BSEP-86-1199, Responds to Violations Noted in Insp Repts 50-324/86-16 & 50-325/86-15.Corrective Actions:Outstanding Work Requests/ Job Orders from Refueling Outage Reviewed to Ensure Proper Limiting Conditions for Operation

Responds to Violations Noted in Insp Repts 50-324/86-16 & 50-325/86-15.Corrective Actions:Outstanding Work Requests/ Job Orders from Refueling Outage Reviewed to Ensure Proper Limiting Conditions for Operation

ML20212P447
Person / Time
Site:	Brunswick
Issue date:	08/14/1986
From:	Dietz C CAROLINA POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
BSEP-86-1199, NUDOCS 8609030136
Download: ML20212P447 (5)

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\% Carolina Power & Light Company Brunswick Steam Eicctric Plant P. O. Box 1042a Southport, NC 26+61-0429 August 14, 1986 FILE: B09-13510E SERIAL: BSEP/86-1199 Dr. J. Nelson Grace, Administrator U.S. Nuc1 car Regulatory Commission Suite 2900 101 Marietta Street NW Atlanta, GA 30323 BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS

Dear Dr. Grace:

The Brunswick Steam Electric Plant (BSEP) has received I&E Inspection Report 50-325/86-15 and 50-324/86-16 and finds that it does not contain information of a proprietary nature.

This report identified two items that appeared to be in noncompliance with NRC requirements. Enclosed is Carolina Power & Light Company's response to these violations.

Very truly yours,

. tu.cA A C. R. Dietz, General Manager Brunswick Steam Electric Plant RMP/dj Enclosure cc: NRC Document Control Desk 8609030136 060G14 PDR ADOCK 05000324 G PDR Tc c/ , \

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VIOLATION B Technical Specification 6.8.1.c requires procedures be implemented for surveillance and test activities of safety-related equipment. Surveillance requirement 4.0.5 of technical specifications requires inspection be performed of ASME Code 2 components. The inspection of the residual heat removal (RHR)

Class 2 supports is performed by PT-91.0.37, which requires a: support to be declared inoperable if a missing support item could impair the proper functioning of the support.

Contrary to the above, procedures for surveillance test were not properly implemented in that support 2E11-21FH62 was not declared inoperable as required by PT-91.0.37 when a misaing nut which impaired the proper functioning of the support was identified.

This is a Severity Level IV violation (Supplement I) for Unit 2 only.

RESPONSE

I. Admission or Denial of the Alleged Violation CP&L acknowledges that surveillance test procedures were not properly impicmented in that support 2E11-21FH62 was not declared inoperable as required by PT-91.0.37.

II. Reason for the Violation The missing nut was initially identified during performance of the in-service inspection of the support in accordance with PT-91.0.37. The mechanism to notify Operations of an LCO condition was the statement on _

the work request / job order (WR/J0) form "LCO required." The ISI Support Coordinator generated a WR/JO to replace the missing nut but did not add this statement. In addition, the log of WR/Jos maintained by the ISI group did not identify this particular item as an LCO condition. A review of the data on 110 support WR/J0s revealed this to be an isolated incident.

This incident revealed a programmatic deficiency in that the previous test data sheets for visual examinations are used only for recording examination results. The decision on whether a deficiency requires an LCO was made solely by the ISI Support Coordinator with no independent review of this determination.

III. Corrective Steps Which Have Been Taken As an immediate corrective action, outstanding WR/J0s issued by the ISI group from the Brunswick 2 refueling outage were reviewed to ensure proper determination of LCO requirements. The review indicated proper determi-nation of LCO requirements. This incident will be reviewed by the ISI group.

IV. Corrective Steps Which Will Be Taken To preclude recurrence of this violation, periodic procedures implementing the ISI support program will be revised to require the following:

A. The VT-3/4 examiner shall make the initial determination on whether a deficiency requires an LCO. This shall be documented on the examination data sheet.

B. A review of the data sheet by a certified VT-3/4 examiner will provide an independent review of the data and LCO determination.

C. The data sheets will be revised to require an LCO and a WR/JO number to be documented.

In addition to these procedural changes, this event will be reviewed by the ISI group to ensure their cognizance.

V. Date When Full Compliance Will Be Achieved The procedural changes and review of the event will be completed by December 18, 1986.

VIOLATION A 10CFR50, Appendix B, Criterion XVI, Corrective Action, as implemented by the licensee's accepted Quality Assurance (QA) Program (FSAR Chapter 17.2.6) requires, in the case of significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, significant conditions adverse to quality were not corrected, in that conditions similar to those found in September 1984 and April.1986 were again found in May 1986 as documented in NCR S-86-028. These similar significant conditions involved jumper 2 as being listed as active, not signed out, and not in the storage cabinet (May 1986), which is the same condition found in April 1986 for jumpers 201, 293, 330, and 345 and found in September 1984 for jumpers 27, 28, 29, 32, 46, 76, and 79.

This is a Severity Level IV violation (Supplement I).

RESPONSE

I. Admission or Denial of the Alleged Violation Carolina Power & Light (CP&L) Company acknowledges- that significant conditions adverse to quality were not corrected in that deficient designated jumper controls were not adequately corrected following audits in September 1984 and April 1986.

II. Reason for the Violation The designated jumper cabinet is a locked cabinet maintained in the Shift _

Operating Supervisor's (SOS) office. Issuance of these jumpers is controlled by the on-shift Operations Technician or the SOS through the use of a log book. Shift Foreman approval and SOS authorization is required for issuance of a designated jumper. This approval is redundant to Shift Foreman approval of the installation document (i.e., plant modification, WR/J0, or procedure). In accordance with Operating Instruction 29 (OI-29), an audit of the Jumper / Wire Removal Log and Designated Jumper Log is performed once per month. This internal audit identifies discrepancies and provides a mechanism for correction of discrepancies identified. The reason for this violation is failure to adequately investigate the disappearance of a jumper before being logged as missing.

III. Corrective Steps Which Have Been Taken Corrective action included conducting an audit of the designated jumper log which identified 14 designated jumpers listed as missing. A search was made of safety-related and nonsafety-related panels to find these missing jumpers. Seven of the fourteen jumpers were found, each in nonsafety-related circuits. The jumper log has been revised to correctly reficct their installation. Also, during the panel search a list of

l .1 Installed jumper tags was made to physically inventory additional jumper /

wire lifts installed by approved methods other than those tracked by the designated jumper log. These items are being reviewed to ensure the installation and accountability are per our plant Operating Manual require-ments. Based on this review and investigation, the remaining seven jumpers are considered lost.

IV. Corrective Action to Avoid Further Violations Appropriate procedures (OI-29, AI-59) will be revised to reflect a physical audit of installed safety-related jumpers controlled under Al-59. For any jumper not accounted for during this audit, an investigation will be conducted with results presented to PNSC prior to logging the jumper as missing.

V. Date When Full Compliance Will Be Achieved Full compliance will be achieved by November 28, 1986.

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