ultimately, the broadening scope of mis-installed bolts led CP&L to declare the Emergency Electrical Distribution System inoperable and led to the shutdown of both Units. As a result, CP&L embarked upon a i
series of inspections and corrective actions, many of which were discussed with the NRC i
I through presentations, the enforcement conference, and written transmittals.
CP&L recognizes that the construction deficiency and significance determination were not resolved in an effective and timely manner. The failure to correctly understand the significance of the botting issue and take timely appropriate corrective action was caused i
by the inadequate interface between Technical Support and Design Engineering, and an ineffective line-driven corrective action program. Aggravating this was the lack of l
l standards for an acceptable time limit for degraded structural conditions and the perception that resource limitations restricted the scope of the effort. Ultimately, CP&L did not recognize and address the full scope of deficient botting and its potential impact until April 1992.
in addition to the specific reasons underlying this violation, broader issues exist, which have been described to the NRC separately in other communications over the last year. These broader issues are being addressed systematically through CP&L's Corporate improvement initiatives, submitted to the NRC on November 30,1992, and the Brunswick Three-Year Plan (1993-1995), which was submitted on December 15,1992. Some particularly
(
relevant provisions are discussed in section D, below, i
l l
E1-2
l i
1 I
1 C.
Corrective Actions. Steos Taken. and Results Achieved Brunswick Technical Support now communicates with Design Engineering using Engineering Work Requests (EWRs) instead of the less formal written memoranda that were in use when the botting deficiencies were identified. Engineering Procedure (ENP) 20, which documents the use of EWRs, requires more levels of review and approval, greater management oversight, and they are tracked using various performance indicators including age.
Brunswick's current Corrective Action Program (PLP-04) was not in place during the early phases of this event. This program now provides the means of identifying adverse conditions, assigning clear responsibility for resolution, and tracking corrective action until completion. Brunswick has continued to strengthen the current program and has included several initiatives under the Brunswick Three-Year Plan.
Changes have been made to the Engineering Evaluation Procedure (ENP-12) to emphasize the need to verify thoroughly as-built records and field inspections including the functional attributes prior to making an operability assessment. Changes were made to the Design Guides for Civil / Structural Operability Reviews (DG-II.20) and Brunswick Nuclear Project Structural Scope Documents for Various Verification Programs (DG-ill.16), stressing the importance of comprehensive field inspections to ensure acceptability of relevant civil functional attributes required for qualification of equipment.
In part due to the concealed nature of these bolt deficiencies, CP&L has conducted a comprehensive design review, inspection (100%), and repair program related to masonry block walls in Class 1 structures ir.cluding the reinforced concrete panel walls in the Emergency Diesel Generator Building. This included an evaluation of the safety function and seismic integrity of the walls and a review, inspection, and evaluation of drilled-in anchor bolts. CP&L restored the walls to the original design margin as established by the IE Bulletin.80-11 program.
Management is providing the leadership, oversight, resources, and support necessary to achieve sustained performance improvement for the plant. For example, CP&L has taken short term staffing actions during the course of the unit outages to address structural issues and concerns including the implementation of the wal', design review, inspection and repair program. The result was a peak staffing level in the structural engineering area of approximately 400 personnel. Long-term improvements will result from integrating the budget process with the projects and initiatives established by the Brunswick Three-Year Plan.
In order to assure timely correcti_ n of degraded structural items, CP&L has incorporated the guidance provided in Generic Letter 91-18 into DG-il.20. Short-term Structural issues will be restored to full design requirements prior to restart from future refueling outages, given availability of design and materials. Exceptions will be minimal, and justified on an individual basis.
El-3
D.
Corrective Actions That Will be Taken to Avoid Future Violations CP&L is committed to substantially improve its nuclear operations, with a goal of *world class
- performance at all three of its nuclear stations. Senior nuclear utility managers with extensive nuclear experience have joined CP&L and are providing the direct leadership for this program of improvement and sustained excellence.
The CP&L Corporate improvement initiatives are designed to contribute to the improvement in performance and safety of CP&L's nuclear plants. These initiatives include definitive steps to achieve higher levels of safety awareness and performance and to set and meet standards that will lead to superior performance.
Also, the Brunswick Three-Year Plan contains numerous initiatives and projects that will i
help prevent future violations. The most relevant Three-Year Plan projects and initiatives are described below.
Of primary interest among these is initiative TY303, " improve Ability to identify and Correct Problems." Undet this initiative, Brunswick is developing and implementing a self-assessment program that causes Brunswick nanagers and staff to critically evaluate the adequacy of plant processes and products. The plant will develop and implement a root cause analysis process strengthened by improved training, line organization involvement, increased management oversight, and integration of information from the Operations Experience Feedback program. Under this initiative, Brunswick will improve training, develop and implement effective subprograms, and effectively track and trend results.
Other Three-Year Plan initiatives that should assist in improving corrective action include the following:
Under Initiative TY102, "BNP Integrated Scheduling and Three-Year Plan Administration,"
projects will be worked according to their assigned priorities, with a standardized ranking system under which r'uclear safety is the most heavily-weighted attribute. This initiative is underway.
Initiative TY506, " Plant Engineering Program Upgrade," will improve plant engineering capabilities to meet the intent of INPO Good Practice TS-413 on use of system engineers.
Under this initiativa, CP&L will provide the technical resources, equipment analysis I
methodology, and tools to upgrade the plant engineering program. Drunswick will establish and maintain quailty component engineering programs, incorporating key elements of j
successful plant engineering programs at other nuclear facilities, j
Initiative TY302, *lmproving the Modification Process," will both implement interim guidance to permit short-term gains in fixing problems needing design work, while simultaneously investigating and implementing long-term improvemente 10 the modification process that will substantially reduce modification cost and the time between modification concept and operability.
l initiative TY509, " Management of Temporary Cc,nditions and Substandard Condidons," will l
improve the processes for control and management o' temporary conditions, reperit failures, l
obsolete equipment, and short-term structural integrity items. Under this initiative, the E1-4 i
t plant will define temporary and substandard conditions, implement controls, and establish targets for resolving each item controlled by this program.
l r
Initiative TY104, " Business Planning improvements," will improve Brunswick's ability to j
apply resources effectively to projects that will provide the greatest returns relative to site goals and objectives. The new business planning process will clearly identify the goals and objectives of the plant, facilitating scheduling projects that support Brunswick's desired l'
direction and will ascist management in making objective decisions on the planned application of resources.
A final initiative that merits mention is initiative TY204, " Management Effectiveness."
l Work is under way to help nurture a plant culture where nuclear safety is of highest priority and where continuous improvement is a way of life.
l l
E.
Date of Full Comoliance
{
CP&L now complies with 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action,"
l j
as described herein.
l l
i I
d i.
El-5
_.. ~.... _,. -
... ~ -
-