BSEP-84-0887, Suppls Response to NRC Re Violations Noted in IE Insp Repts 50-324/83-11 & 50-325/83-11.Corrective Actions: Programmatic Upgrades Incorporated Into Comprehensive Fire Protection Program.Synopsis Encl

Suppls Response to NRC Re Violations Noted in IE Insp Repts 50-324/83-11 & 50-325/83-11.Corrective Actions: Programmatic Upgrades Incorporated Into Comprehensive Fire Protection Program.Synopsis Encl

ML20083L813
Person / Time
Site:	Brunswick
Issue date:	03/30/1984
From:	Howe P CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20083L799	List: BSEP-84-0887, Suppls Response to NRC Re Violations Noted in IE Insp Repts 50-324/83-11 & 50-325/83-11.Corrective Actions: Programmatic Upgrades Incorporated Into Comprehensive Fire Protection Program.Synopsis Encl
References
BSEP-84-0887, BSEP-84-887, NUDOCS 8404170371
Download: ML20083L813 (5)

Text

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$ ru Brunswick Steam Electric Plant P. O. Box 10429 Southport, NC 28461-0429 March 30, 1984 FILE: B09-13510C SERIAL: BSEP/84-0887 Mr. James P. O'Reilly, Administrator U. S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street N.W.

Atlanta, GA 30303 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENTAL RESPONSE TO IE INSPECTION REPORT 83-11

Dear Mr. O'Reilly:

In our letter of February 9, 1984, Serial No. NLS-84-058, Carolina Power &

Light Company stated that an assessment of the Fire Protection Program was being performed and that appropriate programmatic upgrades would be incorporated. These upgrades heve been incorporated into a comprehensive program, a synopsis of which is enclosed for your information. CP&L will periodically provide updates of this program reflecting status and any programmatic or scheduler changes.

Should you require any additional information, please contact a member of my staff.

Very truly yours, C3 P. W. Howe, Vice President Brunswick Nuclear Project TEC/mcg/MSCDR1 Enclosures cc: Mr. R. C. DeYoung NRC Document Control Desk S404170371 e4043o pDR ADOCK 05000324 G

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ENCLOSURE 1 This enclosure describes the plan and schedule for preparing a comprehensive Fire Protection Program for Brunswick. The task can be broken down into five phases:

1. Performing a needs analysis.

2. Developing a set of specifications.

3. Writing the procedures.

4. Fire brigade organization. ,

5. Fire brigade training.

KEEDS ANALYSIS The needs analysis phase involves gathering the commitment documents which impact Brunswick's Fire Protection Program. These would include, but would not be limited to, NUREG 0800; SRP 9.5.1; BTP APCSB 9.5-1 (including Appendix A); 10CFR50 Appendix A and B; 10CFR50.48; Appendix R; Regulatory Guides 1.39, 1.78, 1.101, 1.120; the FSAR; NFPA 4, 4A, 6, 7, 8, 27, and others; commitments made to the NRC; QA audit findings and the Corporate QA Manual; and NRC findings and problems identified at other nuclear plants.

The analysis is an important function in that it must ensure that the program will satisfy all regulatory requirements.

SPECIFICATIONS AND PROGRAM DEFINITION This phase will begin once the needs analysis is complete. Preparation of the specifications is important because it is here that the Brunswick Fire Protec-tion Program will be defined. Specifications will then be generated for each procedure. These specifications will include the procedure's format, purpose, pertinent commitments, codes, regulations, and will indicate whet the procedure will do. Appropriate management review of the specifications will be complete prior to procedural development.

The set of specifications produced will be compared to ensure logical groupings of content, function, purpose, and quantity. This final action will result in a set of procedures which are comprehensive, cohesive, and integrated.

PROCEDURES The procedure writing phase will be straightforward. Using the procedure specifications, referenced codes, regulations, standards, commitments, exist-ing procedures, and drawings, the writer will develop the procedure using any additional assistance required. The procedure will be independently reviewed and then approved by appropriate management as required by regulations and plant procedures.

Procedures will be generated to replace the existing fire protection (FP) procedures, fire instructions (FI) including fire plans, and periodic tests which are performed as part of the Fire Protection Program.

Training of shift personnel and Fire Protection staff members will be conducted on these procedures prior to their implementation. Following this training, the procedures will be impicmented.

FIRE BRIGADE ORGANIZATION A new Fire Brigade organization will be implemented to enhance the brigade's fulfilling of regulatory requirements, fire fighting, and fire prevention at BSEP. The new organization will be implemented over the next 18 months in three phases to assure a smooth transition from the current organization.

The final organization will consist of six shifts of fully dedicated Fire Brigade personnel, supported by an administrative, technical, and supervisory staff during day shifts. The shift Fire Brigade personnel will perform fire protection-oriented tasks, such as pts, fire inspections, fire watch super-vision, and fire equipment checks. Their number will be a function of the normal work load which they will be expected to carry, with a planned minimum of five on each shift in accordance with regulations. It is expected that additional personnel will be required for each shift to perform the required tasks and to maintain continued training. Those which are not utilized for fire protection work activities will be utilized as A0s.

The Fire Brigade organization will be led by the Fire Support Supervisor who will fulfill the requirements for a Fire Chief. Reporting to him will be a Fire Support Specialist, Administrative Specialist, Drill Coordinator, Records Specialist, clerk, and six Shift Fire Supervisors. Firc Brigade members on each shift will report to the Shift Fire Supervisor.

Each operational shift will also have a licensed individual who is fully qualified and trained in fire protection and fire fighting. This person will act as the Fire Commander during a fire. The Fire Commander will be dispatched to the scene of the fire and will report to the Shift Foreman. The Fire Commander directs the fire fighting at the scene with the Shift Fire Super-visor reporting to him. The Shift Fire Supervisor is trained to direct the fire fighting if the Fire Commander is disabled or called to a second fire.

FIRE BRIGADE TRAINING ,

The Fire Brigade training responsibility will be shifted from Operations to the Training Unit. Drills,' practice fire fighting, and real-time training will remain under Operations' control.

The training goals will be to have a Fire Brigade fully trained to deal with fire situations that could reasonably exist and to qualify each Fire Brigade member as an AO. Qualified Fire Protection group personnel will be given A0 training in regularly scheduled A0 classes.

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e a A comprehensive program is being developed to provide additional training for the Fire Brigade personnel. This training is anticipated to include:

1. Fire Academy Training

2. Fire Brigade Training

3. Fire Inspection

4. Fire Protection Procedures

5. Fire Protection Periodic Testing 1 6. Fire Protection Equipment Checks It is also anticipated that the Fire Support Supervisor, Shift Fire Supervisors, and the Fire Commanders receive the above training, plus the following:

1. Regulations and Specifications i

i 2. Fire Chief's Course

3. Supervision Course i

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4. Fire Rescue .

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5. EMT (Emergency Medical Technician) 1 Each Shift Foreman will receive the following training:

1. Fire Brigade Training

2. 24-Hour Academy Training

, A training schedule has been developed and the above training should be accomplished without disruption to the current fire protection responsibilities. Training will be tailored to accommodate a time phased approach to development of the organization.

SCHEDULE A comprehensive schedule has been developed to provide an effective management tool for implementation. This schedule currently calls for individual project start dates ranging from March through June 1984 and a final total completion date of December 1985. The extensive training program is tha primary reason for this extended time period. In addition, various projects cannot be started until prerequisite projects are completed (i.e., the needs analysis must be completed prior to specification development). Due to possible program changes and the availability of outside resources (i.e., Fire Academy), this schedule may change. These changes will be updated in the periodic reports.

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CLOSING COMMENTS The Brunswick station has developed and is implementing what it considers a very comprehensive Fire Protection Program. Many aspects of this program are included in this letter. In addition to those actions identified in this letter, which fall mainly under the auspices of the Operations Subunit and the Training Unit, an engineering program is also in effect. This program not only includes the requirements of Appendix R, but also incorporates many improvements and upgrades to the operation of the Fire Protection System at Brunswick. Should you so desire, CP&L would enjoy the opportunity to present its fire protection upgrade program to you or members of your staff.

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CD&L Carolina Power & Light Company SERIAL: NLS-84-058 FEB 001984 Mr. Richard C. DeYoung, Director Of fice of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 RESPONSE TO NOTICE OF VIOLATION

Dear Mr. DeYoung:

Carolina Power & Light Company (CP&L) has received the letter f rom Mr. James P. O'Reilly dated January 10, 1984 transmitting a Notice of Violation and Proposed Imposition of Civil Penalty (EA 83-88). Ca rolina Power & Light Company has also received Inspection Reports 50-324/83-11 and 50-325/83-11 for the Brunswick Steam Electric Plant, Unit Nos. I and 2. Th e above referenced Inspection Reports do not contain any information of a proprietary nature.

Pursuant to 10 CFR 2.205, CP&L hereby encloses its check in the amount of forty-thousand dollars ($40,000) payable to the Treasurer of the United States, in payment of the proposed civil penalty. As required by 10 CFR 2.201, CP&L's response to the Notice of Violation issued with the Proposed Imposition of Civil Penalty is enclosed.

Should you need any additional information, please contact our Licensing Staff.

Yours very t ruly, M. A. McDuffie Senior Vice President Nucicar Generation WRM/ccc (9453WRM)

En closures c c: Mr. M. Grotenhuis (NRC) MCUM ORICI M Mr. J. P. O'Reilly (NRC-RII)

Mr. D. B. Vassallo (NRC) Cort 1tici Dy

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_ c1 LN M. A. McDuf fie, having been first duly sworn, did depose add say that the information contained herein is true and correct to the best of his infornation, knowledge and belief; and the sources of his information are - ,,,

officers, employees, contractors, and agents of Carolina Power & Lighf. . '.

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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 INSPECTION REPORTS 50-324/83-11 AND 50-325/83-11 RESPONSE TO NOTICE OF VIOLATION Inspection Reports 50-324/83-11 and 50-325/83-11 and the January 10, 1984 Notice of Violation (EA 83-88) identified six items that were in non-compliance with NRC requirements. These items and Carolina Power & Light Company's response to each are addressed in the following text:

VIOLATION A (SEVERITY LEVEL III):

In a response dated May 24, 1982, describing corrective action taken with respect to a Notice of Violation dated April 2, 1982, the licensee stated that Tables I and IA of Volume XI of the licensee's Plant Operating Manual had been revised to assure that all Q-list equipment was correctly identified on both tables. These tables are used by licensee personnel as a reference to determine if a plant instrument is a Q-item (i.e., safety-related).

Contrary to the above, on May 24, 1982, and as of November 1982, numerous discrepancies existed between Tables I and IA of Volume XI of the licensee's Plant Operating Manual, and consequently the tables did not correctly identify all Q-list equipment. For example, Table IA did not identify pressure switches as Q-list equipment while Table I did. Thus, the licensee's response to the NRC of May 24, 1982, contained a material false statement within the meaning of Section 186 of the Atomic Energy Act of 1954, as amended. The licensee's statement was false in that Tables I and IA did not correctly identify all Q-list equipment. The statement is material f or the NRC would have taken further regulatory action to correct the tables had it known they were incorrect.

l i CAROLINA POWER & LIGHT COMPANY'S RESPONSE:

1. Admission or Denial of Violation l

Carolina Power & Light Company acknowledges that the identificatioa of corrective actions set forth in CP&L's response to IE Inspection Report

! 50-324(325)/82-10, Violation D, was not accurate, due to an unintentional

! error, in that Tables I and IA of the Plant Operating Manual, Volume XI (Q-list), were not consistent.

2. Reason for Violation l

This event occurred due to the lack of clear definition of the scope of the Q-list upgrade project and to inadequate direction to all site subunits responsible for input.

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3. Corrective Steps Taken and Results Achieved ,

a. The Q-list has been thoroughly reviewed for inconsistencies and corrected where applicable.

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b. The Q-list has been reformatted to minimize the potential for inconsistencies.

c. The Q-list has been made unit specific to prevent errors due to the differences in equipment.

d. Enhanced procedural controls have been implemented to maintain the list up-to-date.

e. A Project Engineer has been assigned to the Q-list to oversee future improvements.

f. Plant procedures have been developed which provide more rigid controls for accuracy of data submitted to the NRC. These controls include statement verifications and additional management reviews prior to submittal.

4. Corrective Steps to be Taken

< No additional corrective actions are planned for this event.

5. Date Full Compliance will be Achieved Full compliance f or this event has been achieved.

VIOLATION B (SEVERITY LEVEL IV):

Technical Specification 3.7.8 for Brunswick, Unit Nos. 1 and 2, requires that all fire barrier penetrations, fire doors, and dampers, in fire zone boundaries protecting safety-related areas shall be functional. Te chnical Specification 3.7.8 Action Statement "a" requires that, with one or more of the fire barrier penetrations non-functional, within one hour a continuous fire watch must be established on at least one side of the affected penetration or verify the operability of fire detectors on at least one side of the non-functional fire barrier and establish an hourly fire watch patrol.

Contrary to the above, during the period of February 13 to April 5,1983, fire barrier penetrations protecting safety-related areas in Unit Nos. 1 and 2 were nonfunctional and the associated fire detectors were inoperable without continuous fire watch.

CAROLINA POWER & LIGilT COMPANY'S RESPONSE:

1. Admission or Denial of Violation Carolina Power & Light Company acknowledges that it f ailed to establish continuous fire watches as noted in the violation. This violation was identified by CP&L during an internal review of the Fire Protection Program.

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2. Reasons f or the Violation Die Operations Shif t Foreman made an erroneous determination that hourly versus continuous fire watches were to be maintained in the A0G Building when the area fire detectors were declared inoperable by considering only Technical Specification 3.3.5.7, which addresses detector operability.

Hourly fire watches had previously been established in accordance with Technical Specification 3.7.8 due to inoperable fire barriers in the A0G Building. When the fire detectors became inoperable, the Shif t Foreman failed to realize that Tech tical Specification 3.7.8 required continuous versus hourly fire watches since Technical Specification 3.3.5.7 did not provide any reference to other restrictions involving the operability of fire detectors.

3. Corrective Steps Taken and Results Achieved

a. The use of hourly fire watches has currently been discontinued and replaced by the establishment of a continuous roving fire watch in cases where fire detector or fire barrier operability is concerned.

This fire watch, when required, is maintained in the affected area.

b. Training modules f or the Fire Support group have been implemented and completed, emphasizing an increased understanding of Fire Protection systems. Additional training has been conducted on the interrelations of systems within Technical Specifications.

4. Corrective Steps to be Taken No additional corrective action f or this event is planned or anticipated. Corrective measures already implemented have resulted in satisfactory procedural controls for handling Fire Protection related LCOs to avoid future occurrences of this nature.

5. Date Full Compliance will be Achieved Full compliance for this event has been achieved.

VIOLATION C (SEVERITY LEVEL IV):

Technical Specification 6.8.1.f for Unit Nos. I and 2 requires that written procedures shall be established, implemented, and maintained covering Fire Protection Program implementation.

Contrary to the above, procedures covering the Fire Protection Program f or Unit Nos. I and 2 were not adequately implemented as demonstrated by the following examples:

a. Fire Protection Surveillance Procedure, PT-35.7, was inadequately implemented on February 12, 20, 26, and March 7,1983, in that the position of valve WW-V207 was not properly identified. The valve was shut. The position was recorded as being locked open.

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b. Fire Protection Surveillance Procedure, PT-35.1, was inadequately implemented on February 14, 21, 28, and March 7, 1983, in that valve WW-V207 was not properly verified as locked open.

c. Fire Protection procedures PT-35.16 and PT-35.18 were not being adequately implemented in those surveillances to ensure the functional status of fire barrier penetrations were not being performed in accordance with the acceptance criteria specified in these tests.

CAROLINA POWER & LIGHT COMPANY'S RESPONSE:

1. Admission or Denial of Violation Carolina Power & Light Company acknowledges that it f ailed to adequately implement procedures covering the Fire Protection Program as stated in the violation. Two of the three examples were identified by CP&L during its investigation of the event.

2. Reasons f or the Violation

a. PT-35.7, which contains a step to check the position of valve WW-V207, did not require a hands-on verification of the valve position. In addition, the subject valve is remotely located in a dimly lighted pipe chase below floor level which led to an inaccurate determination of its position by visual verification alone. This example was reported by CP&L.

b. PT-35.1 includes a prerequisite to verify that the Fire Protection System is lined up per OP-41. Valve WW-V207 is contained in the OP-41 valve lineup procedure and was not in its required open position when PT-35.1 was conducted. No method existed for tracking exceptions to valve lineups, resulting in the f ailure to recognize that valve WW-V207 was out of position and under clearance.

c. PT-35.16 and PT-35.18 were improperly implemented as a result of insufficient training of the Fire Protection personnel assigned to perform the pts. The determination of fire barrier seal operability was incorrectly based on visual inspection and experience rather than on the acceptance criteria specified in the PT. This example was reported by CP&L.

3. Carrective Steps Taken and Results Achieved

a. PT-35.7 was revised on April 2, 1983, to require a hands-on-check of the associated fire protection valves. Fire Protection personnel who perform periodic testing have also been trained in the proper method to check valve position as specified in 01-13, Valve and Electrical Lineup Verification. As an interim measure until this training was completed, Fire Protection personnel who were assigned evolutions requiring valve position verification were required to be accompanied by Auxiliary Operators.

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b. A method for tracking exceptions to valve lineups has been incorporated into 01-13, requiring the use of a valve lineup exception form as documentation for the reason that a valve is not in its specified lineup position.

c. Fire Protection personnel have received training and were required to pass a written exam on Fire Protection related Technical Specifications. In addition, they have received training on Fire

Protection training modules. Real time training is conducted on a continuing basis to maintain their degree of understanding and knowledge pertaining to current plant Fire Protection concerns.

Verbatim compliance with approved procedures has also been emphasized as a direct result of this event.

4. Corrective Steps to be Taken No additional corrective action for these events is planned or

' anticipated. Satisfactory controls have been established to avoid future occurrences of this nature.

5. Date Full Compliance will be Achieved Full compliance f or these events has been achieved.

VIOLATION D (SEVERITY LEVEL IV):

Technical Specification 6.9.1.8 for Unit No. I requires the reporting within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirmation by telegraph, mailgram, or facsimile j transmission to the Director of the Regional Of fice or his designee no later than the first working day following operation of the unit or affected system when any parameter or operation subject to an LCO is less conservative than the least ' conservative aspect of the LCO established in the Technical >

Specification.

i Contrary to the above, the LCO violation described in the proposed civil '

penalty was a reportable event which was not reported to the NRC Region II within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

CAROLINA POWER & LIGHT COMPANY'S RESPONSE:

1. Admission or Denial of Violation Carolina Power & Light Company acknowledges that it f ailed to make the required prompt report when valve WW-V207 was found shut. This event was identified by CP&L on March 18, 1983.

I 2. Reasons for the Violation i The Shif t Foreman and Shif t .0perating Supervisor that were involved in

! identifying the need for an LCO due to the WW-V207 valve being found j closed f ailed to recognize that the conditions of the LCO had been

- exceeded, thus requiring a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> report to be made in accordance with Te chnical Specification 6.9.1.8.b. No investigative action was initiated -

at that time. A review of the LCO form by the Regulatory Compliance group (9453WRM/ccc)

r later in the day also f ailed to reveal the need for a prompt notification based on the information provided on the LCO form. Five days later the full scope of the occurrence was recognized and a prompt report was made.

3. Corrective Steps Taken and Results Achieved

a. A prompt report was made to the NRC Region II office on March 18, 1983.

b. Formal documented " live time" training was initiated on March 29, 1983, for appropriate operating shif t personnel covering details of this event, including event description, investigation results, corrective actions, safety considerations, and reportability evaluation.

4. Corrective Steps to be Taken No additional corrective action f or this event is planned or anticipated.

5. Date Full Compliance will be Achieved Full compliance for this event has been achieved.

VIOLATION E (SEVERITY LEVEL IV):

Te chnical Specification 6.9.2 f or Unit No. I requires a special report to be issued within 30 days af ter a fire barrier penetration has been inoperable for seven days.

Contrary to the above, in four instances, once on January 26, twice on February 19, and once on March 12, 1983, fire barrier penetrations were inoperable for more than seven days and the req.* ired special reports were not submitted.

CAROLINA POWER & LIGHT COMPANY'S RESPONSE:

1. Admission or Denial of Violation Carolina Power & Light Company acknowledges that it f ailed to make required special reports as required by Technical Specifications. This event was identified by CP&L during its review of the Fire Protection Program.

2. Reasons for the Viointion

a. At the time, there was no established system for the daily tracking -

of fire barrier seal LCOs. Consequently, whenever 'an LCO time frame was exceeded, there was no mechanism by which to notify plant Regulatory Compliance personnel that a 30 day special report'was required in accordance with Technical Specification 6.9.2.

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b. Plant procedures did not provide a mechanism for notifying the Regulatory Compliance group that a protection system had exceeded the allowable technical specification time and that a special report was required.

3. Corrective Steps Taken and Results Achieved

a. Plant Operating Instruction 01-04, which deals with the handling, tracking, and disposition of plant LCOs, was revised on April 8, 1983 to establish a positive tracking system for Fire Protection LCOs. In addition, it is now specifically outlined in the procedure which plant group is responsible f or notifying Regulatory Compliance of an exceeded LCO time frame and how to accomplish the notification.

b. Special training was given to members of the plant Fire Protection group to upgrade their knowledge of the LCO tracking and handling system with respect to Fire Protection LCOs as reflected in the recently revised 01-04.

c. The Senior Fire Protection System Specialist now maintains a daily running account of all active fire barrier seal LCOs. This ensures that those LCOs which have exceeded their specified time f rames are reported to Regulatory Compliance so that timely reporting to the Commission may be accomplished.

d. Plant management also reviews, on each working day, the status of active plant and Fire Protection System LCOs. This will help to ensure expeditious processing, correction, and cancellation of these LCOs.

4. Corrective Steps to be Taken to Avoid Further Violations No additional corrective actions for this event are planned or anticipated. Corrective measures already implemented have resulted in a satisfactory awareness of Operations and Fire Protection personnel to avoid future occurrences of this nature.

5. Date Full Compliance will be Achieved Full compliance has been achieved. * *-

VIOLATION (SEVERITY LEVEL III; CIVIL PENALTY S40,000):

Technical Specification 3.7.7.2 for Brunswick, Unit No. 1, requires that the Deluge System for the Standby Gas Treatment System (SBGTS) Trains IA and 18, be operable whenever the SBGTS System is required to be operable. Action Statement "a" of Technical Specification 3.7.7.2 requires that, with the Deluge System inoperable, a continuous fire watch with backup suppression equipment be established within one hour.

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-g-Contrary to the above, the Unit No. 1 Deluge System for the SBGTS Trains IA and IB was rendered inoperable when valve WW-V207 was shut during the period of February 11 to March 13, 1983, and a continuous fire watch was not established. During this time, the plant was in a condition which required the S BGTS to be operable.

CAROLINA POWER & LIGHT COMPANY'S RESPONSE:

1. Admission or Denial of the Alleged Violation Carolina Power & Light Company acknowledges that a continuous fire watch was not established when valve WW-V207 was isolated as required by Te chnical Specifications. This event was reported in LER l-83-15 on April 1, 1983.

2. Reasons for the Violation Af fected Deluge Systems were unknowingly isolated by closing valve WW-V207 while attempting to isolate Service Water System vital header inleakage.

Since it was not recognized that the Deluge Systems were isolated, no LCO was initiated.

The following items were identified as contributing f actors:

a. The plant Shif t Operating Supervisor (SOS) did not provide appropriate independent review and oversight and was too involved in the details of the actions being taken in association with generating the clearance.

b. The plant drawing aperture card, utilized when attempting to isolate the Service Water System vital header inleakage, was not easily interpretable.

c. Plant equipment clearance procedures did not provide for an overall plant systems impact consideration when additional clearance tags were placed on already existing equipment clearances.

3. Corrective Steps Taken and Results Achieved

a. An appropriate LCO and fire watch were established when the event was identified and maintained until valve WW-V207 was reopened on March 15,1983.

b. A complete internal operations audit of existing plant equipment clearances was conducted to ensure compliance with applicable LCOS.

This audit verified no LCOs were being violated.

c. The involved SOS was extensively counseled concerning this event and further disciplinary action was taken.

d. Informal on-shift counseling was conducted by the Manager - Plant Operations for shif t supervisory personnel concerning this event.

This informal counseling was begun immediately following the determination of the event.

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e. Formal, documented " live time" training was begun on March 29, 1983, for appropriate operating shift personnel covering details of this event, including event description, investigation results, corrective actions, safety considerations, and reportability evaluations.

f. The clearance procedure has been revised to require a complete review of the entire clearance when extending the boundary of an existing clearance.

g. Appropriate in-line valve handwheels in the Fire Protection System have been painted red for immediate identification as a Fire Protection valve.

h. Plant drawing aperture cards have been upgraded to allow easier interpretation of actual system layouts. This upgrade is continuing as an ongoing process.

The results of the immediate corrective actions taken corrected the violation and ensured that no similar conditions existed. Follow-u p corrective actions have improved operating practicca and operational administrative controls such that the possibility of reoccurence has been greatly reduced. '

4. Corrective Steps Taken to Avoid Further Violations No additional corrective actions f or this event are planned or anticipated.

5. Date Full Compliance will be Achieved Full compliance for this event has been achieved.

ADDITIONAL INFORHATION While Carolina Power & Light Company acknowledges that the Deluge Systems to the Unit No.1 SBGT Systems lA and IB were made inoperable from February 11 to March 13,1983, we would like to present several items which we believe reduce the safety significance of this event:

1. Although a fire watch was not specifically assigned to monitor the unprotected area, a radiation checkpoint station located between the SBGTs was continuously manned during this period.

2. A review of Shif t Foremen's log and LCOs indicate that the standpipe system and the fire dotection system in the area of the SBGTs were operable from February 11, 1983 to March 13, 1983 except for approximately one hour on March 10, 1983. Vie standpipe system was isolated f rom 10:45 a.m. to 11:40 a.m. to allow work on the system.

3. During the time of this event, Unit No. I was in Operational Condition 5 (Refuel) and the only equipment in the area required to be operable were the SBGTs. Ihving been in cold shutdown for two-to-three months prior to and during this event, the anticipated fission product heat loading would (9453WRM/ccc)

, 10 be greatly reduced f rom that of the design TID-14844 release. In any case, as a fire would make the SBGTs inoperable - so would activation of the Deluge System.

t BRUNSWICK IMPROVEMENT PROGRAM The notice of the proposed imposition of Civil Penalty also requested that

, CP&L include the changes we made, or plan to make, in the Brunswick Improvement Program (BIP) which address the programmatic problems in the Fire  !

, Protection Program. Cp6L does not plan to initiate changes to the BIP to separately address the Fire Protection Program. Since this event occurred

(approximately one year ago), many changes have been ef fected concerning Fire Protection - as addressed in the corrective actions to the enclosed '

violations. In addition, a Principal Engineer - Operations position has been  !

4 staf fed with specific management responsibility for the Fire Protection Program. The filling of this position has been instrumental in providing the managerial guidance needed in this area. Following assumption of the Principle Engineering position, an assessment of the Fire Protection Program was performed in which several additional areas were identified which require f improvement. Based on the results of this assessment, and any futuru assessments, appropriate programmatic upgrades will be incorporated.

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