IR 05000324/1989003

Insp Repts 50-324/89-03 & 50-325/89-03 on 890123-27.No Violations Noted.Major Areas Inspected:Followup to Operational Performance Assessment Conducted on 880627-0715, Described in Insp Repts 50-324/88-19 & 50-325/88-19

ML20235L359
Person / Time
Site:	Brunswick
Issue date:	02/10/1989
From:	Breslau B, Lawyer L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20235L338	List: IR 05000324/1989003 ML20235L335
References
50-324-89-03, 50-324-89-3, 50-325-89-03, 50-325-89-3, NUDOCS 8902270487
Download: ML20235L359 (10)

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'k_ UNITED STATES

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j lj' NUCLEAR REGU,LATORY COMMISSION o, j' REGION H 101 MARIETTA ST., e ,,,, g ATLANTA, GEORGIA 30323 i

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I Report No.: 50-325/89-03 and 50-324/89-03

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Licensee: Carolina Power and Light Company P.O. Box 1551 Raleigh, NC. 27602 Docket No.: 50-325 and'50-324 License Nos.: DRP-71 and DRP-62-Facility Name: Brunswick 1 and 2 Inspection Conducted: Januar 23-27, 1989 Inspectors: w w bdNM2, I///f~

B. 'Bresl au , Tsam Leader Date Sign'ed/

Team Mesbers: R. Starkey C p

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kf L. Law;ver, (Acting) Chfef / Date Signe Operational Programs.Section Division of Reactor Safety SUMMARY Scope: This announced inspection was conducted as a follow-up to the Operational Performance Assessment (0PA) conducted June 27-July 15,1988, Inspection Report Nos. 50-325,324/88-19. The scope of this inspection included review of four inspector Follow-up Items (IFI) as well as those items identified in the OPA as program weaknesses or concern Result Increased management attention to site activities is apparent and and appears to be an area of potential strength, paragraph 2.g.(1).

' Revision 4 to the Emergency Operating Procedures indicate significant improvement, but there are areas which require futher improvement, paragraph 2.g.(3).

8902270487 890216 ""'

PDR ADOCK 05000324 Q PDC

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REPORT DETAIL

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! Persons Contacted Licensee employees

• K. Altman, Manager, Maintenance

• C. Blackmon, Manager, Operations

• A. Cheatham, Manager, Environmental and Radiological Control

• R. Creech, Supervisor, I&C Maintenance

• Dorman, Supervisor, Quality Assurance

• K. Enzor, Director, Regulatory Cocpliance

• Geise, Project Specialist, Training

• J. Harness, General Manager

• R. Helme, Manager, Technical Support

• J. Holder, Manager, Outages

• Martin, Principal Engineer, Onsite Nuclear Safety

• J. O'Sullivan, Manager, Training  !

• R. Poulk, Project Specialist, Regulatory Compliance l

• R. Starkey, Manager, Brunswick Nuclear Plant l t

Other Licensee employees contacted included instructors, engineers, technicians, operators, and office personne NRC Representatives

• Ruland, Senior Resident Inspector

• Attended exit interview Acronyms used throughout this report are listed in the last paragrap . Action on Previous Inspection Findings (92701) (0 pen) Unresolved Item 324,325/87-12-01, Evaluation of Licensee's action to resolve equipment failures associated with licensee event reports 1-86-024, 1-87-001, 2-87-001, 2-87-00 This item involved the licensee's difficulties with their HPCI system. The licensee is still pursuing the HPCI component problem Their schedule indicates these items will be completed by December 198 This item will remain open pending NRC review of the licensee's action (Closed)IFI 324,325/87-12-03, Review of LER preparation proces The licensee committed to review and revise procedure RCI-06.1, which delineates the method for LER preparation. The inspector reviewed revised procedure RCI-06.1 and determined that the guide lines are adequate for satisfactory LER preparatio (Closed)IFI 88-19-01, method by which temporary procedure revisions are attached to control room working copies is confusing.

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Paragraph 2.b., Temporary Procedure Revisions, identified an inconsistency in the method by which temporary procedure revisions are attached to control room working copies. Discussions with the !

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licensee concerning this issue resulted in a commitment to revise the administrative procedure to ensure that temporary procedure revisions are properly controlle Volume 1, Book 1-Administrative Procedures, Section 5.7.4.2, Temporary Revisions, has been rewritten to establish new guidelines for handling control room working copies. This new method was acceptable and should eliminate potential operator confusion when using temporary procedure revision (Closed) IFI 88-19-02, control and posting of operator aids observed as a weaknes Paragraph 2.h., Operator Aids, identified four examples of unauthorized operator aids and questioned the mechanism for controlling operator aid The licensee took prompt action to remove the four identified aids and in one case issued a properly executed operator aid to replace the unauthorized on On this followup inspection the inspector performed an extensive plant walkdown and did not observe any unauthorized operator aid Two aids were discovered which had been posted under the guidelines of an outdated operator aid procedure. The licensee removed these and will replace them with properly authorized aids. The control and posting of operator aids is considered by the inspector to be adequately controlle (0 pen) IFI 88-19-03, lack of justification for not concurrently performing pressure, level, and power control as directed by the BWROG EPG Paragraph 3.d., E0P Documentation, the licensee did not document the exception for not concurrently performing power, level, and pressure control according to the BWROG guideline The licensee had taken action to document this deviation but the documentation was insufficient in detail. The licensee has committed to providing further detail to demonstrate the required actions of pressure, level, and power control are performed in the five flowpath (0 pen) IFI 88-19-04, lack of documentation for conversion from the PSTG to the E0P Paragraph 3.d., E0P Documentation, the licensee documentation for development of the PSTG and E0P flowcharts was insufficiently detailed or did not exis The licensee has developed this documentation but it was incomplete because it did not specifically state where the PSTG step is

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addressed on the flowpaths. . The licensee is currently- developin additional documentation that relates a flowpath step to a PSTG step but. they did not consider this to be part of the E0P documentatio Since this additional documentation provides an important link between the E0Ps and the PSTG, it should be. included as part of the E0P docurientation. The licensee has committed to including this additional ~ documentation as.part of the E0P documentatio g. In addition to the above Items, a number of weaknesses and concerns were identified in Inspection Report No. 325,324/88-19 and are addressed below:

(1) Management Controls (a) Paragraph 5.a., plant status meetings noted that during selected daily plant status meetings there was a lack of. substantive participation by most attendees. .The meetings were terse restatements of plant status with little, if any associated discussions. The accuracy and adequacy of status information versus actual plant status was questionable and management's assertiveness and control ~ varied widely depending on the subjec The inspector attended daily plant status meetings .and Plant Nuclear Safety Committee meetings. -The participants provided accurate status information, with each member providing detailed information regarding their respective areas. The inspector detected a marked improvement of management assertiveness and control between these meetings and the ones previously observed in the June - July 1988 inspectio (b) Paragraph 5.b., Management involvement, indicated that the lack of management's direct involvement in' plant activities was considered a weakness, this was evidenced by the fact that managers, excluding the Operations and Maintenance Managers whose offices were locatea in the protected area, were spending only 3% of their available time within the protected are The licensee recently reorganized, and has placed new managers in the General Managers and Site Vice President positions. The inspector observed management conducting daily tours and noted that they actively took part in assessing on-going activities. Additionally, the inspector requested a printout of security computer transactions to determine how often and how long key members of management accessed the protected and vital area Analysis of the printout revealed that upper management's involvement in the plant has increased from the previously noted 3%, to approximately 10 % of the available tim _ _ _ - - _ _ - - -_ _ _ - _ _ _ - _ _ . ----

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This positive emphasis by management toward direct involvement should provide qualitative result (2) Operations Area (a) Paragraph 2.a.(1), Control Room Decorum, expressed a concern regarding control room crowding following a major plant event such as a reactor scram. During this followup inspection no such event occurred and, therefore, no direct observation of such crowding was possibl However, the inspector did discuss with the Manager-0perations his views of this concern. He stated that those personnel in the control room following major

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plant events are normally operations or management personnel whose presence is needed or requested during such evolutions. Furthermore, these extra personnel were an aid rather than a hindrance to the control operato (b) Paragraph 2.a.(2), Status of Control Board and Local Instrumentation, discussed 4 discrepancies as noted during 3 control board walkdown Subsequent review by the inspector of corrective actions has revealed that two of the discrepancies will be corrected via a plant modification, PM87-087, during a future refueling outage. A third discrepancy concerning the circulating water intake pumps-was resolved via a plant modificatio The fourth discrepancy involved readability problems with Area Radiation Monitor recorders, D22-R600 and D22-R601, located in the Unit 1 control room. These recorders have a history of malfunctioning as evidenced by numerous work requests on each recorder. No permanent resolution to the recorder reliability / readability has been determined. It should be noted, however, that the data provided by the recorders is also available on other instruments in the control room and that no routine data from these recorders is used by the operator (c) Paragraph 2.g., Housekeeping, identified several areas needing increased housekeeping attention. The inspector toured those areas mentioned in the OPA report and is satisfied that either corrective action has been taken or steps have been initiated to provide long term corrective action Specifically, the system engineer for the service water system is cognizant of corrosion concerns in i the service water pump house building and will present his recommendations for corrective actions to plant managemen The other item that will require further action by the licensee concerned seismic considerations for bookcases and file cabinets in the control room. A design has been approved

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for installation of brackets to properly secure these fixtures.

i Installation will take place in the near futur (d) Paragraph 2.j., Overtime, discussed the failure to follow

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procedure in'the use of overtime.for operations personne The potential for exceeding overtime guidel_ines had been

- identified by the licensee and was therefore not cited'as a violatio However, in the NRC Resident Inspector's report, 50-324, 325/88-41, - four examples -were identified of operations personnel exceeding the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in seven consecutive days'

criteria without prior Plant . General Manager approva The Resident Inspector's report was in draft form -at the time .of_ this followup _ inspection, but the intent is to

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cite a violation of Technical Specifications concerning exceeding overtime guideline On December 29, 1988, the' Manager-0perations issued - a strongly worded memorandum to all operations personnel reminding them that they are required to' work within the administrative overtime guidelines or receive Plant General Manager approval of any exceptions befare actually exceeding the overtime limits. Plant management appears to be giving an appropriate level of attention to the o'vertime issu (e) Paragraph.2.1., Management Involvement, stated that Shift Foremen were not making plant tours as often as they should and that additional emphasis should be placed on performing plant tour Discussion with the Manager-0perations concluded that he has stressed to the Shift Foremen and Shift Operations Supervisors the importance of making tours each shif The Plant General Manager also has emphasized plant' tours as an important element in employee job performanc (3) Emergency Operating Procedures l

(a) Paragraph 3.a. , Flowpaths, noted several instances of unclear step The licensee has performed a detailed review and corrected these instances of unclear steps in the flowpaths.

l l (b) Paragraph 3.a. , Flowpaths, identified instances where l

operators could not locate information contained in the

Users Guid The licensee has tabbed sections of the L Users Guide necessary to proper E0P usag (c) Paragraph 3.a. , Fl owpaths, noted a concern about the number of steps on the flowpaths. The licensee has -

significantly streamlined all the flowpath .

Additionally, a separate procedure for Station Blackout is .j under development and will allow removal of these steps from Path-4. Since a significant number of steps have g

been removed from the flowpaths, consideration should be '

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given to reducing the physical size of the flowpath !

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In reviewing the current flowpaths,- the 'symbo1 used iio exit Path-1 was not described in-the Writers Guide. The-Writers Guide should be corrected to ' include this symbol !

or the exit symbol changed to- that already described in -

'the Writers Guid (d) Paragraph - 3.b. , . Local Procedures, identified' lack' o i

" sufficient control room copies of Local Emergency y Procedures. The. licensee has placed a sufficient number V - of ccpfes .in ' the control room to' allow personnel outside 1 the control room access to these procedures- without S impacting control room activitie (e) Paragraph . 3.b. , Local Procedures, was ; concerned with manpower and equipment resources not specified in the

- procedure and identified several instances of incorrect labelin The licensee has specified manpower and '

resource requirements .at the beginning of each local procedure. The licensee has also performed walkdowns ' .

of each local procedure and corrected any' equipment labeling discrepancie (f) Paragraph 3.b., Local Procedures, identified a lack of I adequate key control for equipment keys necessary to accomplish the E0P The : licensee has implemented an accountability program for keys required in the E0Ps. All keys are placed in a labeled bag and kept locked in the E0P table. The key to the E0P table is maintained in the Control Room key locker as are the keys for SLC and AR (g) Paragraph 3.b., Local Procedures, noted preferred order was implied but not specifically stated. The licensee has listed the alternate boron injection systems in order of preference but has not applied this to all the emergency procedure If a preferred order exists, it should be stated in the procedur '

(h) Paragraph 3.b., Local Procedures, identified difficulty in accessing manually operated valve The recovery procedure for instrument air was again walked dow As previously identified, the operator must stand on the service air piping in order to reach the cross-connect valv Operation of other manual valves in this area were similarly affected by requiring the operator to stand or climb on supports or other structures not intended for this purpos Ladders were located near the area but were locked in place and Operations does not have a ke Additionally, design modifications to correct this problem were requested but rejecte Communications in this area was difficult because of the background noise level and the distance to the page system. The use of hand-held radios was questioned, but

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the concern of inadvertent ' scrams prevent their 'us During emergency. operations . at a ' local ' area, - clear communications should be the overriding concer (i) Paragraph 3.c., Training, identified the lack of sufficient simulation fidelity during ATWS condition The licensee has implemented a program. to replace .the-

' deficient simulation models. This should correct the current simulation deficiencies with reactor water level, reactor pressure, and reactor power, In addition to the above items, a number of weaknesses and concerns were identified in Inspection Report No. 325,324/88-20 and are addressed below:

-(1)' Primary Containment Water Level determination: Procedure has been revised to direct installation of a temporary' gauge at the PASS cabinet. This allows the pressure at the 100' level to be determine The differential pressure between the 20' or 30'

level and the 100' level can then be calculated and the water

level determined from this dp. To determine the pressure 'at the 100' level, the operator is required to operate the PASS panel which is normally operated by Chemistry. Additionally, a plant modification to add a permanent pressure transmitter a the 100' level and install a meter in the control room will not be implemented until 1990 for Unit 1 and 1991;for Unit 2. The licensee has no plans to expedite this modification schedul (2) Calculations: When the draft E0Ps were reviewed by the inspection team, the licensee had not completed a calculation review which was in progress. The' licensee has since reviewed all calculations and updated the affected procedure (3) Non-EPG/ event specific steps: The licensee has reviewed the E0Ps either through simulator validation or walkdown to determine the effect of non-EPG steps of the E0Ps. The licensee is including this review in the justification for these steps in the E0P documentatio Observations during simulator exercise of E0Ps:

(1) During an ATWS, the SF was reluctant to place the Mode switch in SHUTDOWN as directed by the E0P The reasoning stated was to maintain the MSIVs open and use the main condenser as a heat sink. The E0Ps currently do not contain an allowance to leave the Mode switch in a position other than shutdown. If the Mode switch did remain in another position, this would result in a condition outside the analysis of the E0Ps. Additionally, it is unreasonable to assume the simulator response is correct since current simulation of ATWS conditions is marginal. This i item is consider a part of Inspector Followup Item 50-324,325/88-19-0 _ _ _ _ __ i

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- (2) When performing flowpaths for Primary Containment, Secondary Containment, and Radiation Release Control; the STA placed

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these _ flowpaths around the ERFIS terminal area. This action i

. obstructed access to ERFIS and - hindered personnel movement-through the control are Also, the STA's attention was n focused on these flowpaths and was unable to assist the SF -

in executing Paths 1 through In several cases, the Shift Operating Supervisor'. assumed the responsibility of the STA and assisted the SF. The STA directed control operator activities in response to these flowpaths and coordinated these activities with.the SF only after they had been executed. This

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has the potential for directing actions contrary to those on Paths 1 through 5. Also, there is no requirement for the.'STA to be licensed. . It would be inappropriate for non-licensed personnel to direct licensed activitie (3) During execution- of directed activities, the operators were directed by the SF to. align miscellaneous turbine support-equipmen This caused the operators to be distracted from the current activity and slowed progress through the flowpath The licensee should consider the necessity of these step (4): Two. training deficiencies were noted during the performance of the E0P ~

-(a) ERFIS does not alarm when Secondary Containment parameters exceed entry conditions. The STA did not enter Secondary Containment Control until prompted by the instructor that

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main steam tunnel temperature had_ exceeded the entry setpoint. Also, the simulator annunciators are marked to specifically identify entry conditions into Secondary Containment Contro The operator should have entered Seconda ry Containment Control without having to be prompte (b) The SLC and ARI keys were not kept in the key locker as specified by procedure. Instead, .these keys had been either placed in the E0P table drawer or included in the E0P key bag When the SLC key was placed in the simulator key locker, the operators checked the E0P table drawer and key bags but failed to check the key locker when the key could not be located. Additionally, the E0P

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I table cannot be locked the same as it is in the control room because the key has been los . Exit Interview An exit interview was conducted on January 27, 1989, with those persons indicated in paragraph I tbov The inspectors described the areas inspected ~ and discussed in detail the inspection results. Proprietary information is not contained in this repor Dissenting comments were not' received from the license _ _ _ = _ _ _ _ - _ - _ - _ _ _ _ _ - _ -

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9 i Acronyms ATWS Anticipatory Transient Without Scram ARI Alternate R0d Insertion E0P Emergency Operating Procedures EPG Emergency Procedure Guidelines ERFIS Emergency Response Facility Information System HPCI High Pressure Coolout Injection I&C Instrument and Control IFI Inspector Follawup Item LER Licensee Event Report OPA Operations Licensee Performance Assessment PASS Post Accident Sampling System PSTG Plant Specific Technical Guidelines MSIV Main Steam Isolation Valve SF Shift Foreman SLC Standby Liquid Control STA Shift Technical Advisor

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