BSEP-98-0043, Responds to NRC Re Violations Noted in Insp Repts 50-324/97-13 & 50-325/97-13.Corrective Actions:Established Controls to Ensure safety-related Clearances Are Maintained as QA Records IAW Site Procedures & Counseled Personnel

Responds to NRC Re Violations Noted in Insp Repts 50-324/97-13 & 50-325/97-13.Corrective Actions:Established Controls to Ensure safety-related Clearances Are Maintained as QA Records IAW Site Procedures & Counseled Personnel

ML20203C702
Person / Time
Site:	Brunswick
Issue date:	02/23/1998
From:	Hinnant C CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-324-97-13, 50-325-97-13, BSEP-98-0043, BSEP-98-43, NUDOCS 9802250237
Download: ML20203C702 (9)

Text

FEB 23 '99 05858 P!1 TECH SUPPORT _ _

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"6NAlCPiL to _f 1 Al19 Coroline Power & Ught Compeny C.S. HinnerW P.O. nom 10429 Yke Prn: dent Southport. NC 28461 0429 brunswick Nuclear Plom SERIAT.. BSEP 98-0043 10 CFR 2.201 FEB 2 31998 .

U. S. Nuclear Regulatory Commission ATTN: . Document Control Desk Washington,DC 20555 BRUNSWICK STEAM ELECTRIC PLANT,l' NIT NOS.1 AND 2 DOCKETNOS. 50 325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REPLY TO NOTICE OF VIOLATION Gentlernen:

l On January 23,1998, the NRC issued a Notice of Violation (NOV) to the Brunswick Steam i Electric Plant (BSEP), Unit Nos. I and 2. The NOV contains three violations, the bases for I which are delineated in NRC Inspection Report Nos. 50 325/9713 and 50-324/9713.

l Enclosure 1 provides the responses to the violations in accordance with tne provisions of 10 CFR 2.201. In addition, Enclosure 1, Response to Violation C, provides additional information regarding the concern identified in the NRC letter dated December 23,1997, associated with the documentation and handling of the out of specification drywell temperature data. Enclosure 2 delineates regulatory commitments contained within the responses.

This reply to the NOV does not contain information of a propietary nature. Please refer any questions regarding this submittal to Mr. Keith R. Jury, Manager - Regulatory Affairs, at (910) 457-2783.

Sincerely, csl%x C. S. Hinnant SFT/sft l l:- h- l 'l i

Enclosures:

1. Reply to Notice of Violation

2. List of Regulatory Commitments Huo q g , '

9802250237 900223 PDR ADOCK 05000324 I]O[ [ **nb

j G PDR Hwy 87 Tel(910) 457.2496 FAX [910) 4572803

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FEB 23 '90 05:58Pt1 TECH SUPPORT ' 'P .

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Document Control Desk BSEP 98 0043 / Pago 2 oc(with snclosures):

U. S. Noclear Regulatory Commission, Region II ATTN: Mr.Luis A.Reyes, Regional Administrator.

, Atlanta Federal Center ,

61 Forsyth Street, SW, Suite 23T85 Atlanta. OA 30303 U. S. Nuclear Regulatory Commission ATfN: Mr. Charles A. Patterson, NRC Senior Resident Inspector 8470 River Road Southport,NC 28461-4 U. S. Nuclear Regulatory Commission ATTN: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) 11555 Rockville Pike Rockville, MD 20852 2738 The Honorable Jo A. Sanfoni Chairman North Carolina Utilities Commission P.O. Box 29510 Raleigh,NC 27626 0510 4

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FEB 23 '98 05:39Pt1 TECH SUPPORT 99.3 ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC P', ANT, UNIT NOS.1 AND 2 DOCKETNOS.50 325 AND 50-324 LICENSE NOS DPR-71 AND DPR 62 RSPLY TO NOTICE OF VIOLATION ,

During an NRC inspection conducted bom November 9 through December 27,1997, three -

violations of NRC requireme .ts ware identified. In accordance with the "Genci Statement of ,

Policy and Procedure for NRC Enforcement Actions " NUREG-1600, the violations are listed below:

l VIOLATION At Technical Specificatios (TS) 6.10 requires that facility records be rctained in accordance with the American National Standards Institute (ANSI) N45.2,9-1974, Collection, Storage, and Maintenance of Quality Assu.ance Records.

ANSI N45.2.9 1974, in Section 3.2.7, Retention of Records, states that Appendix A to the standard defined the types of Quality Assurance (QA) records and the recommended retention periods. Attachment A to ANSI N45.2.9-1974 Section A.4.4, Mechanical, aquhes data sheets or logs on equipment installation, inspection, and alignment be maintained.

Contrary to the above, on December 9,1997, the inspector determined that the licensee had not maintained data sheets or logs for equipment alignment as evidenced by the failure to require that clearances be maintained u a QA record in Nuclear Records Management Procedure ORMP 001, j  !**g of Plant Records and Nuclear Generation Group Standard Procedure OPS NGOC-1301, Equipment Clearance.

This is a Severity Level IV violation (Supplement 1). This is applicable to both Units.

RESPONSE TO VIOLATION A:

Admlaalon or Denityf Violation:

Carolina Power & Light (CP&L) Company admits the violation. ,

Raason for Violation:

The failure to retcn clearance records as QA documents is attributed to a programmatic deficiency. The individuals responsible for developing the index of QA records required by ANSI N45.2.9 1974, Section 3.2.2, inappropriately determined that clearance records were not required to be nalntained as QA records. This decision was based on an inadequate int-y.ution of the requirements contained within the standard. Additionally, this deficiency El-1

FEB 23 '90 05859PM TECH SUPPORT 9. .a was not recognized during a myiew and upgrade of the QA record list conducted in 1994, which locluded a validation of the QA/non-QA record classlScations. .

Corrective Actions Which }Igy; Bean Takan and Results Achieved:

Controls have been established to ensure that safety.related clearances are maintained as QA ,

records in accordance with site procedures. .

Corrective Stann Which Will Be Taken to Avald Further Violations:

A revision to procedure OPS-NOOC-1301, " Equipment Clearance," will be implemented to require the retention of safety related clearances sa QA mcords.

CPAL will validate that the non-QA record classifications, made during the 1994 review and upgrade, are correct Any deficiencies identified will be corrected.

Data Whma Full Cnmnliance f#ill Be Aehleved:

Full compliance with the mquirements of TS 6.10 has been achieved.

l VIOLATION B:

Technical Specification 6.8.1 requires that procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Oulde 1.33, November 1972. Appendix A, Paragraph 9.a recommends written procedures appropriate to the circumstance for performing maintenance. -

Preventive Maintenance Procedure OPM MCC002, Revision 7. Pre'rentive Maintenance of GE Motor Control Centers (MCCs) and Switchboards, seccifies the inspection requirements and acceptance criteria for MCCs and switchboards. Caroline Power and Light Environmental ,

Qnall& !on M Data Package (QDP) 67, Revision 5, dated July 29,1991, for the OE MCCs requires missing or disturbed Nelson flame seal putty be repaired or replaced.

Carolina Power and Light Company Qualification Data Package (QDP) 26, Revision 1, Joy Fan / Reliance Electric Motor Company Class 1E, Cont!nuous Duty,20 HP, and QDP 68 Revision 5 Standby Oas Treatment System - Fair Company Filter Unit and Controls, specify Chevron SR12 grease as the qualified lubricant for environmental qualification of electric motors -

in the QDPs.

Contrary to the above, maintenance procedures were not eablished eppiepsiate to the circumstances as evidenced by the following:

1. Procedure OPM-MCC002 did not contain the requirement of QDP 67 to repair or replace disturbed Nelson flame seal putty. This missed procedural requirement noted during an unrelated MCC breaker test on December 10,1997, resulted in damaged flame seal putty El-2

gg g3 723 SaisyM Tech SUPPORT *P.5 not being identified in MCC 2 2XB 2 during performance of Procedure OPM MCC002 on September 17,1997,

2. CP&L Maintenance Procedure MMM 053, Revision 6, dated November 11,1997, Equipment Lubricant Application Guidance and Lubricant Listing, specifies the use of a Mobil lubricant for those motors. The effect of using Mobil lubricant on environmental qualification of the motors included in QDPs 26 and 68 was not evaluated.

This is a Severity Level IV violation (Supplement 1). This is applicable to both Units, RESPONSE TO VIOLATION B:

Mmianion or Denial _of Violation:

CP&L admits the violation.

Raasan for Violadan: -

The causes of the issues cited in the exampics to this violation are attributed to human perfonnance errors. With aspect to example 1, the irdividuals responsible for revising procedure OPM-MCC002 failed to fully incorporate idendfled inspection / repair instructions for MCC cable penetration seals. As part of the actions initiated to correct MCC Environmental Qualification (EQ) concems identified in 1996 which were documented in Condition Report (CR) 96-02545, engineering personnel identified the need to revise 14 maintenance procedures.

! Procedure Action Requests (PARS) were establish:d for each of the procedures and submitted to the Maintenance organization. Of the 14 PARS, nine contained essentially identical changs request information. However, one of the nine PARS, the PAR submitted to support revision of OPM-MCC002, included the request to add inspection / repair requirements for MCC cable / conduit entrances. This additional request was ovedooked by the procedure writer and the individuals responsible for technical and administrative reviews of the procedure change. In addition, the procedure preparer failed to obtain an EQ discipline review of the changes. An inter-discipline review by the EQ engineering group would have provided an additional tamer for ensuring that the procedure change satisfied the requirements of the procedure change request.

The cause of the second example to this violation is attributed to inadequate reviews of the technical documentation used to support the exclusive use of Mobli lubricants at BSEP end to .

develop QDP 26. In the early 1970s, an initiative to secure a sole supplier of oil and lubricants was implemented. The Mobil Oil Company (Mobil) was selected as the vendor. Mobil evaluated the site lubrication needs and developed a report identifying lubricant types and periodicity recommendations for site equipment. The Mobil report was used as the bases for lubricants specified in the original preventive maintenance equipment lubrication procedure developed in 1974. This procedure specified the use of Mobilux EP #2 for fan motors. The requirement to use Mobil lubricants for fan motors has been carrisd forward in the procedures which have superseded the original lubrication procedure, including OMMM 053.

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U P.6 FEB 23 '90 06:00PM TECH SUPPORT In October of 1985, QDP 26 was issued to address the qualification requirements for the Residual Heat Removal and Core Spray systems pump room cooler fan motors. QDP 26 indicated that lubrication was not critical and, therefore, not a requirement to maintain the qualified life of the affected fan motors. Consequently, changes to the lubrication requirements specified in maintenance procedures were not identified at this time.

T'ne cause of this inue was determined to be an inadequate review of the Mobil report.

Individuals responsible for implementation of the lubrication program failed to formally evaluate the acceptability of using Mobil lubricant versus Chevron lubricant, as specified by the fan motor vendor. Although required by current procedures, there is no evidence indicating that.

engineering had formally reviewed the Mobil report at that time. In addition, the ladividuals ,

responsible fo the development and review of QDP 26 incorrectly determined that lubricati . 1 was not a critical factor in maintaining motor qualification.

Corrective Actionn Which Have Been Takan and Rasults Achieved:

The individuals responsible for the preparation and review of the inappropriate change to OPM-MCC002 have been counseled on the lessons teamed from the issue idantifled in example one to this violation, including the importance of applying self charWe techniques and the appropriate level of attention during procedure development, 1

l An engineering evaluation has been performed documenting the acceptability of using Mobil lubricants in environmentally qualified motors.

A review has been performed to ensure that lubrication requirements are being maintained in accordance with QDP requirements. No other deficiencies were identified. In addition, the violation indicates that the effects of using Mobil lubricant for the motors addressed in QDP 68 were not evabated. The motors addressed in QDP 68 contain sealed bearings and therefore, require no lubrication. Consequently, QDP 68 is considered acc able as written, corrective Stens Wah Will Be Tak n to Avald Further Violations:

An evaluation of procedure 0AP-003, " Procedure Preparation, Review, and Approval," will be performed to determine whether enhancements are needed to assist procedure writers and reviewers in specif'ying inter discipline reviews.

Training will be provided to Maintenance procedure writers on the lessons leamed from the issue Identified in example one to this violation.

CP&L committed to QDP reconstitution in CP&L letter date December 3,1997 (Serial:

BSEP 97 00508). Revisions to QDP 26 and other affected QDPs to address motor lubrication requirements for environmentally qualified components will be completed in ecojunction with the QDP reconstitution effort.

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4 Me Full Comellanem Will Be Achieved: .

Full compliance with the requirements olTS 6.8.1 has been achieved, yjQLATION C:

TS 6.8.1.a, requires that written procedures shall be established, implemented, and maintained covering the activities in Appendix " A" of Regulatory Guide (RG) 1.33, November 1972. '

RO 1.33,Section I, requires procedures for power operatien rod process surveillance.

Operating Instruction 10103.1, Control Operator Daily Surveillance Report, step 4.2.5 recnited the control operator (CO) to red circle all values which are not within required limits.

Contrary to the above, on November 30 through December 1,1997, the CO failed to red circle thsout of specification Steam Jet Air Ejector Off Gas Radiation Monitor values.

This is a Severity Level IV violation (Supplement 1). This is applicable to Unit 1 only.

RESPONSE TO VIOLATION C:

Ms or Dantal of Viglgign:  :

CP&L admits the violation.

Reason for Viniglan:

The cause of this violation wu inadequate implementation of Revision 57 to 10I-03.1, which

- incorporated the Technical Specification / Operating Limit (TS/OPER LIMIT) of "Normally

< 1,000 mR/hr" for the Steam Jet Air Ejector (SJAE) off-gu radiation level.

Unit I has been experiencing fbel leaks for several months which resulted in normal readings for '

the SJAE off gas radiatlan monitor to exceed 1,000 mR/hr. In order to ensure that appropriate actions were implemented prior to reaching the SJAE off gas radiation monito Jarm setpoint, Revision 57 to procedure 10103.1 was made in October 1997, adding "Normdly < 1000 mR/ht" in the TS/OpER LIMITS for the SJAE off gas radiation level checks. Prior to this revision there had been no limiting value fcr this parameter. However, the word "normally" resulted in confbslon. As a result, it was determined that red circling of SJAE off gu radiation levels in .

excess of 1000 mR/hr was not required because that was a " normal" reading for the existing Unit 1 conditions (i.e., operatior, with leaking fbel).

AdditionalInformation:

CP&L committed, in a letter dated hauan 22,1998 (Serf ah BSEP 98-00013), to address the concern identified in the NRC letter dated December 23,1997, regarding the documentation and handling of the out of-specification drywell temocrature data in the response to the violations cited in NRC Inspection Report Nos. 50 325/97-13 and 50-324/97-13. Investigationinto this El-5

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Issue determ'ned that Operations personnel did not exhibit the proper sensitivity concoming long term operstion with the out-of-specification drywell temperature readings. Following the initial troubleshooting of the failed drywell fan, it was determined that a unit outage and drywell e~ would be required to correct the problem. This work was scheduled for the next refueling age, starting in April 1998. Based on infortnation provided by Engineering personnel that the

,arrent drywell temperatures were bounded by analysis and knowing that correction of the condition would not occur for almost a year, Operations personnel should have initiated a revision to the daily logs to reflect the higher temperatures justified in the analysis; thereby, correcting the out-of-specification reading in a timely manner.

Corrective Actions Which Mave Been Taken and Results Aehleved:

Procedures 10103.1 and 20103.1 were revised to remove "Normally < 1000 mR/hr" from the TS/OPER LIMITS fw the SJAE off iiss radiation level checks.

Control Operator, Auxiliary Operator, and Radwaste daily check sheets and daily surveillance reports were reviewed to verify that they do not contain ambigvous wording in the TS/OPER LIMITS section.

10103.1 and 201-03.1 were revised to reflect the higher analyzed limits for dr>well I temperatures.

The status of out-of specification readings from the daily logs was included in the moming management status report.

Corrective Stans Which Will Be Takan to Avoid Further Violancns:

As a result of the review of Control Operator, Auy"lary Operator, and Radwaste daily check sheets and daily surveillance reports,101-03.1 and 201-03.1 will be revised to remove "Normally < 4 mR/hr" from the Reactor Building radiation monitor limits and " Consistent with ,

plant conditions" from the Gaseous releue flow instrument channel check limits.

Date Whan Full Co.nnllance Will Be Achieved:

Full compliance with the requirements of TS 6.8.1 has been achieved.

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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKETNOS 50-325 AND 50-324 LICENSE NOS. DPR 71 AND DPR 62 REPLY TO NOTICE OF VIO! ATION .

LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Carolina Po gr & I.ight (CP&L) -

Company in this document. Any other actions discussed in the submittal represent intended or planned actions by CP&L. They are described for the NRC's information and are not regulatory commitments. Please notif'r the Manager Regulatory Affairs of any questions regarding this -

document or any associated regulatory commitments.

Committed Commitment date or outage Implement a revision to procedure OPS-NOOC-1301, " Equipment - April 24,1998 Clearance," to require the retention of safety-related clearances u QA records.

Validate that the non-QA record classifications, made during the 1994 review December 18,1998 and upgrade, are correct. Any deficiencies identified will be corrected.

An evaluation of procedure OAP-003, " Procedure Preparation, Review, and March 31,1998 Approval," will be performed to determine whether enhancements are needed to assist procedure writers and reviewers in specifying inter-discipline reviews.

Training will be provided to Maintenance procedure writers on the lessons September 4,1998 loamed from the issue identified in example one to Violation B.

101-03.1 and 20103.1 will be revised to remove "Normally < 4 mR/hr" from April 10,1998 the Reactor Building radiation monitor limits and " Consistent with plant -

conditions" from the Oaseous release flow instrument channel check limits. ,

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