IR 05000324/1990026

Safety Insp Repts 50-324/90-26 & 50-325/90-26 on 900701-31. Violations Noted.Major Areas Inspected:Maint Observation, Surveillance Observation,Operational Safety Verification, Onsite Review Committee & Onsite LER Review

ML20059H085
Person / Time
Site:	Brunswick
Issue date:	08/22/1990
From:	Prevatte R, Verrelli D NRC Office of Inspection & Enforcement (IE Region II)
To:
Shared Package
ML20059H079	List: IR 05000324/1990026 ML20059H075 ML20059H081
References
TASK-2.E.4.1, TASK-TM 50-324-90-26, 50-325-90-26, NUDOCS 9009140230
Download: ML20059H085 (12)

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as . UNITE 3 STATES

, ( NUCLEAR REGULATORY COMMISSION

[ REGION 11 h;

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-g 101 MARIETTA STREET.N.W.-

2 ATLANTA, GEORGI A 30323 -

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Report No.: 50-325/90-26.and 50-324/90-26-

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Licensee: Carolina Power and Light Compan *

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P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: -50-325-and 50-324 = License'Nos.: .DPR-71 and DPR-62 ,

Facility Name: Brunswick 1 and 2 -

Inspection Conducted: July-~1 - 31, 1990 Lead Inspectori hm h/Nio .;

roA R. L. Prevatte Date Signed-

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Other ln'spectors: W. Levis ,

D. J. Nelson Apprcled By: /dd /. 2.k9 g[ l D. PVVerrelli, Branch Cl)fef . K

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Date 51gnt!d Division of: Reactor Projects

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I SUMMARY

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Scope:

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This routine safety inspection by the. residentiins'pector'involvEdithe areas- of maintenance - :observati.on, surveillance obser~vation, operational safety-verification, onsite! review- committee 'onsite Licensee . Event Reports: (LER)

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review, action on previous inspection findings, followup on operator-l requalification and TMI action plan followup.-

Results: _

In' the: areas inspected one violation 'was identified. -- A valve that was required to be open was found'in the closed position in1the emergency diesel generator-

, fuel. oil system. A valve was found'in;the open position on. the CAD system i instead'of being in the required locked open position, paragraph (4b..

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An unresolved item was identified during a followup review-'of an open ' item onL

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the TMI L Action- P1an followup. This involved' theiability of the CAD- systemL power. supplies to. meet the single failure requirement. This item is currently  :

being reviewed by the NRC, paragraph '

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During the review of an unresolved-item involving the loss'of offsite p(wer to Unit 2 emergency -bus E3, it was determined _ that the licensee has initiated -

corrective action to address the event. However, it was noted that the stated ,

date for completion of' corrective action wastover-18 ' months from the event

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i occurrenc This delay did not appear ' to have been . assigned' a priority . . , ,l commensurate with the contribution that a loss of'offsite' power can' contribute' 'i '

to core damage risk as. identified-in the licensee's P.?A, paragraph ;

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REPORT. DETAILS l Persons Contacted

.i Licensee Employees ,

• K. Altman, Manager IRegulatory Compliance- ,

, F. Blackmon, Manager 0perations  !

E *S. Callis, On-Site Licensing Engineer- <

T. Cr.ntebury, Manager - Unit 1 Mechanical Maintenance -

G. Cheatham, Manager . Environmental' & Radiation Control

'M. Ciemnicki, Security-R. Creech,. Manager'- Unit 2 4&C Maintenance:

J. Cribb, Manager - Quality Control (QC) i

• Dorman, Manager - Quality Assurance (QA)/(QC) l V. Grouse,: Employee Relation '

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• J. Harness, General Manager;- Brunswick. Steam Electric Plant:

W. Hatcher, Supervisor - Security: '

l A. Hegler, Supervisor - Radwaste/ Fire Protection l

• R.-Helme, Manager:- Technical. Support

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J. Holder, Manager.- Outage. Management-& Modifications ,(0M&M)

L. Jones, Manager Procurement . l OH Jones, Manager - On-Site Nuclear Safety BSEP ,

R. Kitch6n,- Manager - Unit .2 Mechanical Maintenance

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J. Leviner, Manager - Engineering Projects:

• L. Nartin, Interim Manager -: Training'  !

J. McKee, Manager. .QA

• J. Moyer, Technical Assistant =to Plant General Managerc-B. Poteat, Administrative Assestant to Plant. General: Manager- >

R. Poulk, Manager - License Trainin "

• W. Simpson, Manager - Site Planning and Control S. Smith, Manager - Unit 1 I&C Maintenance

• R. Starkey, Vice President - Brunswick Nuclear Project

• J. Titrington, Manager - Operations-

• R. Warden, Manager - Maintenanc B. Wilson, Manager - Nuclear. Systems Engineering -

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Other licensee l euployees contacted included construction > craftomen,-

enginears, technicians, operators, -office personnel', and security' force members,

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• Attended the exit interview-Acronyms and initialisms used in the report are listed in --the last" paragrap ,

, MaintenanceObservation'(62703)

The inspectors observed maintenance activities, interviewed personnel, and reviewed records to verify that , work. was. conducted in accordance with'

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h approved-- procedures.: Technical. Specifications and applicable;in'dustry '

codes-- and standards.;- The- inspectors also, verified : that: redundant

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cv90nents'were operable; administrative- controls were followed; tagouts- j were adequate;-personnel:were qualified; correct' replacement parts wereL used; radiological- controls were proper; . fire- protection was adequate; t quality: control! hold - points' were . adequate ~ and observed; adequate '

post-maintenance testing was- performed; and independent verification .

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j requirements were implemented. The inspectors independent 1y' verified that' l selected equipment' was properly returned to service.' ]

Outstanding work requests:were' reviewed'to ensure that1the licensee gave'- l priority-to safety-related maintenanc The inspectors obsarved/ reviewed' portions of the- following maintenance I activities: -

t LStuck~ Rod 02-35, Unit 2

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OP 7.Section CRD Flush Rod 02-35, Unit 2- .

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90 AHJH1 CAC 4410'S0V Replacement- .

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90 AMPH1 .RWCU/HPCI Logic Troubleshooting ,

Violations and deviations were'not identified. .  ?- '

' Surveillance Observation .(61726) s:

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The inspectors observed ' surveillanca testing required; by Technical; ,

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Specifications. Through ' observation, interviews,' and record review, the X l

inspectors - erified that:- tests conformed. to Techhical Specification requirements; administrative controls- .were followed; ' personnel: were qualified; instrumentation' was calibrated;- and data was accurate an ~

I complete. The inspectors independently verified selected test results and-proper return to serv. ice of equipmen '

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The inspectors witnessed / reviewed portions' _of - the following.: Ltest

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activities: ,

a Main Steam Line High Radiation Channel FunctionaliTe'st'

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1 MST RPS 11W-2 MST APRM 22Q APRMB'and LPRM Group-B Channel Calibration = Functional- J Test 2 PT SLC'SystemOp'erabilitsTest 1 PT 10. RCIC System-Operability Test ,' .

2 PT 1 Control Rod Operability Check 1 PT 7.2.4A CoreSpraySystemOperabilityTestL-LoopfA Violations- and deviations were not identified.- 9 i OperationalSafetyVerification(71707)-

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The inspectors verified that Unit 1 and Unit 2 were; operated in compliance with Technical Specifications and other regulatory' requirements by direct 4

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observations of activities, facility tours, discussions with personnel, !

reviewing of records and independent verification of safety. system status.- l-t The inspectors verified that control room manning requirements of 10 CFR 50.54 and the technical specificatior-S were met. Control operator,

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shift supervisor, clearance, STA, daily anu standing instructions, 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 Techrical Specifications Limiting Conditions for- ;

Operation Direct observations of control room _ panels and instrumentation and recorder traces important to safety were conducted to ,

verify operability and that operating parameters were within Technical Specification limits. The' inspectors observed shift turnovers to verify that system status continuity was maintained. The inspectors verified the ,

status of selected contro1~ room annunciator !

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Operability of a selected Engineered Safety Feature ' division was verified =

weekly by insuring that: each accessible valve in the-flow path was in its correct position; each power supply and breaker was closec for components that must activate upon initiation signal; the RHR subsystem -,

j cross-tie valve for each unit was closed with the power removed from the-t valve operator; there was no leakage of major components;'there was proper lubrication and cooling water available; and conditions did not exist which could prevent fulfillment of the system's functional requirement Instrumentation essential to system actuation or perforniance was . verified ,

operable by observing on-scale in)ication and proper instrument valve lineup, if accessibl The inspectors verified that the licensee's health physics policies /prc:edures were followed. This included observation of HP  !

practices and a review of area surveys, radiation work permits, postings,

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and instrument calibratio The inspectors verified by general observatiens that: the security organization was properly manned and security personnel were capable of performing their assigned functions; persons and packages were checked prior to entry into the protected area; vehicles were properly authorized, searched and escorted within the PA; persons within the PA displayed photo identification badges; personnel in vital areas were authorized; effective compensatory measures were employed when required; and security's respoese to threats or alarms was adequat The inspectors also observed plant housekeeping controls, verified i position of certain containment isolation valves, checked clearances, _and verified the operability of onsite and offsite emergency power source , The inspector reviewed NRC form 396 for selected operators to ensure that the licensee was complying with the medical requirements of

'10CFR5 The inspector found in all records reviewed that the ;

licensed operators had received a medical examination within the required 2 year time period. Training depm tment persvael were also ;

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i aware of the last date of the physical exam for each operator an I which personnel were due for an exam. The inspector questioned two i cases which may require that the . license be amended to include =  ;

restrictions. . One. case concerned an individual who did not appear to' l meet the uncorrected vision requirements. ' This individual does not currently perform licensed dut ts. In the past the inspector had  ;

observed the operator wearing torrective lenses. The .second  ;

individual had a past history os fainting' spell The problem ha :

not occurred within the last year'and was evaluated by the licensee's-  !

doctors. as satisfactor These two cases were referred ' to the- '

Operator Licensing Section in Region 11 for resolutio i The inspectors also found that nearly half-of the valid licensed 1

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operators were not respirator qualified. Qualifications of these individuals had lapsed due to the failure of the operators to attend  !

classroom training or take'a mask fit test within the required time period. . The inspector is not aware of any regulatory requirements explicitly requiring this qualification but felt that it' may, be i necessary to wear this protective clothing during some emergency  :

conditions. Licensee management stated that it was their policy that -

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the operators be respirator. que11fied and that the failure of the  ;

op?rators to _ keep their qualifications- current was an oversight. The j operators have' been. directed to update their. qualification, i September 14, 1990 has been set for the completion of these action ! On July 27, 1990, an NRC inspector found valve 2 F0D V61, #3 4 day tank to fuel oil transfer < pump A isolation. valve, closed instead of-open as required by the OP.39, Diesel Generator Operating Procedur R45 valve lineup. The inspector informed the L' nit 2 C0 of this '

condition and the valve was returned to the open position. Clearance  :

2-90-1569 had previously been issued on this system to allow the removal and' repair of the pump's relief valve. The. relief. valve had been reinstalled and the clearance rWoved on July 23, 1990. 2.F00.

l V61 was not included in the clearance and was outside of the clearance boundar Although the relief valve was reinstalled, the fuel' oil transfer pump was still considered to be. inoperable and under a tracking LC0 because the WR/JO had not been closed out. The inspector noted, however, that the pump would have started on low-low f saddle tank level. The B fuel oil transfer pump was operable during this time perio The licensee had not determined the cause of the valve being in the incorrect position. Licensee procedure 01-13 Valve and Electrical lineup Administrative Controls, R28, section.4.6 requires that all  ;

valves be maintained in the position required by the.0P valve lineup-  !

i except for these valves under clearance as being operated in the course of an approved procedure. The failure to maintain valve 2 F00 V61 in its correct OP valve lineup is a Violation 324-90-26-01, Valve Position Not In Accordance With OP Valve Lineu l

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i On July 30, 1990, the inspector, accompanied by the CAC system I engineer, found valve CAD'NP-V3, CAD Loop A Shutoff Valve, not locked l as required by 20P24, Containment Atmosphere Control System Operating Procedure R92. The SF was informed'of this condition and the valve- -

was verified to be open and then locked. The licensee could not ,

immediately determine why the valvo was not' locked in the open -

position and have initiated a Plant Incident Report to_ determine the i cause. The failure to maintain this valve in 1,he required locked "

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position is a violation and is listed as the srecond example of th<

violation noted above. The two failures to adtquately control */' * r position is a repeat problem and was previously cited in report 69-26 l

' dated November 6, 198 !

! OnsiteReviewCommittee'(40700)

The inspectors attended selected Plant Nuclear Safety Committee trcetings !

contacted during the period. The inspectors ' verified. that the meetings were conducted in accordance with Technical Specification requirements regarding quorum membership review process, frequency and personnel t i qualification Meeting minutes were reviewed to ' confirm that ;

decisions / recommendations were reflected in the' minutes and followup of ;

i corrective actions was completed, r r

l Violations and deviations were not. identified.

' OnsiteReviewofLicenseeEventReports'(92700) 1 The below listed LERs were reviewed to verify; that the .information: . '

provided met NRC reporting requirements. ' The . verification = included adequacy of event description and _ corrective action taken or planned, existence of potential generic problems and the relative safety-significance of the event. .0nsite inspections were performed and concluded that necessary corrective actions have been taken:in accordance with existing requirements, license conditions and commitments, unless otherwise state (CLOSED) LERs 1-88-011 Inoperability of High Pressure Coolant Injection

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System Resulting From Failure of HPCI Pump Suppression Pool Suction Supply Outboard Isolation Yalve E41-F341; 1-88-012, Inoperability of High- -

Pressure Coolant Injection Systems Due to' Failure of HPCI Turbine Steam Inlet Isolation Valve E41-F001, During Operability Testing; 1-88-019.- ,

Inadequate Design of High Pressure Coolant Injection Pump Discharge Valve E41-F00 The above LERs dealt with the inoperability of the Unit.1 HPCI System due' :

to valve failures or potential valve failures caused by design deficiencies. The particular deficiencies, other inspections and licensee -

corrective actions are discussed in report'89-02 dated February 2,~198 ;

Based on these previous inspections these LERs :will be closed. Further ;

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J inspections in 'this area will be performed in the closecut of IFI )

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(CLOSED)LER2-88-08, Full Reactor Protection System Trip Resulting From A  !

i Downscale Inoperative _ Trip of APRM Monitor D With Reactor Protection -

System Shorting Links Removed. During the 1988 refueling outage a full reactor protection system trip occurred when the mode switch of APRM D was rotated beyond the switch mechanical stop position. This energized-the '

monitor inoperative circuitry. .Since the RPS shorting links were removed, An investigation- revealed that an

this resulted in a full RPS tri incorrectly . configured, i.e., a~ two-deck six position versus a two-deck five position, switch was installed due to a procurement error. A search i for other potentially generic or similar installations identified that an- l incorrect switch had also been installed in APRM F meter panel.- The i'

switch for APRM D was replaced and the function switch for APRM F was properly reconfigured. As a part of the corrective action GE has agreed ,

to provide warning labels on switches to. identify switches that are '

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adjustable anc' may require a configuration check or adjustment before installatio (CLOSED) LER 1-88-20, RCIC System Isolation with PCIS Group V Actuation on

"B" Logic Channel During RCIC System test. This event occurred during the performance of RCIC System Operability test PT-10.1.1. Investigation by  ;

the licensee determined that this resulted from a malfunction of the speed *

sensing circuit. Further investigation revealed that the speed sensor and connector had probably been damaged by personnel either stepping or climbing on these components while performing work activities in the ,

general area. The inspectors reviewed the licensee's corrective actions i l stated in the LER. They appear adequate to either reduce the' probability  ;

L or prevent future occurrences of this ite Violations and deviations were not identifie +

7 Action on Previous Inspection Findings (92701) (92702)  ;

(CLOSED)URI 325,324/89-40-02, Fire Protection Sprinkler. Actuation During -

HELB May Affect EQ Components Previous inspection of this item is contained in report 89-4 The inspectors reviewed EER.90-0031, dated February 16, 1990, and EER 90-0113, dated May 26, 1990, which evaluated the operability of the. leak detection .

system for HPCI and RCIC and the effects of sprinkler activation on safety l related equipment located in the Reactor Building. The evaluation included the walkdown results of affected equipment along with supporting tests and disposition of discrepant-conditions. The licensee concluded ,

that the leak detection. systems were operable and that the appropriate design features which 'would prevent moisture intrusion had been satisfactorily implemented. In addition, the licensee has changed the'

sprinkler heads in the North and South RHR rooms with ones rated at 212  :

I degrees F. Compensatory measures are in place to preveni flooding of the .

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ECCS room A PID will be initiated by December'1990,-to permanently -

resolve the flooding issu l Inadvertent actuations of fire suppression equipment and its effect on ,

safety related equipment is currently being addressed by the NRC as !

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Generic Issue 57. The issue is listed as.high priority with a task action }

plan. scheduled to be in pir.ce by July 1992. ' Based on this continued ,

review by NRC and actions taken by the licensee to date, this -item is -

closed. Further inspections could be performed at the completion of NRC '

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review of the issu (CLOSED)URI 325, 324/90-17-03, Loss of Offsite Power to Unit 2 Emergency Bus E3. This event occurred on May 30, 199 This item was also ,

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discussed in Report 325,324/90-19. The licensee concluded -that the root !

cause of this event was personnel error. After opening a knife switch to

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deenergize the watt transducer for removal, 'the transmission maintenance and onsite maintenance technicians checked for voltage .and found the transducer still Suspecting a wiring error, the two

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energize technicians disconnected the energized transducer instead of investigating the reason for the =till present voltag The knife switches were unlabeled and the incorrect one was opened to isMate the transducer. The j inspector concluded that no violation occurred, however, the technicians :

demonstrated careless disregard of rudimentary workmanship practice l The licensee acknowledged that there was' a lack of- agreed definition of responsibilities between the Transmission Department and Onsite 1

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Maintenance as to which group had responsibility for this equipment. The ;

l result was a combined effort with neither group clearly in charge. The !

technicians considered each other to be the. system expert. This grou !

interface work control problem was a contributor to the June, 1989 Loss of !

Offsite Power (LOOP) event in which errors by Transmission Department !

personnel caused the loss of the Unit 2 SAT.(Described in LER 2-89-009).

l Corrective action for that event -included review and ' revision of the switchyard work interface document. This was not completed at the time of the May, 1990 LOOP to E3 even This event placed increased emphasis on the interface document and a '

general interdepartmental procedure, Division of Responsibilities with i Respect to Maintenance of Substation, Relay, and Control Equipment at Generating Plants, was issued July 2,1990. . Additional site-specific ,'

interfaces are still under development. Had this been completed prior to the May,1990 event, clearer responsibilities would have been defined for the watt transducer work - perhaps preventing the event. The inspector noted that the licensee's connitment for completion of corrective action for the June 1989 event is February,199 The NRC is particularly interested in the corrective actions associated with Loss of Offsite Power events. LOOP accident sequences were determined ta be a significant contributor to core damage risk in the PRA stud Od the total core damage frequency (CDF), 38% was due to LOOP l .

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sequence The inspectors will , closely monitor the OPEN corrective i actions in this area until completed, j Confirmation of Action: FollowuponOperatorRequalification(92703)  !

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An operational evaluation of two shifts was conducted on July 23-26, 199 As a result of this evaluation the licensee gained sufficient licensed !

, operators to increase shift manning to five shifts. The details and l results of the above-evaluation'are contained in report 324/0L-90-0 l l TMI Action Plan Followup (25565)

(OPEN) Item II.E.4.1 Dedicated Hydrogen Penetrations -

Licensee letters dated April- 30, 1985 and January 27, 1986 requested license amendments for Units o 1 and 2 respectively, to reflect modifications made to the' containment atmospheric dilution system' to conform to the requirements of. NUREG 0737. Item II.E.4.1. Amendment 91 was approved for Unit 1 on September '0,1985 and . Amendment 125 was approved for Unit 2 on May 5,1986 to railect the necessary Technical'

Specification changes to accommodate son aciditional components. The CAD'

system is used during accident conditions to control combustible gases inside primary containment by providing an injection path for' nitrogen-addition to maintain oxygen concentration less than.5% and a vent path to pm it primary containment internal pressure from exceeding 'one half of desh pressure. As stated in section 6.2.5.2.1.2.2 the system. is designed with suitable redundancy and interconnections such that no single i failure of an active component will render the system inoperabl The inspretor verified that programs and procedures were developed for the

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CAD system. Operating procedures, annunciator procedures and emergency

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operating procedures have been developed and implemented. Surveillance test procedures are also in place' for satisfying the. technical I specification surveillance requirements of ~ technical specification 7.6.6.2. The inspector identified procedural problems where 2 CAC HVII and 2 CAC HV12, CAD tank pressure build up coil inlet valves are normally shut by the OP valve lincup. The valves must be open when the sb tem is in operation to maintain tank pressure at-about 85 nsig. No guidance is provided in the system operating procedures to open these valves when placing the system in service. Section 6.2.5.5 of the FSAR states that l tank pressure is automatically controlled by redundant pressure build up.

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coils. Operations training materials and the-system description state that the pressure control valves are normally in service. The valves are

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shut to aid in preventing high tank pressure. The licensee is currently evaluating the need to leave the valves open or provide the necessary procedural guidanc The inspector reviewed power supplies for. selected components and l

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inspected accessible components to determine.if single failure criteria were satisfied and to assess system operability the foll_owing discrepancies were found:

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I, o, The failure of E-6 will render both injection paths inoperable due to I the power supply arrangement to the vaporizers and vaporizer inlet !

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and flow control valves. This condition affects both units (50.72 report made July 25,1990). i o The failure of E-8 will render the vent path for Unit 2 inoperable since 2 CAC-V49 is under clearance and' deenergized in the closed position. The valve is under clearance due to a ground and has been ,

tagged out since March ~ 11, 199 Initial licensee attempts'to clear '

the ground by cleaning the junction box have improved the ground but ,

not sufficiently to clear the ground ala o Check valves 2 A0G-RA-V522, 523 which isolate the safety related air '

system from the nonsafety related air system were tested on January 20, 1990 in response to GL 88-14 and both were found to be stuck in '

the open position approximately 1/2" off the seat. The valves were repaired but no operability or reportability determination was mad t The -valves are not yet on a; periodic inspection schedul !

o Check valve 2 A0G-NP-V083 which must open to supply the safety grade nitrogen as the pneumatic source to CAD components has not been 1 teste '

Based on the above discrepancies the inspector concluded that the licensee did not meet their commitments regarding TMI item II.E.4.1 in that the .

system was not designed, installed and operated such that single failure ,

criteria were satisfied. The. licensee declared the system inoperable on

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July 25,1990 based on the power supnly concerns and are currently >

evaluating the systems ability to perform its design function. This matter will be Unresolved pending licensee evaluation and disposition of the above items and subsequent NRC review.. URI 325, 324/90-26-02, CAD :

System Does Not Meet Single Failure Requiremen . ExitInterview(30703)

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.The inspection scope and findings were summarized on August 3, 1990,

! with those persons indicated in paragraph 1. The inspectors described the [

l areas inspected and discussed in detail the inspection findings listed below. Dissenting comments were not received from the license '

Proprietary information is. not contained in this repor '

Item Number Description / Reference Paragraph-324/90-26-01 Violatio Valve Positions Not In Accordance #

With OPS Valve Lineu Paragraph 4b 325,324/90-26-02 Unresolved Item. CAD System Does Not Meet Single-Failurc Requirements. Paragraph 9 i

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l 11. Acronyms'and Initialisms

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i L A0 . Auxiliary Operator BSEP Brunswick Steam Electric Plant [

ESF Engineered' Safety Feature i F Degrees Fahrenheit l HP Health Physics i

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18C Instrum1ntation and Control IE NRC Office of-Inspection and Enforcement IFI Inspector Followup Item ..

i IPBS Integrated Planning, Budgeting and Scheduling LER Licensee Event Report i NRC Nuclear Regulatory Commission PA Protected Are PNSC Plant Nuclear Safety Committee QA Quality Assurance '

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QC Quality Control RHR Residual. Heat Removal STA Shift Technical Advisor i

TS- Technical Specification URI Unresolved Item i

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