IR 05000324/1986034

Safety Insp Repts 50-324/86-34 & 50-325/86-33 on 861201-31 & 870114.Violation Noted:Failure to Provide Adequate Instructions for Sealing Pressure Switches

ML20210U257
Person / Time
Site:	Brunswick
Issue date:	02/06/1987
From:	Fredrickson P, Garner L, Ruland W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210U201	List: IR 05000324/1986034 ML20210U198 ML20210U215
References
50-324-86-34, 50-325-86-33, NUDOCS 8702180425
Download: ML20210U257 (10)

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. ; Report Nos. 50-325/86-33 and 50-324/86-34

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. Licensee: Carolina Power and Light Company P.'O.' Box'1551

~ RaleighJNC 27602 Docket Nos. 50-325 and 50-324 License Nos. DPR-71 and DPR-62 Facility Name: Brunswick 1 and 2 Inspection Conducted: December 1-31,-1986 and January 14, 1987 Inspectors: [ I. N k vs  %!$

go L V. H. Rula M Date Signed

2/6ls7 TCEf5.Mlin . Ga er -

Date Signed

Approved By: - 'f-P. E. Fredrickson, Section Chief

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/ Dat'e Signed Division of Reactor Projects

SUMMARY

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Scope: This routine safety inspection involved the areas of followup on previous

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enforcement matters, maintenance observation, surveillance observation, opera-tional safety verification, followup on inspector identified items, plant modifications, preparation for Unit I refueling, onsite followup of events, and licensee response to GE SIL 44 Results: One violation was identified - failure to provide adequate instructions for sealing pressure switche l l

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REPORT DETAILS Persons Contacted

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Licensee Employees P. Howe, Vice President - Brunswick _ Nuclear Project C. Dietz, General Manager - Brunswick Nuclear Project T. Wyllie, Manager - Engineering _and Construction G. Oliver, Manager - Site Planning and Control

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J. Holder, Manager - Outages-E. Bishop, Manager - Operations L. Jones, Director - Quality Assurance (QA)/ Quality Control (QC)

R. Helme, Director - Onsite Nuclear Safety - BSEP J. Chase, Assistant to General Manager J. O'Sullivan, Manager - Maintenance G. Cheatham, Manager - Environmental & Radiation Control'

K. Enzor, Director - Regulatory Compliance R. Groover, Manager - Project Construction A. Hegler, Superintendent - Operations W. Hogle, Engineering Supervisor B. Wilson, Engineering Supervisor B. Parks, Engineering Supervisor W. Biggs, Principal Engineer R. Creech, I&C/ Electrical Maintenance Supervisor (Unit 2)

R. Warden, I&C/ Electrical Maintenance Supervisor (Unit 1)

W. Dorman, Supervisor - QA W. Hatcher, Supervisor - Security R. Kitchen, Mechanical Maintenance Supervisor (Unit 2)

C. Treubel, Mechanical Maintenance Supervisor (Unit 1)

R. Poulk, Senior NRC Regulatory Specialist D. Novotny, Senior Regulatory Specialist

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W. Murray, Senior Engineer - Nuclear Licensing Unit

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Other licensee employees contacted included construction craftsmen,

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engineers, technicians, operators, office personnel, and security force member . Exit Interview (30703)

The inspection scope and findings were summarized on January 14, 1987, and during the report period with the general manage A violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings-(paragraph 10) was discussed in detail. The licensee acknowledged the findings without exceptio The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during the inspection.

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2 Followup on Previous Enforcement Matters (92702)

(CLOSED) Violation (324/83-32-02), Failure to Follow Procedure OI-13 Results in Fire Protection Valve Being Shut. The inspector reviewed the licensee's response, dated December 7,1983, to the notice of violation. The correc-tive actions adequately addressed the root caus (CLOSED) Violation (325/83-34-01), Failure to Establish Procedures for Control of Drawings During Enhancement Process. The inspector reviewed the response to violation, dated December 22, 1983, and BESU AS-Built Program Guidelines, issued January 11, 198 These appear to have adequately addressed the lack of controls which contributed to the violatio (CLOSED) Violation (325/83-41-01), Failure to Correctly Perform Steam Jet Air Ejector (SJAE) Off Gas Radiation Monitor Calibratio The inspector reviewed the response to infractions of NRC requirements dated February 7, 1984. The corrective actions appear to be adequate. The inspector verified that PT-70, Revision 4, SJAE Off Gas Radiation Monitor Channel Calibration, issued December 15, 1983, contained the information described in the licensee's response. The current Revision 7 of PT-70 no longer contains the information. However, the inspector verified that PT-04.3.6PC, Main Condenser Air Ejector Radiation Monitor Channel Calibration and Functional Test, Revision 5, dated October 10, 1985, adequately addressed the calibra-tion setpoint issu The current revision of PT-70 requires that PT-04.3.6PC be performed at the time PT-70 is performe (CLOSED) Violation (325/83-41-03), Failure to Adequately Establish Shutdown Procedur The inspector reviewed the licensee's response, dated February 7,1984. The licensee included appropriate steps in GP-05, Unit Shutdown, and committed to incorporate appropriate changes, if necessary, into operating procedures. The inspector verified that appropriate steps are included in the current revisions of GP-05 (Revision 10), and Unit 1 and 2 operation procedures, Neutron Monitoring System (Revision 2 and 10 for Unit 1 and 2, respectively).

(CLOSED) Violation (324/84-07-02), Failure to Have Latest Copy of Emergency Procedure EI-29 at Remote Shutdown Panel. The inspector reviewed the response to the violation, dated May 2,1984. The actions described appear adequate to prevent future occurrence The inspector with the assistance of an auxiliary operator verified that only current revisions of A0P-32 (EI-29 replacement) were stored at the unit 1 and 2 remote shutdown panel (CLOSED) Violation (325/86-17-01), Rigging Scaffolding to Reactor Core Isolation Cooling (RCIC) Snubber Attachment, response dated October 16, 198 The inspector reviewed Revision 1 to WP-18, Temporary Rigging and Scaffolding, and reviewed the attendance list for reinstruction of personnel in the requirements of WP-1 ._

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(CLOSED) Violation ' (325/86-17-02 and 324/86-18-02), Cigarette Smoking in the Diesel Generator (DG) Building, response dated October 16, 198 Reviewed plant management memo mentioned in the response dated August 7, 1986, that was addressed to Plant Management group. Memo was also forwarded to construction and training. ~ A - discussion of no smoking areas is now -

included in the General Employee Training (GET). The inspector reviewed the meeting attendance sheet for the training. The-inspector also-reviewed the Weekly Fire and Housekeeping Inspection, FPP-013, for the week of November 14, 1986. No evidence of smoking was found by the licensee during that inspectio No violations or deviations were identifie . Maintenance Observation (62703)

The inspectors observed maintenance activities and reviewed records to verify that work was conducted in accordance with approved procedures, Technical Specifications, and applicable industry codes and standards. The inspectors also verified that: redundant components were operable; administrative controls were followed; tagouts were adequate; personnel were qualified; correct replacement parts were used; radiological controls were proper; fire protection was adequate; quality control hold points were adequate and observed; adequate post-maintenance testing was performed; and independent verification requirements were implemented. The inspectors independently verified that selected equipment was properly returned to servic Outstanding work requests were reviewed to ensure that the licensee gave priority to safety-related maintenanc The inspectors observed / reviewed portions of the following maintenance activities:

86-BZQG1 Reactor Building Closed Cooling Water System Head Tank Level Switch Repair 86-CACA1 Reactor Building Ventilation ' Radiation Monitor, D12-RM-N010B, burnt relay replacemen MI-16-05 Local Power Range Monitor (LPRM) Neutron I/V Curve OPM-RE002 Preventive Maintenance on NMC Radiation Monitor and Drywell Analyzer System Cabinet No violations or deviations were identified.

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- Surveillance Observation (61726)

'The'-inspectors observed'surveillanceztesting required by Technical'Specifi-cations. Through observation and record review, .the -inspectors verified '

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.that: tests conformed to Technical ' Specification requirements; admini -

strative controls were followed; personnel were qualified; instrumentation was calibrated; and data was . accurate and . complete. _ The . ' in spectors independently verified selected test results' and proper return to service of ,

equipmen The inspectors witnessed / reviewed portions of the following test activities:

PT-4. Reactor Building Vent Exhaust. Monitoring' System _ Function Tes PT-12.3.5d Emergency Diesel Generator No. - 4,- 54 Month Inspection -

Crankcase Deflection Measurements. and Jacket Water Heat

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Exchanger Cleanin PT-1 Electric Power Systems Operability Tes No violations or deviations were identifie . Operational Safety Verification (71707)

The inspectors verified conformance with regulatory requirements by direct observations of activities, facility tours, discussions with personnel, reviewing of records and independent verification of safety system statu The inspectors verified that control ~ room manning _ requirements of 10 CFR 50.54 and the Technical Specifications were me Control room, shift supervisor, ' clearance and Jumper / bypass logs' were -reviewed to obtain information concerning operating trends and out of service safety systems to ensure that there were no conflicts with Technical Specifications Limiting

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Conditions for Operations. Direct observations were conducted of control room panels, instrumentation and recorder traces important~ to safety to .;

verify operability and that parameters were within Technical Specification limits. The inspectors observed shift -turnovers to verify that continuity--

of system status was maintaine The - inspectors verified ' the status -of selected control room annunciator Operability of a selected Engineered Safety Feature (ESF) train was veri.fied by insuring that: each accessible valve in the flow path was in its correct position; each power supply and breaker, including control room' fuses, were aligned for components that must activate upon initiation signal; removal of power from those ESF motor-operated valves, so identified by Technical Specifications, was completed; there was no leakage of major components; there was proper lubrication and cooling water available; and a condition did not exist which might prevent fulfillment of' the system's functional-t_ _ _ __

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5 i requirements. Instrumentation essential to system actuation or performance was verified operable by observing on-scale indication and proper instrument valve lineup, if accessibl The inspectors verified that the licensee's health physics policies /

procedures were followed. This included a review of area surveys, radiation work permits, posting, and instrument calibratio The inspectors verified that: the security organization was properly manned and security personnel were capabl_e of performing their assigned functions; persons and packages were checked prior to entry into the protected area (PA); vehicles were properly authorized, searched and escorted within the PA; persons within the PA displayed photo identification badges; personnel in vital areas were authorized and effective compensatory measures were employed when require The inspectors also observed plant housekeeping controls, verified position of certain containment isolation valves, checked a clearance, and verified the operability of onsite and offsite emergency power source During routine review of control room indications, the following items were pointed out to the control operators:

On December 1,1986, the inspector observed no reactor control board indication for the Unit I south Residual Heat Removal (RHR) room cooler fa The control operator dispatched an auxiliary operator to the Motor Control Center (MCC). No local indication was lit. Work request 86-BXCX1 was issued. The breaker was found with the A phase open and the output wiring damaged. The breaker and damaged wiring were replaced and the fan was returned to service. Probable cause of failure was attributed to a possible loose connection due to heat or vibration.

t On December 30, 1986, the inspector observed the Unit I containment atmosphere monitor CAC-1262 with the no flow indicator lit and the motor on indicator not lit. The control operator started the monitor with no troubl On December 30 and 31, 1986, the inspector observed the diesel generator building supply fan B indicator on the main control board was not li In both instances, the breaker was found tripped. On January 1, 1987, because operations personnel were aware of other breaker trips in recent weeks, work request 87-AAAA1 was issued to investigate the proble No violations or deviations were identified.

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6 Followup on Inspector Identified Items (92701)

(CLOSED) Inspector Followup Item (325/83-32-01 and 324/83-32-01), Inadequate Test Procedure and Personnel Inattention Results in High Pressure Coolant Injection (HPCI) and RCIC Isolations. The subject event was discussed in correspondence dated September 16, 1983, between P. Howe and J. O'Reill In the letter, the licensee discussed the surveillance procedure upgrade project. The upgrade project was completed in early 1986. The inspector had numerous discussions with the upgrade project personnel during the project. The issues raised by this event have been satisfactorily addressed by the license (CLOSED) Inspector Followup Item (325/83-41-02 and 324/83-41-01)e Establish a Convenient Method of Retrieving Radiation Monitor Setpoints. The inspector I discussed the method presently in use with the cognizant supervisor. A copy of the completed setpoint data sheet is being maintained in a file in the Environmental and Radiation Control (E&RC) of fice. The inspector verified that the file was being maintained current as required by procedures. This adequately addresses the inspector's concern. However, during the inspec-

) tion on December 16, 1986, the inspector was shown an unofficial espy ( e., not required by procedure), of E&RC procedure 2020 data sheet posted in the counting room. This copy was dated by the foreman as being reviewed on October 10, 1986. The latest copy in the file drawer was dated November 20, 1986. The inspector verified that there had been no change in data between the two sheets. The subject data sheet contains setpoint information for the main stack, the reactor and turbine building monitors and the off gas monitors. The inspector discussed the posting practice with the E&RC manager. He said that they would discontinue the practice of posting a copy in the counting room. The outdated data sheet was remove (CLOSED) Inspector Followup Item (325/84-31-05 and 324/84-31-05), Licensee to Change Annunciator Response Procedures to Provide Specific Guidance on Personnel Protection Following Chlorine Hazard Alarms. The inspector reviewed the following revised annunciator procedures: APP UA-28 5-1, 5-2 and 6-2 for Unit 1 and Unit 2. These procedures adequately address the inspector's concern. The inspector verified that the current revisions to these procedures still contain the appropriate actions and warning (CLOSED) Inspector Followup Item (325/85-27-03 and 324/85-27-03), Enhance  ;

Controls to Preclude Installation of Safety Related Equipment in Proximity l to Unanalyzed Masonry Walls. Structural Design Guide SDG-2, Design of Pipe Supports, Revision 1, and SDG-5, Design of Seismic Class 1 Safety Related Conduit Supports, Revision 1, have been revised to assign the responsibility for checking structural drawings to address the masonry wall issue to the support enginee No violations or deviations were identifie __ _ - _ _ _ _ _ _ _ _ _

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l Plant Modifications (37700)

The inspector observed work in progress for modifications86-096, Chlorine 4 Re-distribution, and 86-072, Chlorine Detector Work observed by the '

inspector was accomplished in accordance with the approved modification package The licensee removed the chlorine tank car from the protected area, as required by Technical Specifications (TS), while replacing the chlorine detector No violations or deviations were identifie . Preparation for Unit 1 Refueling (60705)

The inspector observed new fuel receipt inspection, fuel channel fastener placement, and storage of five new fuel assemblies for the upcoming Unit I refueling. The inspector verified that the licensee performed the inspec-tions in accordance with ENP-27, Rev. 5, New Fuel, Channels, and Channel Fasteners Inspectio No violations or deviations were identifie . Onsite Followup of Events (93702)

Pressure Switches Installed Without Environmentally Qualified (EQ) Conduit Seals On December 12, 1986, the licensee identified that ASCO pressure switches, 2-IA-PSL-3596 and 3597, installed per plant modification No.84-196, were not installed with the required conduit seals. The licensee had procured EQ switches and had pulled EQ cable to the switches but had failed to seal them in accordance with the requirement of the EQ qualification data package, QDP-77. Page 2-9 of the QDP requires that the conduit entrance should be sealed. The QDP-77, Revision 0, was issued on October 17, 198 The affected modification was entitled Nitrogen Back-up System. The modification provides a safety related pneumatic supply to the Automatic Depressurization System (ADS) safety relief valves and Torus-to-Reactor Building vacuum breakers. The modification received a technical review and project engineer review on September 6, 1985. Final approval by the general manager designee was granted on December 12, 198 Subsequent to these approvals, on December 20, 1985, the pressure switches and associated

, solenoid operated valves were added to the modification design basis i

document and included in Field Revision 4 to the modification package, dated

{ January 13, 1986. The licensee identified that these items had to meet 10 l CFR 50.49 requirements. The switches were installed in the spring of 1986.

, Because the modification package failed to require an EQ conduit seal, the

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switches were installed at that time without the proper seal. However, the l solenoid valves were unavailable then, so the switches were not in service.

In October,1986, the licensee installed the solenoid valves and connected the switches to them.

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Failure.to have the switches sealed has only minor safety significance. The switches open the nitrogen bottle bank isolation solenoids upon low reactor building air pressure. Review of the system design indicates that, on lose of power, the solenoid valves fail open, thereby placing them in . the required position. The licensee stated that ASCO, the switch manufacturer, indicated that the small quantity of moisture expected to intrude into the unsealed switch would cause no problem. However, even if moisture did affect the switch, the probable failure would be a short circuit and_ blowing of the internal switch fuse. This would result in-lose of power to the solenoid and failure to the safety related positio An inadvertent actuation of the solenoids would potentially allow the nitrogen banks to leak dow The licensee has provided annunciation and provisions for re-supplying the nitrogen bank As described in Generic Letter 86-15, issued September 22, 1986, if a violation of the EQ rule identified after November 30, 1985 does not relate back to action or lack of action before the deadline, enforcement should be taken under the current enforcement policy. As described above, this event does not relate back to action or lack of action before the November 30, 1985 deadline because the design identified the need for an environmentally qualified component after the deadline and the failure to incorporate the seal requirement occurred between the design change and field revision, g., between December 20, 1985 and January 13, 1986, 10 CFR 50, Appendix B, Criterion V, requires activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances. Environmental qualification of a component as described by 10 CFR 50.49, is an activity affecting qualit Failure to provide adequate instructions to seal'the conduit openings into pressure switches 2-IA-PSL-3596 and 3597 resulted in the components being unqualified and thus constitutes a violation of 10 CFR 50, Appendix B, Criterion V: Failure to Provide Instruction to Ensure Pressure Switch is Installed Per EQ Requirement (324/86-34-02).

One violation and no deviations were identifie . Licensee Response to GE SIL No. 445(92705)

On June 26, 1986, General Electric (GE) issued Rapid Information Communica-tion Service Informal Letter (RICSIL) No. 007 concerning a potential undetectable loss of the Intermediate Range Monitor (IRM) initiated Reactor Protection System (RPS) scram function. On. September 10, 1986, a followup Service Information Letter (SIL) No. 445 was initiated with three recom-mended practices. One of the recommendations has been implemented and 'two are being evaluated. The first recommendation involves performance of the channel functional tests on each channel upon completion of fault repai This is normal licensee practice and is implemented by their post mainten-ance test requirement system. For the Brunswick type monitor (diagram N E384), the second and third recommendations involve upgrading the logic I

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power fuse to a 1.5 amp size and installing a negative voltage sensor relay in the circuitr This sensor relay would provide a RPS IN0P (inoper-l ability) trip in response to a loss of negative powe The licensee is in the process of-writing a special procedure, No. SP-86-068 for Unit 1 and SP-86-073 for Unit 2, to verify that their installed monitors do indeed have the problem. The licensee has scheduled the. special

! procedures for the week of January 19, 1987. Based on the results, the L licensee will implement the last two recommendations as necessary. The licensee has identified a conceptual design change to install the negative voltage sensor. The inspector reviewed the SP's with the system engineer dnd has no questions. Completion of the SP's and potential modifications is an Inspector Followup Item: IRM Fuse Testing and Subsequent Required Modifications ('425/86-33-01 and 324/86-34-01).

Pending these actions, the licensee had determined on October 6,1986, that their required surveillance procedures MST-IRM11W and 12W involving channel functional testing would detect a failed negative voltage fus These procedures are performed per TS once per 7 days while in condition 2, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to startup if not in previous seven days and within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering condition 2 from condition No violations or deviations were identified, i

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