IR 05000324/1993049

Insp Repts 50-325/93-49 & 50-324/93-49 on 931009-31. Violations Noted But Not Cited.Major Areas Inspected: Maintenance,Operations,Onsite Review Committee & three-year Plan

ML20058J621
Person / Time
Site:	Brunswick
Issue date:	11/24/1993
From:	Christensen H, Prevatte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058J605	List: IR 05000324/1993049 ML20058J600
References
50-324-93-49, 50-325-93-49, NUDOCS 9312140177
Download: ML20058J621 (11)

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UNITED STATES f#pn pic*% NUCLEAR REGULATORY COMMISSION g* -~ t REGtON 11

O 101 MARIETTA STREET, N.W., SUITE 2900 5

: y ATLANTA, GEORGIA 30323-0199

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Report Nos.: 50-325/93-49 and 50-324/93-49 '

Licensee: Carolina Power and Light Company '

P. O. Box 1551 Raleigh, NC 27602 l

Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 i

Facility Name: Brunswick I and 2 Inspection Conducted: October 9 - October 31, 1993 '

Lead Inspector: [ k ///L3/f7 !

R.L.Prevhtte,SeniogesiffntInspector Date Signed Other Inspectors: P. M. Byron, Resident Inspector  !

M. T. Janus, Resident Inspector (in training)

Approved By: , # td; @

H. 0.Christensen, Chief Date Signed Reactor Projects Section lA Division of Reactor Projects SUMMARY Scope:

This routine safety inspection by the resident inspectors involved the areas of maintenance, operations, onsite review committee, Three-Year Plan, and action on previous inspection finding Results: ,

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In the areas inspected, a non-cited violation for an inadequate clearance on the Augmented Off Gas system on Unit I was identified. This event, which was on a unit ;

that was shutdown and defueled, had minimal safety significance (paragraph 4). A l strength was identified in the strong proactive approach taken by the licensee to assure the quality of shroud repairs and to keep their staff informed on the status *

of these repairs (paragraph 7).

Unit I continued in the outage that began on April 21, 199 Unit 2 was operated at essentially full power for the reporting perio i l

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REPORT DETAILS-

, Persons Contacted  ;

Licensee Employees 1

K. Ahern, Manager - Operations-Support and Work Control  ;

R. Anderson - Vice-President, Brunswick Nuclear Project

• G. Barnes, Manager - Operations, Unit 1

• P. Beane, Manager - Quality Control  ;

E. Blackmon, Manager - Radwaste/ Fire Protection

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• M. Bradley, Manager - Brunswick Project Assessment

• J. Cowan - Plant Manager, Unit 1

• R. Godley, Supervisor - Regulatory Compliance .

• R. Grazio, Manager - Brunswick Engineering Support _Section

• J. Heffley, Manager - Maintenance, Unit 2 .

• G. Hicks, Manager - Training t

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• C. Hinnant - Director of Site Operations

• P. Leslie, Manager - Security

• Levis, Manager - Regulatory Affairs (Acting) .

R. Lopriore, Manager - Maintenance, Unit 1 [

G. Miller, Manager - Technical Support

• C. Robertson, Manager - Environmental & Radiological Control *

• J. Titrington, Manager - Operations, Unit 2 C. Warren, Plant Manager - Unit 2 G. Warriner, Manager - Control and Administration E. Willett, Manager - Project Management Other licensee employees contacted included construction craftsmen, engineers,

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technicians, operators, office personnel and security. force member * Attended the exit intervie Acronyms and initialisms used in the report are listed in the last paragrap . Maintenance (62703) (61726)

, Maintenance Activities

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The inspectors observed maintenance activities, interviewed personnel, 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 :

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followed; tagouts were adequate; personnel were qualified; correct replacements 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 ;

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Outstanding work requests were reviewed to ensure that the licensee gave priority to safety-related maintenance. The inspectors observed / reviewed portions of the following maintenance activities:

i WR/JO 93-BBMK1 1A Service Water Lube Water Pump Repair ;

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WR/JO 93-BBQR1 IB RFP Oil Leak Repairs i WR/JO 93-AEHY1 Unit 1 Jet Pump Flow Test WR/JO 93-ARPG1 Replace Seal on Pre Lube Oil Pump on DG No. 3 WR/JO 93-BCUU1 Investigate & Repair Leak on Unit 1 NSW Header

WR/JO 93-ABGCl Replace 3R and 8R ruel Injector Pipe Assemblies l on DG No. 3  !

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WR/JO 93-AFHG1 Troubleshoot & Repair Low Service Water Pressure >;

on Unit 2 l WR/JO 93-BBRIl Troubleshoot & Repair Unit 2 Hydraulic Control Units PM 82-220L Replace 2A NSW Pump PM 89-001 Digital Feedwater Control System. Installation on Unit 1 l The inspector observed the above work activities and noted that the observed portions of that work was performed by knowledgeable and professional personnel, current revisions of procedures were available and in use at the work site, there was adequate craft and engineering support for these activities, and all work was completed in a timely j manne ;

i b. Temporary Leak Sealant Repairs  ;

Due to recent problems at other nuclear sites involving temporcry leak sealants, the inspectors reviewed the licensee's process. The licensee uses temporary leak sealants to repair leaks on both safety and nonsafety-related equipment. Leak Repair Incorporated (LRI) provides the sealant material and installs the material using their procedure i Leak sealant applications are maintenance activities which are i considered temporary repairs. LRI controls the process and their '

engineering personnel provide a safety review for the applicatio Additionally, the licensee writes an EER for each temporary repair. An ;

expiration date for the temporary repair is included in the EER. LR1 is

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an approved vendor and their QA program has been audited by the  :

licensee's Quality Verification Sectio i The inspector reviewed two recent EERs 93-0420 (Packing Stuffing Box !

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Repair for 2-MSV-37 and 93-0464 (Packing Stuffing Box Repair for 2-MSV-

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47). The evaluations were found to be adequate, with expiration dates for the repairs being in the next refueling outage. Maintenance witnesses the installation and participates in the post maintenance testing. The inspector interviewed the Unit'l and Unit 2 maintenance ;

managers and determined that they were knowledgeable of temporary leak I sealant applications and any significant issues resulting from their !

use. Additionally, NAD had not performed any assessment of the use of i temporary leak sealants. The inspector also determined that the  :

licensee had switched vendors several years ago because of problems i associated with that vendor's product. No problems have been noted with !

the current vendo Violations and deviations were not identifie ! Surveillance Observation  !

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The inspectors observed surveillance testing required by Technical Specifications. Through observation, interviews, and record review the ,

inspectors verified that: tests conformed to Technical Specification i requirements; administrative controls were followed; personnel were qualified; instrumentation was calibrated; and data was accurate and '

complete. The inspectors independently verified selected test results >

and proper return to service of equipmen On October 16, 1993, while performing 2MST-RHR25M, RHR Pump Discharge !

Pressure ADS Permissive Instrument Channel Calibration on Unit 2, an +

unanticipated ADS alarm annunciator was received in the control roo !

Plant parameters were verified to be normal and the operators inhibited the ADS logic to prevent an inadvertent depressurization. This rendered ;

the ADS system inoperable and placed the licensee in a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> LCO (Technical Specification 3.5.2.b). Licensee investigation of the problem revealed that an I&C technician had improperly installed a volt-ohm meter (V0M) in the a rcuit being tested. The V0M was placed on the ,

correct terminals, but the technician had selected the resistance scale rather than the DC volt scale. The voltage from the VOM caused the ADS relay to energize. The technician recognized his mistake and notified I the control room. The licensee restored the ADS system to service 31 '

minutes after the problem occurred. The licensee counselled the I&C J technician on the correct use of this test equipment. The technician's acknowledgement of his error enabled the licensee to save considerable time in identifying and correcting the problem. This reflects a change ;

in craft attitud l l

Violations and deviations were not identifie . Operations (71707)

The inspectors verified that Unit 1 and Unit 2 were operated in compliance l with Technical Specificat'.ons and other regulatory requirements by direct i observations of activities, facility tours, discussions with personnel, l reviewing of records and independent verification of safety system statu !

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The inspectors verified that control room manning requirements of 10 CFR 50.54 and the Technical- Specifications were me Control operator, shift ,

supervisor, clearance, STA, daily and 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 Technical Specification Limiting Conditions for Operations. Direct observations of control room panels, instrumentation and recorded 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 also verified the status of selected control room - ;

annunciator .

Operability of a selected Engineered Safety Feature division was verified weekly by ensuring that: each accessible valve in the flow path was in its ;

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correct position; each power supply and breaker was closed for components that must activate upon initiation signal; the RHR subsystem cross-tie valve for ,

Unit 2 was closed with the power removed from the valve operator; there was not 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 requirements. Instrumentation essential to system actuation or performance was verified operable by observing on-scale '

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indication and proper instrument valve lineup, if accessibl The inspectors verified that the licensee's HP policies and procedures were i followed. This included observation of HP practices and a review of area surveys, radiation work permits, posting and instrument calibratio _,

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The inspectors verified by general observations 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 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; effective compensatory measures were ,

employed when required; and security's response to threats or alarms was :

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adequat The inspectors also observed plant housekeeping controls, verified position of certain containment isolation valves, checked clearances and verified the operability of onsite and offsite emergency power source Opening of Valves Under Clearance j On October 11, 1993, clearance number 1-93-2390 was implemented to perform ;

work on the Unit 1 Augmented Off Gas (A0G) System Loop Seal Reservoir i Equalizing Valve, 1-G16-V1383. This system was out-of-service, and the Unit ;

was shutdown and defueled. The clearance had been completed in the field by Operations, but had not been accepted by Maintenance. On October 13, operators in the control room noticed that three of the valves under i clearance (1-A0G-FV-244-1,1-A0G-FV-244-2, and 1-A0G-FV-244-3) were indicating open, contrary to the clearance which required them to be close ,

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Investigation by Operations revealed that the valves were open. The valves had drifted open after being closed by the clearance two days eari;er. The clearance had been accomplished by isolating the air- ,

supply to these air operated valves, and the resultant slow bleed down 2 of air had caused the valves to slowly drift open. The investigation ;

revealed that the valves were air to close, rather than air to open as shown on the clearance for Based on this discovery, on October 13, the senior control operator (SCO) pulled the clearance and restored the ,

system back to its original status. The SCO also initiated a Minor i Adverse Condition (MAC) report to document this issue and track the '

corrective actions. The MAC was later upgraded to an Adverse Condition _

Report (ACR) based on the results of a preliminary revie l The licensee initiated a detailed investigation into the steps involved in preparing the original clearance. This revealed that the clearance

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was written using the Equipment Database System (EDBS) as the only .

source of data for the valves involved in the clearance. The data *

provided to the clearance writers by EDBS was incorrect. The valves in !

question were specified in EDBS as air to open valves rather than air to clos l The data obtained from EDBS is uncontrolled, generally known to contain i errors, and is used only as a referenc The data fields used by the ;

clearance center are not verified nor are they maintained as controlled documents. The use of the EDBS data in the establishment of this i clearance was not in accordance with AI-58, Equipment Clearance -

Procedure. Section 5.3.1.5 requires the use of plant piping and ;

instrumentation diagrams (P& ids) in the generation of clearances with a l fluid boundary. The above procedure also requires that plant drawings !

used for clearances are to be verified correct using the Nuclear !

Revision Control Syste i The licensee responded to this event by developing and implementing a ,

series of short and long-term corrective actions. To date the licensee has briefed clearance center personnel on the event and the limitations .

of EDBS information. Future actions include: real-time training for !

Operations personnel on the acceptable uses of EDBS in developing clearances; clarification of the acceptable uses of EDBS in the ;

clearance preparation procedure, Al-58; removal of uncontrolled valve i failure information from EDBS; and restoration of validated / controlled !

valve failure information to EDBS for safety and nonsafety-related

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valves. These actions are scheduled to be completed by June 30, 1994, for the safety-related valves, and March 31, 1995, for the nonsafety- ,

related valves. The inspector has reviewed and discussed these :

corrective actions with the licensee and finds them acceptabl The failure to implement the requirements of AI-58 in the est .olishwnt )

of clearance 1-93-2390 is identified as a Violation of Tecnnical !

Specification 6.8.l(a) Inadequate Clearance (50-325,324/93-49-01). j However, this violation will not be subject to enforcement action l l

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i because the licensee's efforts in identifying and correcting the violation l meet the criteria specified in Section VII.B. of the Enforcement Polic ;

One Non-cited Violation was identifie . Three-Year Plan i The inspector reviewed the licensee's Three-Year Plan monthly management l report for September 1993. Initiatives completed during September included: i establishment of an Integrated Planning and Scheduling Organization (TY 101), j development of a corrective maintenance backlog definition and Work Control ;

Priority System (TY 103), and awarding the contracts for construction of new :

facilities (TY 206). The physical work on the Technical Training Center,

Operations / Maintenance Building, Sewage Treatment Plant, laundry and Material Storage Building, Snubber Rebuild Shop, and the Hot Calibration Shop is scheduled to begin shortly, with completion and occupancy scheduled for the ;

Fall of 199 l

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The design of LPRM cable replacements for the Unit 2 drywell has been ]

rescheduled to allow incorporation of lessons learned from the Unit 1 '

installation. The design phase of the drywell radiation monitors was also delayed because this project was transferred from Nuclear Engineering to i Technical Support. Overall,16 of 26 activities scheduled for-completion in September were completed. Also, 12 activities were completed ahead of ;

schedule and 2 previously late activities were also completed. There are J currently 22 initiatives and 67 projects in proces The inspector reviewed the status of the licensee's initiative TY 501, l Preventive / Predictive Maintenance Program Improvement The purpose of the j initiative is to enhance the preventive maintenance program by reconstructing the Preventive Maintenance (PM) basis for applicability and effectiveness and performing engineering assessments on PM exceptions and revision request This project will also create a structure to support the corporate initiative for the maintenance rule and develop a predictive maintenance program to evaluate equipment and component conditions through the use of vibration, lube oil analysis, and infrared thermography. The above initiative has over 25 individual tasks assigned. Several of these tasks are underway and the entire initiative will extend over several years until completion in 1995. For review, the inspector selected task 4A since it is cerrently underway and receiving considerable management attention. This task involves Reliability Centered Maintenance (RCM), which is a systematic methodology used to develop or optimize a new or existing PM program. The objective of the RCM initiative is to optimize the PM program by ensuring that it consists of the right PM tasks being performed at the right frequenc l l

A licensee review of the PM program found that they were performing over i 19,000 component PMs that took 181,770 man-hours to complete each yea ~

A i industry review by the licensee also found that similar plants are performing a approximately 12,000 PMs per year. The licensee has established a goal to reduce the PM and PM man-hours by approximately 1/3 by 1995. The focus will be on man-hours and RCM will play a major role in this effort. In addition, ,

the plant currently has greater than 100 PM frequencies. This PM initiative '

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will also seek to reduce the PM frequencies to approximately 28 by mid-199 This task has currently reduced the frequencies to 41 for Unit 2 and 47 for Unit 1. The licensee hopes that the man-hours gained from these efforts can be refocused to other plant improvement The licensee has developed a plan and schedule to complete RCH for 28 dual unit systems. Four dual unit systems (Residual Heat Removal, Feedwater/

Feedwater Control, Condensate, and 480 VAC Distribution) are scheduled to be completed by CP&L and a consulting contractor by January 1994. The remaining 24 dual unit systems are to be completed by December 1995, on a semi-annual basi The above work will have four CP&L employees and four contractors for the first four systems. This will allow CP&L personnel to learn the methodology and become knowledgeable on the associated computer systems and softwar After the first four systems are completed, the succeeding systems will be done by CP&L (without contractor assistance) based on a priority.that includes:

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core damage frequency

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radiation exposure

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system maintenance cost in 1992

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megawatt loss by system from plant performance data system for past years The licensee started RCM analysis on the first four systems on September 12, 1993. The inspector discussed the progress on these systems with the manager assigned to this task. It appears to be on schedule. The licensee believes that this system will allow them to focus their resources on the right preventive maintenance activities and that this will result in better utilization of manpower and monetary resources to provide improved plant reliability and safety. The concepts and ideas behind this initiative appear to be reasonable and sound. The implementation of this initiative indicates-management's commitment to improve the plant maintenance progra The inspector will follow this project and report as major milestones are reache . Onsite Review Committee (40500)

The inspectors attended Plant Nuclear Safety Committee meetings on the following dates October 7, 20, 22, and 28. The inspectors verified that the meetings were conducted in accordance with Technical Specification requirements regarding quorum membership, review process, frequency and personnel qualifications. Meeting minutes were reviewed to confirm that decisions and recommendations were reflected in the minutes and followup of corrective actions was complete There were no concerns identified relative to the PNSC meetings attended. The resolution of safety issues presented during these meetings was considered to be acceptabl . . . . .

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! Action on Previous Inspection Findings (92701) (92702) I (0 pen) Ifl 93-33-03, Cracks in Core Support Shroud. The licensee has completed the visual and ultrasonic inspection of the core support shrou )

However, they continue to review the tapes of the visual inspections and plan 1 to re-examine questionable areas if needed. Base line depth and length information was obtained on two selected H-5 weld areas with the UT scanner for future growth reference. The ends of the selected H-5 circumferential cracks were also punch marked for future visual growth referenc GE is designing the modification.(PM93-038) for the permanent repair of the l

shroud. This includes the design and fabrication of the support blocks and :

associated repair equipment. The licensee has dispatched personnel to the l vendor's facilities to oversee the engineering, fabrication, and modification i installation testing. The current repair involves the use of 12 low carbon ;

stainless steel support blocks which are to be attached to the upper and lower shroud in the area of the top guide support ring (H-2 and H-3 welds). These i support blocks are to be spaced at 30 degree intervals and be attached to the i shroud by four bolts. As-built dimensions have been obtained at each of the l proposed mounting locations to assist in the design of the support blocks and of the tooling equipment. The design of the support blocks had not been finalized at the close of the reporting period. The attachment holes through !

the shroud are to be made by Electric Discharge Machining (EDM) using a guide ;

plate or fixture for accuracy. Two holes are to be machined simultaneously per fixture and the licensee plans to use three fixtures, so that six holes will be machined simultaneousl Procedure and methodology qualification were still in progress at the end of the inspection perio EDM qualification testing to date has determined that approximately 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> will be required for machining each pair of holes. Based on this information, the licensee is estimating that approximately 14 days will be needed for machining the hole The shroud material removed by EDM will be in a dust form called swarf, and will be removed from the vessel by an underwater vacuum and deposited in filter GE has estimated that 400 filters will be used for this operatio The licensee is making preparations for the disposal of the filters which will be contaminate The licensee has required that full scale deep water testing of the alignment fixture, EDM equipment, and installation tools be performed at the GE

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facility. This will allow the licensee and GE to identify any equipment and/or process weaknesses and provide corrective actions prior to the equipment becoming contaminated. Personnel involved in the installation of the modification have been or will be trained for their assignment at GE's facilities. The licensee has requested that GE train all involved personnel on their tasks prior to the actual onsite installation of the modificatio The added effort of prequalifying equipment, personnel, and techniques should-minimize the time required to implement the modificatio On October 21, 1993, the licensee issued EER 93-0536, Evaluation of Unit 1 Core Shroud Indications and Operability Assessment of Unit 1 and 2, Revision 0. The licensee plans to issue Revision I when all of the inspection results have been analyzed and the repair design has been finalized. The revised EER will be submitted to the NRC for review.

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On October 22, 1993, the licensee met with the NRC in Rockville, Maryland and discussed the causal factors of the cracks, shroud inspection results, screening criteria, and the proposed repairs. The licensee plans to meet t:ith the NRC after the repair design has been finalized. The inspector has found the licensee to be detailed and thorough in addressing the cracks in the core support shroud. They have developed first of a kind inspection techniques that identified cracks which would not have been identified by normal inspection methods. The decision to repair the H-2 and H-3 welds during this outage rather than attempt to justify deferral by analysis was conservative and demonstrated a clear management commitment to do the job correctly. The licensee has also taken an active role in assuring the qualifications of the personnel performing this job and in assuring that Technical Support personnel communicate the status of this project to station staf The above actions are identified as a strength. The inspector will continue to follow this issu . Exit Interview (30703)

The inspection scope and findings were summarized on November 1, 1993, with those persons indicated in paragraph 1. The inspectors described the areas inspected and discussed in detail the inspection findings listed below and in the summar Dissenting comments were not received from the license Proprietary information is not contained in this repor Item Number Description / Reference Paraaraoh 50-324,325/93-49-01 Non-cited Violation involving an inadequate clearance, paragraph . Acronyms and Initialisms ACR Adverse Condition Report A0 Auxiliary Operator BSEP Brunswick Steam Electric Plant CBEAF Control Building Emergency Air Filters CFAR Component failure Analysis Report CP&L Carolina Power & Light Company CQA Corporate Quality Assurance CT Current Transformer DG Diesel Generator EDM Electric Discharge Machining EER Engineering Evaluation Report ESF Engineered Safety Feature F Degrees Fahrenheit FTE Full Time Equivalent GE General Electric Company HP Health Physics HVAC Heating Ventilation and Air Conditioning I&C Instrumentation and Control IFl Inspector Followup Item IPBS Integrated Planning, Budgeting and Scheduling LC0 Limiting Conditions for Operation

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i LER Licensee Event Report  !

LRI Leak Repair Incorporated l MCC Motor Control Center '

NAD Nuclear Assessment Department i NED Nuclear Engineering Department NRC Nuclear Regulatory Commission NSW Nuclear Service Water  ;

OM&M Outage Management & Modification j ONS Onsite Nuclear Safety .

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PA Protected Area PM Plant Maintenance ,

PNSC Plant Nuclear Safety Committee  !

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QA Quality Assurance  !

QC Quality Control j RCM Reliability Centered Maintenance '

RFP Reactor Feed Pump i RHR Residual Heat Removal >

SBGT Standby Gas Treatment '

STA Shift Technical Advisor  ;

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SW Service Water TS Technical Specification ,

URI Unresolved Item i UT Ultrasonic Testing V0M Volt-Ohm Meter  ;

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