IR 05000324/1998009

Insp Repts 50-324/98-09 & 50-325/98-09 on 980830-1010. Violations Noted.Major Areas Inspected:Operations, Engineering,Maintenance & Plant Support

ML20195G424
Person / Time
Site:	Brunswick
Issue date:	11/09/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20195G416	List: IR 05000324/1998009 ML20195G412 ML20195G419
References
50-324-98-09, 50-324-98-9, 50-325-98-09, 50-325-98-9, NUDOCS 9811200300
Download: ML20195G424 (29)

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U. S. NUCLEAR REGULATORY COMMISSION REGION 11 l

l Docket Nos: 50-325,50-324 License Nos: DPR-71, DPR-62  ;

l Report No: 50-325/98-09,50-324/98-09 j Licensee: Carolina Power & Light (CP&L)

Facility: Brunswick Steam Electric Plant, Units 1 & 2 Location: 8470 River Road SE Southport, NC 28461 Dates: August 30 - October 10,1998 Inspectors: C. Patterson, Senior Resident inspector E. Brown, Resident inspector E. Guthrie, Resident inspector B. Desai, Senior Resident inspector, Robinson, (Sections M and M8.2)

N. Merriweather, Reactor Inspector, (Section E8)

J. Lenahan, Reactor inspector, (Section E8)

T. Morrissey, Project Engineer-in-Training, (Section E8)

L. Mellen, Reactor Inspector, (Section 05)

Approved by: B. Bonser, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure 2 9811200300 981109 #

PDR ADOCK 05000324 :

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i EXECUTIVE SUMMARY Brunswick Steam Electric Plant, Units 1 & 2 l NRC Inspection Report 50-325/98-09,50-324/98-09

.This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 6-week period of resident inspection; in addition, it includes the results of an engineering inspection and an operator requalification inspection by regionalinspector Ooerations l

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Increased licensee attention has resulted in a reduction in the number of " operator workarounds." However, opportunities to correct an outage-related workaround were not taken (Section O2.1).

. There were no significant problems identified during verification of a clearance for the Unit 1 Uninterruptible Power Supply (Section O2.2).

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The licensee's operator requalification program complied with the requirements and standards of plant procedures as well as the requirements of 10 CFR 55.59 for the areas inspected. The licensee developed and administered simulator examinations, in-plant Job Performance Measures (JPMs) and simulator JPMs that effectively identified areas in need of improvement (Section 05.1).

. The feedback program and the remedial training programs were effective tools for

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improving the overall licensed operator requalification program (Section O5.1).

Maintenance  !

.. Corrective maintenance activities on the Service Water system were properly performed, adequately coordinated, and satisfactorily supervised (Section M1.1).

. The inspectors identified a procedure violation during the pedormance of the Residual Heat Removal Remote Shutdown Panet System Flow Channel Calibration. Technicians did not properly flush the transmitter in accordance with the procedure. All other aspects of the evolution obsented were performed satisfactorily (Section M2.1).

. The investigation and subsequent dispositioning of an out-of tolerance calibrator were pedormed in accordance with the controlling procedure. No safety-related equipment I was determined to be adversely affected (Section M6.1).

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Review of a service water valve test failure revealed an inadequate analysis justifying

nuclear service water operability. The inspectors identified a violation for the licensee's failure to adequately identify potential inservice Test program impacts resulting from this valve test failure, as well as for the failure to obtain supervisory approval for the operability determination (Section E2.1).

. The inspectors identified a violation for the licensee's failure to properly maintain or retain Inservice Testing Deviation Reports, which were a record of pump and valve testing performance problems and corrective actions (Section E3.1).

. The inspectors identified a procedural violation regarding the failure to perform a procedure revision prior to implementing a procedure acceptance criteria change for an Inservice Testing valve stroke time (Section E3.2).

. Both channels of the radiation monitors for the steam Jet air ejectors were declared inoperable as a result of conflicting terminology and data produced by several different procedures. Resolution of the conflicting procedures, terminology, and data by the

licensee continued to be poor (Section E7.1).

. Improvements were noted in the evaluation of Inservice Testing Program non-l conformances, identification of root and contributing causes, and implementation of corrective actions (Section E7.2).

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Plant Sucoort

. Control of transient combustibles has improved. Two instances of improper storage of combustible materials were identified by the inspectors. Proper dispositioning of the items was satisfactorily accomplished (Section F2,1).

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Report Details Summarv of Plant Status Unit 1 returned to service on August 29,1998, following a shutdown for Hurricane Bonnie. At the end of the report period the unit had been on-line continuously for 40 day Unit 2 operated continuously during this period. At the end of the report period the unit had been on-line continuously for 41 days. The unit operated with two control rods inserted to suppress power around a leaking fuel assembl l. Operations

02 Operational Status of Facilities and Equipment O2.1 Ooerator Workarounds 1 Inspection Scoce (71707)

The inspectors reviewed " operator workarounds." and disabled annunciators for both I units to evaluate the licensee's progress in promptly correcting identified operational deficiencies. An " operator workaround" is defined as a degraded or nonconforming condition that complicates the normal operation of plant equipment and is compensated for by operator actio Observations and Findinas The inspectors reviewed the " operator workarounds" for both units. Out of six workarounds, only two had been initiated in the last three months. The other four were between nine months and a year old. Only one required an outage for repair. The inspectors noted that some items remained despite several forced and refueling outages. In addition, no items requiring the unit to be in Mode 4 or Mode 5 were worked during a dual unit shutdown from August 25 to 27, for Hurricane Bonnie. These items included deficiencies requiring additional operator action to assist in emergency operating procedures (EOPs), as well as a nuisance alarm in N control room. A historical review indicated that in the past, increased attention by tae licensee had resulted in a reduction in the number of operator workarounds. However, opportunities to correct the outage-related workaround were not take l During a review of disabled annunciators on September 17, the inspectors observed a higher-than-normal number of disabled annunciators for Unit 2. Nine annunciators were disabled for Unit 1 and eighteen annunciators for Unit 2. The inspectors noted that ten per unit was the maximum number of disabled annunciators normally observed by the inspectors. The inspectors reviewed the list for Unit 2 and determined that a majority of the annunciators were for balance of plant functions. Review of the BNP Work Control Performance Review- September 1998, indicated an increase in control room l

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deficiencies from ten in early July 1998 to twenty in September 1998. The licensee goal i for control room deficiencies was identified as thre j

' Conclusions Increased licensee attention has resulted in a reduction in the number of " operator workarounds". However, opportunities to correct an outage-related workaround were not take .2 Clearance Walkdown (71707)

The inspectors verified proper implementation of clearance 1-98-1526 during a ,

walkdown on October 7. This clearance was hung to support troubleshooting on the '

Unit 1 Uninterruptible Power Supply. Electrical feeder breakers were verified to be racked out or locked off as appropriate. Technical Specifications were verified to have 4 been appropriately initiated for the out-of service equipment. Clearance tags reviewed l were properly marked and hung. No significant problems were identified during I verification of this clearanc Operator Training and Qualification O Licensed Operator Reaualification (LOR) Proaram inspection Scoce (71001)

During the period October 5 through 9, the inspectors reviewed the licensee's requalification program for licensed reactor operators (ROs) and senior reactor operators (SROs). The inspectors evaluated the program's ability to assess operator and crew performance with respect to the training objectives, as well as the licensee's ;

effectiveness in evaluating and revising the requalification program for licensed i operators based on their operational performance and requalification examination result Observations and Findinas Operating History The inspectors reviewed the facility's operating history to assess significant licensed operator errors that have occurred since the last requalification program evaluation (inspection or examination) to determine if the errors could be related to ineffective training. The review of operating history for the last two years revealed no operating problems or trends which were attributed to training weaknesses. NRC and licensee documentation indicated that both planned evolutions and unplanned transients were effectively controlled by the operators. The inspectors witnessed the administration of !

LOR-SIM-GEN 01. This provided training on recent changes to the simulator and included a discussion of Improved Technical Specifications (ITS) and recent plant modifications. This presentation also included a discussion of RO actions that were expected to occur without prior SRO approval.

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! 3 Written Examinations and Operating Tests The inspectors reviewed the facility licensee's requalification examinations to assess the adequacy of written requalification examinations and operating tests.

l The Inspectors reviewed the last completed requalification written examination that was

- administered in 1997. The written exam had several questions that had little or no l discriminatory value. There were questions with implausible distractors or multiple correct answers. The inspectors then reviewed the requalification written examination weekly quizzes administered in 1998. The inspectors found these questions to be discriminating with distractors that were generally plausible, in addition, these questions were written at a higher cognitive level (more comprehension and analysis) than the questions written in 1997. The inspectors concluded that the questions that were written for the 1998 requalification cless were effective tools for discriminatio Requalification Examination Administration Practices The Inspectors reviewed the facility licensee's requalification examination administration practices by observing examinations and tests in progress and interviewing personnel to assess the facility licensee's effectiveness in conducting written examinations and

, operating tests to ensure operator mastery of the requalification training program conten The inspectors witnessed the performance of several simulator scenarios. The crews completed all critical tasks. There were minor lapses in the scenarios, but these were identified by the facility evaluators. The scenarios did not enforce the potential consequences of having minimal support staff available. There appeared to be an almost unlimited supply of Auxiliary Operators (AOs), Instrumentation and Control (l&C)

personnel, and othe support groups. The inspectors discussed this with the facility training staff and Wy stated that they would evaluate the consequences of any delay this causes in the accident mitigation strateg The simulator scenarios developed by the training staff adequately challenged the operators in order to evaluate operator competency. The scenario set used during the observed exam week met the quantitative attribute guidance in NUREG-1021, " Operator Licensing Examination Standards for Power Reactors." The scenario selection process ensured that each operator had not received the same scenario in the last two year The bank of scenarios for annual evaluation was separate from those scenarios used for training. The bank was unpublished to preclude operators from predicting malfunctions based on familiarization with the scenario The inspectors witnessed the performance of severalin plant Job Performance Measures (JPMs). The technical problems observed by the inspectors were noted by the facility evaluator. The inspectors noted that the evaluators did not require detailed i explanations of how to access equipment that could not be readily accessed from the l floor. One task observed was the use of fire protection water as an alternate cooling l source following a station blackout. This JPM task required the candidates to j- manipulate E11-F073, with minimal DC lighting and using either ladders or climbing on L

equipment. E11-F073 is a reverse acting valve that is approximately 7 feet above floor l

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level in a location that would be difficult to access with a ladder. Access to this valve was not tested nor was it observed by the facility evaluator The inspectors witnessed the performance of several simulator JPMs. The technical problems observed by the inspectors were noted by the facility evaluator. The inspectors noted that one of the identified critical tasks contained an activity that was not critical to the completion of the task. The inspectors discussed this with the facility training staff and they will ensure that those tasks identified as critical tasks meet the definition of a critical task as defined in Appendix D of NUREG-102 Feedback System The inspectors reviewed the facility licensee's training feedback system to assess the effectiveness of the facility licensee's process for revising and maintaining its licensed operator continuing training program up-to-dat The inspectors reviewed the LOR program feedback for the past two years. The feedback was reviewed by licensee staff at an appropriate level. Students were offered the option of written feedback on their comments. At the end of each training week the feedback forms are reviewed and the comment resolutions are proposed for each comment. Operations representatives participate in this meeting. Operations also provides feedback and comments on training directly to the training department. The feedback program resulted in several changes to the LOR program. The inspectors found this to be an effective tool to improve the overall LOR progra ,

Remedial Training Program The inspectors reviewed the facility licensee's remedial training program to assess the adequacy and verify the effectiveness of the remedial training conducted since the last requalification examinations and the training planned for the current examination cycle to ensure that it addressed (s) licensed operator or crew performance weaknesse The inspectors reviewed the records of students with performance deficiencies that required remedial training. The actions taken were well documented, the level of remedial training provided was appropriate and the student's performance generally improved. For students that entered remedial training three times in an LOR cycle, an Academic Review Board met to determine what course of action was appropriate. This board helped identify generic weaknesses in the student's performance or in the material presented to the student. The inspectors found this to be an effective tool to improve the overall LOR program, c. Conclusions The licensee's operator requalification program complied with the requirements and l

standards of plant procedures as well as the requirements of 10 CFR 55.59 for the

areas inspected. The licensee developed a id administered simulator examinations, in-l plant JPMs and simulator JPMs that effectively identified areas in need of improvemen In addition, the feedback program and the re. medial training programs were effective tools for improving the overall LOR progra _ _ _

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08 Miscellaneous Operations issues (92901)

08.1 (Closed) Violation 50-324/97-12-01: Clearance Errors. Multiple clearance errors were made during a fall 1997 Unit 2 refueling outage. One of the errors resulted in damage to the recirculation pump seals. The errors were attributed by the licensee to  ;

inadequate human performance. The inspectors noted that some of the corrective j actions proposed by the licensee had not been completed prior to the Unit 1 Outag l

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Similar types of human performance errors occurred during the Unit 1 outage as described in NRC Inspection Report (IR) 50-325(324)/98-07 and the associated violation - l 50-325(324)/98-07-02, Configuration Control Problems. The inspectors concluded that

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the lack of oversight in scheduling the corrective actions for outage-related items before the next outage occurred, was a contributor to the recurrence identified in IR 50-l 325(324)/98-07. The closure of these additional issues will be tracked under the associated violation. The inspectors verified completion of the proposed actions including procedure revisions, addition of these issues to the Outage Lessons Learned database, and discussion of these events by licensee management with licensed personne '

l 11. Maintenance M1 Conduct of Maintenance M1.1 Service Water Actuator Maintenance Inspection Scoce (62707)

The inspectors observed the installation of a SmartStem (a valve stem torque measuring device), as well as the replacement of the torque switch, worm gear, and spring pack for Service Water (SW) system motor-operated valve 1-SW-V10 Observations and Findinas On September 25, the licensee stroked valve 1-SW-V106 to obtain design input information for an Engineering Service Request (ESR) to resolve Inservice Testing (IST)

valve operability issues associated with activities described in Section E2.1 of this repor On September 30, the inspectors observed the installation of the SmartStem, as well as the replacement of the torque switch, worm gear, and spring pack for 1-SW-V106. The inspectors verified that an adequate clearance boundary had been established. The technicians observed demonstrated satisfactory knowledge of the activities performe A minor size discrepancy in the key for the SmartStem was promptly evaluated and corrected. Supervisory oversight and communication was observed to be satisfactor Engineering support was present, which aided in the coordination and prompt evaluation of post-maintenance test results. The inspectors verified that the work instructions and related procedures were present at the job site and properly verified. Post maintenance testing indicated no leakage past 1-SW-V10 J

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6 Conclusion Corrective maintenance activities on a SW system valve were properly performed, adequately coordinated, and satisfactorily supervise M2.1 Observation of Residual Heat Removal (RHR) System Flow Channel Calibration on the Remote Shutdown Panel (RSDP) Insoection Scooe (61726)

On September 16, the inspectors observed the performance of Maintenance Surveillance Test OMST RHR280,"RHR RSDP System Flow Channel Calibration,"

Revision 1. Observation of the surveillance test was conducted to ascertain that it was conducted in accordance with Technical Specification (TS) and procedural

.equirement . Observations and Findinas The inspectors observed the entire performance of the surveillance. The inspectors observed good communications and noted no deficiencies with the surveillance paperwork. The procedure was a " Continuous Use" procedure which required that the steps be performed in sequence and verbatim. The inspectors observed the technicians fill and vent flow transmitter E11-FT-3338 through the vent plugs, and then close and torque the vent plugs. The technicians then flushed water through the transmitter via a portable test holdup tank. The inspectors noted that this was contrary to the procedure in that it required the transmitter to be vented and flushed in step 7.1.5.3 and then in step 7.1.5.4 the vent plugs were to be closed and torqued. The procedure was written so that the venting and flushing of the transmitter and piping was all done through the vents and not both the vents and the holdup tank as was performed. The inspectors determined that the technicians believed that they were performing the steps correctl _

The inspectors concluded that the technicians performed the steps out of sequenc The inspectors questioned the licensee as to whether the air introduced into the transmitter during the calibration check was all being removed as it was performed during the observed evolution. The licensee agreed with the inspectors that the transmitter was not vented and flushed properly and that the method used by the technicians was not acceptable. The proper technique was to use the pressure in the holdup tank to vent and flush through the vent plug The licensee initiated Condition Report (CR) 98-02226, Transmitter Flushing, based on the inspectors' finding that the transmitter was improperly vented and flushed. The

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licensee concurred that this practice could leave small amounts of air in the transmitter, possibly affecting operability. Following questions by the inspectors, the licensee determined that the transmitter was operable. The inspectors concluded that this was an isolated event following the licensee's investigation of all the other technicians'

transmitter venting techniques. The investigation found that they performed transmitter l venting correctly. Additionally, the licensee counseled the technicians involved, ensuring that they understood the proper technique for transmitter flushing. The licensee stated that training would be conducted during winter training classes for all

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technicians on proper methods for this evolution. The training department was developing this training course at the close of the inspection perio TS 5.4.1 states that written procedures shall be established, implemented, and maintained covering activities which are recommended in Regulatory Guide 1.33, Appendix A, November 1972. The improper flushing of the transmitter was a failure to properly implement procedure OMST-RHR280,"RHR RSDP System Flow Channel Calibrction," Revision 1. The failure to implement the procedure was a violation of TS 5.4.1. This violation is the first example of VIO 50-325(324)/98-09-01, Failure to implement Procedure Conclusions A procedural violation was identified during the performance of the RHR RSDP System Flow Channel Calibration. Technicians did not properly flush the transmitter in accordance with the applicable procedure. All other aspects of the evolution observed were performed satisfactoril M6 Maintenance Organization and Administration M6.1 Out-of-Tolerance Test Eauioment I Insoection Scoce (61726)

l The inspectors reviewed a licensee finding regarding an out-of-tolerance instrument calibration device used on safety-related equipmen Observations and Findinas During attendance at the morning ticket review on August 19, the inspectors noted that Deficiency Log Entry (DLE) 98DO3298 indicated that a calibration of instruments for Reactor Core Isolation Cooling and Reactor Vessel Level had to be rechecked as a result of an out-of-tolerance Ronan Calibrator. The inspectors reviewed the associated Calibration Non-Conforming Action Sheet contained in Attachment 5 to Maintenance Management Manual OMMM-006," Control of Measuring and Test Equipment," Revision 7. The inspectors verified that the investigation of the out-of-tolerance test instrumentation was conducted in accordance with the procedure. The investigation included notification of past users of the instrumentation to determine if previous calibrations may have been adversely affected. No equipment was required to be recalibrate The inspectors noted that OMMM-006 did not include timely notification of Operations should an investigation conclude that previous calibrations may have adversely affected safety-related plant equipment. Procedurally,14 days, regardless of the safety significance of an instrument, were permitted to complete an assessment of the impact of an out-of-tolerance test instrument. Generic Letter 91-18 provides guidance on the timeliness of assessments of degraded or nonconforming equipment and indicates that the timeliness of the assessment should be commensurate with the relative safety

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. significance of the degraded equipment. The inspectors questioned the licensee i

! regarding timeliness of an equipment operability assessment in the event that the . calibration of in-service plant equipment may not be valid. This concern was recorded in l

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CR 98-2337, M&TE Nonconformances. The licensee reviewed the finding and determined that enhancements could be made to existing maintenance procedures to

assure timely operability determination '

i J Conclusions j The investigation and subsequent dispositioning of an out-of-tolerance calibrator were

, performed in accordance with the controlling procedure. No safety-related equipment '

] was determined to be adversely affected.

i j M8- Miscellaneous Maintenance issues (92902) l

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M8.1 - (Closed) Licensee Event Reoorts (LERs) 50-325(324)/97-010-00.01; Failure to Comply with Surveillance Requirements to Test Emergency Diesel Generators During

Shutdown. This LER and the supplement were submitted as a result of the licensee

identifying that the TS surveillance requirement to inspect the Emergency Diesel

Generators (EDGs) every 18 months in accordance with vendor recommendations was

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not being performed while the plant was in a shutdown mode. The EDGs were being

, inspected while the EDGs were shutdown. The licensee confirmed that the inspections i had been conducted at the required interval, albeit not when the plant was shutdown.

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The root cause of the condition was attributed to procedure writers misunderstanding of the term shutdown as specified in TS. As corrective action, the licensee requested and received from the NRC in March 1998, a TS change to allow performance of the

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surveillance in any plant operational condition.

I The inspectors reviewed and discussed the LER with the licensee and concluded that

. the safety significance of the condition was minimal. This non-repetitive, licensee-

identified and corrected violation is being treated as a Non-Cited Violation (NCV),

consistent with Section Vll.B.1 of the NRC Enforcement policy. This is identified as NCV 50-325(324)/98-09-02, EDG Testing During Shutdow M8.2 (Closed) Licensee Event Report 50-325(324)/97-012-00: Standby Gas Treatment System (SBGT) Fire Protection System Deluge Valve Surveillance Interval Exceede ' This LER was submitted by the licensee upon identifying that TS 4.7.7.2, which required cycling of each testable Fire Protection (FP) deluge valve associated with the SBGT system, was not conducted at the required 12-month frequency. The FP deluge valves were tested every 18 months. The frequency had been changed in 1990 due to a misunderstanding of what constitutes a testable valve. The fire protection requirements, !

including those associated with testing the deluge valves, were removed from TS in 1994. Upon identification of this condition in 1997, the licensee reverted to testing the valves every 12 months as required by the FP program. The inspectors verified the schedule that reflects the 12-month testing frequenc __ __ __ _ _ . . _ . .

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l This non-repetitive, tiensee identified and corrected violation is being treated as an l Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy.

l This is identified as NCV 50-325(324)/98-09-03, Surveillance Test Interval Exceede M8.3 (Closed) Licensee Event Report 50-324/97-001-00: Containment Atmospheric Control Monitor inoperability Due to Thermoelectric Cooler Failure. The root cause of the CAC monitor inoperability was determined by the licensee to be a thermoelectric cooler failure. The thermoelectric cooler failed, allowing water to build up in the sample line, causing a low-flow condition, resulting in CAC monitor inoperability The licensee performed an assessment of past operability and compliance with TSs and,"... concluded that the thermoelectric cooler failure could have prevented the 2-CAC-4410 monitor from fulfilling its intended safety function for a period in excess of that allowed by TSs." The TS Limiting Condition for Operation (LCO), TS 3.6.6.4, for one monitor secured, was 31 days. The licensee could not determine the exact time of failure. The monitor was determined to be inoperable on June 6,1997 and restored June 7,1997. It was not possible, based on the preventive maintenance frequency, to determine when the 2-CAC-4410 monitor became inoperable, so that it could not be conclusively determined whether the TSs were actually exceede The CAC monitors perform a monitoring function only; they do not perform an active safety function. The licensee had the capability to sample the primary and suppression l pool atmosphere through the Post Accident Sampling System and is required to take this action in an accident scenario as a backup to the CAC monitors. The inspectors i verified that a current procedure was available to perform this samplin l The inspectors reviewed and verified completion of the licencee's corrective action Consideration was given to redundant divisions and like monitors in the other operating unit. Testing was conducted on the other unit and no problems were found. The monitors preventive maintenance instructions were enhanced to include thermoelectric l cooler performance and monitoring for water accumulation in the sample line, and the thermoelectric coolers weie replaced with units having an improved seal desig l 111. Enaineerina E2 Engineering Support of Facilities and Equipment E Nuclear Service Water (NSW) isolation Valve Inspection Scope (37551. 71707)

The inspectors reviewed a surveillance test failure of 1-SW-V106, Reactor Building Closed-Cooling Water (RBCCW) Heat Exchanger Service Water inlet Valve. During a Loss of Offsite Power (LOOP) this valve would receive a signal to close to allow flow exclusively to safety-related components. The safety-related equipment supplied by the

service water header included seal cooling for the residual heat removal (RHR) pumps,

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room cooling for RHR, core spray (CS), high pressure coolant injection (HPCI), and EDG coolin Observations and Findinas On July 25,1998, during the performance of routine inspection activities, the inspectors noted that the Unit 1 Operations Log indicated a discrepancy with 1-SW-V106. The valve had failed the full stroke exercise in Periodic Test OPT-8.1.4a, "RHR Service Water System Operability Test - Loop A," Revision 47, on July 24,1998. Testing indicated leakage past the valve at approximately 2000 gallons per minute (gpm). TS Surveillance Requirement (SR) 3.7.2.5 stated, " Verify each required SW (Service Water]

System automatic component actuates on an actual or simulated initiation signal." The TS BASES Surveillance requirements and the Updated Final Safety Analysis Report (UFSAR) indicated that this valve's safety-related function was to isolate the nuclear service water flow to the RBCCW heat exchangers during a loss of offsite power or a loss of coolant accident (LOCA).

When the valve discrepancy was identified, the Operations staff questioned NSW header operability. Engineering Service Request (ESR)98-455, Failure of 1-SW-V106 to Close, was initiated. The ESR review concluded that adequate margin existed to supply the NSW header. The ESR established that up to 4700 gpm out of a maximum pump limit of approximately 7800 gpm could be diverted without affecting NSW header operability. The inspectors questioned the ESR's conclusion due to a lack of supporting detail and the failure of the ESR to receive any kind of review other than that of the originating engineer. However, the inspectors concluded that satisfactory stroke testing of the redundant isolation valve 1-SW-V103, RBCCW Heat Exchanger Service Water inlet Valve, justified continued service water system operabilit Section 9.2.7.2 of Nuclear Generation Group Procedure EGR-NGGC-0005,

" Engineering Services Requests," Revision 9, requires, in part, that potential impacts to programs be identified if the ESR affects the performance parameter of a valve within the IST program or affects any safety-related motor-operated valve in a safety-related system. ESR 98-455 failed to adequately assess the potentialimpacts to IST program performance parameters. The failure to properly assess program inputs resulted in the failure to establish those actions necessary to assure EDG cooling in the event of subsequent degradation of the 1-SW-V106 valv Inspector review of ESR 98-455 revealed that the information and assumptions made to arrive at the conclusion that the header was operable were not supported by the information provided. As a result of the inspectors' concerns, the licensee performed a review of ESR 98 455 and determined that adequate detail to support the conclusion was not contained in the ESR and that the supervisor's signature was not obtained in accordance with Nuclear Generation Group Procedure EGR-NGGC-005. These discrepancies were described and evaluated in CR 98-2054, NGGC-005 Procedure Violation, and CR 98-2131,1-SW-V106. In addition, the licensee identified that no action was proposed or initiated to monitor valve degradation. Degradation in excess of 4700 gpm could have resulted in EDG inoperability should valve 1-SW-V103 have failed open. The licensee initiated ESR 98-484, Hydraulic Analysis of 1-SW-V106 Failure, and ESR 98-527,1-SW-V106 Engineering Analysis, to provide further evaluation of the l

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I valve degradation issue. On September 25, the licensee stroked the 1-SW-V106 to l obtain design input information for the ESRs. The subsequent data obtained showed l further degradation leakage had increased from 2000 to 3200 gpm. The licensee initiated maintenance activities to address the valve degradation. These activities are described in Section M1.1 of this repor ;

10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, and drawings. Nuclear Generation Group Procedure EGR-NGGC 005," Engineering Service Requests,"

Revision 9, requires that Engineering Service Requests (ESRs) include identification of '

potential impacts to plant programs and organizations, and receive supervisor signature and approval. The failure to identify impacts of the valve degradation on performance parameters for the Inservice Test Program and to receive supervisor signature and approval is a violation of 10 CFR 50, Appendix B, Criterion Conclusion i Review of a service water valve test failure revealed an inadequate analysis justifying nuclear service water operability. The inspectors identified a violation for the licensee's failure to adequately identify potential IST program impacts resulting from this valve test failure, as well as for the failure to obtain supervisory approval for the operability determinatio l E3 Engineering Procedures and Documentation E Inservice Testino Deviation Report Record Retention I l Inspection Scope (37551)

The inspectors reviewed the record retention requirements and the implementation of those requirements for an IST Deviation Repor Observations and Findinas On September 11, the inspectors reviewed the required retention requirements associated with Engineering Procedure OENP-16.1, "lST Pump and Valve Data,"

Revision 18. The inspectors found that the IST Deviation Report, Attachment 1 of OENP-16.1, was not being retained as required. The inspectors determined by direct observation that the original IST deviation reports for 1996,1997 and 1998 were being maintained by the IST engineers. The inspectors reviewed the requirements specified in the Required Records List (RRL), Revision 05 associated with the IST Deviation Reports. The RRL required that the IST Deviation Report be retained as a quality assurance document for the life of the plant. The licensee determined that records for 1994 and 1995 were destroyed

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The IST Deviation Reports were used to record safety-related components which had test data showing performance which fell into increased Test Frequency or Required Action Ranges. The report also recorded the corrective actions taken to address the deviation, track the increased frequency testing, and the investigation into component repair or replacement. The inspectors noted similar Quality Assurance (QA) document retention problems in previous inspection reports, but found that they were not repetitive because they did not have similar root cause TS 5.4.1 states that written procedures shall be established, implemented, and maintained covering activities which are recommended in Regulatory Guide 1.33, Appendix A, November 1972. Section 14.0, Quality Assurance Records and Document Control, of the Quality Assurance Program Manual, NGGM-PM-007, Revision 0 established the requirements for retention of OA records. IST Deviation Reports were required to be maintained for the life of the plant, in the Brunswick vault, in accordance with the RRL, Section 5.1.3, of Administrative Procedure OAP-009," Records Management Procedure," Revision 0. This NRC-identified failure to properly maintain and retain IST Deviation Reports is a violation of TS 5.4.1. This violation is the second example of VIO 50-325(324)/98-09-01, Failure to implement Procedure The licensee determined that they were going to revise OENP-16.1 to delete the IST Deviation Report. The licensee was going to use the CR process to document IST deviations, track corrective actions, and place them into QA record retention. These actions were addressed in CR 98-2183, IST Deviation Report Conclusions The inspectors identified a violation for the licensee's failure to properly maintain or retain Inservice Testing Deviation Reports, which were a record of pump and valve testing performance problems and corrective action E3.2 Surveillance Test Acceotance Criteria Chance Without A Procedure Revision Insoection Scope (61726. 71707)

The inspectors reviewed an IST engineering database change which changed the acceptance criteria in Periodic Test OPT-10.1.8, " Reactor Core Isolation Cooling (RCIC)

System Valve Operability Test for the 1-E51 F008, RCIC Steam Supply Outboard Isolation Valve." This change occurred on August 6,199 Observations and Findinas A review of the August 6,1998, operator logs indicated that the 1-E51-F008 valve failed its stroke time surveillance test in the open direction. The stroke time was less than the minimum acceptable value allowed in the acceptance criteria for this valve, according to OPT-10.1.8. The inspectors verified that the licensee took the appropriate actions when the 1-E51 F008 valve failed its stroke time requirements in accordance with ASME/ ANSI, OMa 1988," Operation and Maintenance of Nuclear Power Plants, Part 10, inservice Testing of Valves in Light-Water Reactor Power Plants (Third Interval),"

Section 4.2.1.9.b, Corrective Actions. The logs indicated that the IST database was

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revised and that, based on that revision, the stroke time was satisfactory and therefore the TS requirements were met. The logs also stated that OPT-10.1.8 would not be revised until the next performance of the quarterly required tes The inspectors found requirements that contradicted the actions taken in the logs i Engineering Procedure OENP-17, " Pump and Valve Inservice Testing," which did not allow the IST database revision to be effective until the procedure was revised. A note in Section 6.6 of OENP-17 stated that,"[t]esting requirements are not applicable until approval of the applicable test procedure." in Section 6.6.3.1 of OENP-17, the inspectors found that the procedure specifically stated that revisions created by the IST database change were not implemented by OENP-17 but by, "an implementing document which governs that change to the plant, process, or programs." In this case, the governing document was Administrative Procedure OAP-003," Procedure Preparation, Review, and Approval," Revision 13. This procedure applied to all procedures in the Plant Operating Manual. Not revising OPT-10.1.8 allowed a change to the procedure acceptance criteria and, thus, a change to a risk significant system without being reviewed in accordance with OAP-00 The inspectors questioned the licensee as to why it was acceptable to implement the IST database revision without a procedure revision being complete. The inspectors were informed that Engineering Procedure OENP-16.1, IST Pump and Valve Data stated, in Section 5.5, that, "[i]f a VAC [ Valve Acceptance Criteria] is revised, ISTBASE shall be revised to incorporate the new Acceptance Criteria. A PAR [ Procedure Action Request] to Operations Support group should be initiated by the IST Engi,eer to change the Acceptance Criteria in the applicable periodic test procedure for the affected valve (s)." Section 5.7 stated that, "[t]here will be some time delay between the generation of a new VAC for the valve and approval of the surveillance test procedure revision to reflect the change. However, the new VAC stroke time ranges are effective upon saving the new VAC in the ISTBASE." The inspectors found, through a discussion with the licensee, that they did not realize that these procedure steps conflicted with OENP-17 and 0AP-003, specifically in relation to when the change could go into effec These steps were generated, according to the licensee, to alleviate time constraints with completing a procedure revision and short time LCO Action statements in TS The inspectors reviewed the original change form used for the 1-E51-F008 valve IST stroke time rebaselining. This document was used to change the IST database with the new rebaseline values after the valve failed the surveillance test. This form required that a verification was performed ensuring that the reference document included a 4 safety analysis when that document was revised. The inspectors noted that this check was marked not applicable (N/A) for the 1-E51-F008 valve IST stroke time change. The inspectors questioned this practice because the N/A implied no check was being performed. OPT-10.1.8 was governed by 0AP-003 which did require a safety revie The licensee agreed with this concern and decided to provide guidance in the procedure during the next revision. This was discussed in CR 98-02290, IST Progra On September 9,1998, the inspectors determined that procedure, OPT-10.1.8, acceptance criteria were revised and that a change to a plant procedure was made and implemented without following required plant procedures. As a result of this concern, the licensee initiated CR 98-02290, IST Program, discussing the detailed actions that

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would be taken to correct the concern. This CR refers to CR 98-02131 to specify the detailed action items determined from root cause investigation 98-02131. The root cause investigation specified several actions, including revision of OENP-16.1 and OENP-17, changes to the IST program reporting and supervisor structure, performance of an ESR for every IST discrepancy, and generation of a CR for every IST related discrepanc TS 5.4.1 states that written procedures shall be established, irplemented, and maintained covering activities which are recommended in Regulatory Guide 1.33, Appendix A, November 1972. Administrative Procedure OAP-003," Procedure Preparation, Review, and Approval," Revision 13, identified the requirements for procedures requiring revision which are governed by the Plant Operations Manual, and that those procedures be revised according to the requirements specified. The failure to perform a revision to OPT-10.1.8 prior to changing and implementing the acceptance criteria for the 1-E51-F008 valve stroke time was a violation of TS 5.4.1. This violation is the third example of VIO 50-325(324)/98-09-01, Failure to implement Procedure Conclusions The inspectors identified a procedural violation regarding the failure to perform a procedure revision prior to implementing a procedure acceptance criteria change for an IST valve stroke tim E7 Quality Assurance in Engineering Activities E7.1 Steam Jet Air Elector (SJAE) Radiation Monitor Setooint Inspection Scope (71707)

The inspectors reviewed the circumstances surrounding the declaration of both trains of SJAE radiation monitoring inoperable. The SJAE radiation monitors provide an indication of fuel failur Observations and Findinas On September 21, the licensee performed Periodic Test OPT-04.1.7. This test required that the Hi and the Hi-Hi calculated setpoints for the A and B SJAE monitors be consistent with the actual setpoints. The values for the Hi setpoint for both channels did not match each other. As a result, both channels were declared inoperable. This event was captured in CR 98-2242, Inop cable SJAE Rad Monitors. The inspectors determined that the instructions for monitoring / control of the SJAE radiation monitor setpoints were found in four different procedures. These procedures were controlled by three different site organizations. The subsequent licensee investigation revealed that conflicting terminology and data from several different procedures resulted in the

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communication of the wrong installed setpoint values. This information was captured in CR 98-2263, inaccurate Setpoints.

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The SJAE monitor's Hi-Hi septoint values were not changed and were set conservatively below the Offsite Dose Calculation Manual value. The Hi setpoint was changed as background levels changed and was adjusted to prevent spurious alarms. Inconsistent Hi alarm setpoints did not indicate an inoperable monito Previously, the inspectors had noted, in IR 50-325(324)/97-13, that incorrect sensitivities were used during the November 25,1997, adjustment of the SJAE radiation monitor alarm setpoints. This was documented by the licensee in CR 97-4046, SJAE Rad Mon, sensitiv' ties. CR 97-4180, SJAE Rad Monitor Setpoints, addressed coordination problems between the Operations procedure used to request new radiation monitor setpoints, the Environmental and Radiation Control (E&RC) procedure that calculated the new setpoint, and the Maintenance procedure that installed the new setpoints. The most recent events are similar to the previous inspection findings which included the determination that the licensee's control and coordination of the SJAE alarm setpoints continued to be poo Conclusions Both channels of the radiation monitors for the steam jet air ejectors were declared inoperable as a result of conflicting terminology and data produced by several different procedures. Resolution of the conflicting procedures, terminology, and data by the licensee continued to be poo ;

l E7.2 Inservice Test Deficiencies Root Cause Analysis (40500)

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The inspectors observed, during review of the root causes for deficiencies discussed in Sections E2.1, E3.1, and E3.2, significant improvement in the evaluation of adverse !

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conditions. The root causes were clearly identified and contributing causes were adequately evaluated. The identification of the root and contributing causes was accompanied by corrective actions appropriate to the magnitude of the issues. The licensee indicated that the improvement noted in implementation of the corrective action program was attributed to the performance of Human Performance Fundamentals Training. This training was initiated in response to a growing trend in human performance event E8 Miscellaneous Engineering lasues (92903)

E (Closed) Violation 50-325(324)/96-14-01: Failure to Maintain the Environmental Qualification (EO) Program in Accordance with 10 CFR 50.49. This violation i

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identified numerous examples of failure to implement the requirements of 10 CFR 50.49. These included:

• Failure to include some post-accident sampling system components in the EO progra * Failure to provide documentation to determino qualification of reactor building motor control center j

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Failure to include 120/208 AC distribution panels on the EQ equipment lis i

• Failure to document qualification of various fuses and thread sealant .

• Failure to maintain EQ equipment list current by improperly deleting 300 components from the list without adequate justificatio ,

• Failure to maintain the EQ equipment list and EQ files current in that qualification [

data packages (ODPs) were not maintained current, some QDPs had not been '

issued, and ODPs did not consider effects of beta radiation, the effect of -

-- radiation changes caused by hydrogen water chemistry modifications, and current temperature profile The licensee responded to this violation (Civil Penalty) by letter dated December 19, 1996. The licensee determined that the cause of the violation was the failure of personnel responsible for the EQ program to implement the program effectively and inadequate management oversight of the EQ program. The licensee developed an extensive corrective action program to address the deficiencies in the EQ program. The corrective actions included the following:

• Establishment of a task force to implement corrective actions and increase the number of EQ engineers to maintain the progra * Provide training of engineering, operations, and maintenance personnel on the '

environmental qualification program.

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• Development of a new EQ equipment master lis * Reviewing and updating EQ equipment qualification data package ,

a inspection of installed EQ equipment to verify that the as-installed configuration of the equipment was in accordance with qualification documentatio * Development of new procedures to ensure procedures are in place to support '

EQ program implementation.

I- * Resolve open condition report action item * Review other technical program The licensee issued CR 96-01277 to document and disposition the EQ program deficiencies. The inspectors reviewed the licensee's corrective actions during inspections documented in NRC Inspection Report numbers 50-325(324)/97-02,97-03, 97-06,97-08,97-09,97-12,97-13,98-04, and 98-06. During these inspections, the inspectors performed walkdown inspections and examined installed EQ equipment, reviewed records documenting the licensee's walkdown inspections, reviewed several revised and updated ODPs, reviewed new EQ engineering and maintenance procedures, reviewed the Reactor Building Environmental Report and the EQ equipment

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database, and reviewed operability evaluations or justifications for continued operation (JCOs) and CRs initiated to document and disposition EQ program deficiencie During the current inspection, the inspectors verified that all action items associated with CR 96-01277 had been resolved. The inspectors reviewed DR-227, Environmental Qualification Service Condition, and verified that the effects of the increased radiation levels resulting from the hydrogen water chemistry modifications had been included in the environmental parameters for equipment qualification. The inspectors also reviewed ODP 94, Thread Sealants, and ODP-92B, Enertech/Herion Pneumatic Valves, and verified that the QDPs had been revised and issued to address issues documented in CR 96-01277. The licensee had disbanded the EQ task force c:nce their corrective actions were completed to address the EQ program deficiencies. They presently have two full-time EQ ongineers in the Brunswick Engineering Support Section (BESS) to maintain the program and are in the process of hiring a third EQ engineer. There are also several other personnel in BESS who are qualified as EQ engineers who are available to supplement the EQ staff when necessary. The inspectors concluded that the licensee's corrective actions to resolve the EQ program deficiencies have been complete E8.2 (Closed) Violation 50-325(3241/96-14-04: Failure to Promptly ider.tify and Correct Nonconforming Conditions. This violation identified nurnerous examp!es of the licensee's failure to promptly identify and correct deficiencies in the EQ program. The licensee responded to this violation (Civil Penalty) by letter dated December 19,1996. The cause of the violation was attributed to the failure of engineering and EQ personnel to take timely action to document and resolve known deficiencies in the EQ program, and the failure of management to recognize the extent of the deficiencies and the ineffectiveness of the corrective actions initiated to resolve some of the deficiencies. The licensee's corrective actions included improvements to their corrective action program, performance of self-assessments of the corrective action program, and increased training on the corrective action program for engineering and other personne The inspectors reviewed the licensee's actions to address the corrective action violation examples in parallel with review of the EQ program corrective actions discussed in Section E8.1. Some additional examples of corrective action violations were identified which the licensee addressed by making organizational changes to improve management oversight. The inspectors concluded that the licensee had implemented adequate corrective actions to address this violatio E8.3 { Closed) Violation 50-325(324)/97-12-05: Failure to implement Corrective Actions in Accordance with the Corrective Action Program (CAP). The licensee responded to this violation by letter dated January 7,1998. The Notice of Violation documented four examples of the licensee's failure to implement corrective actions in accordance with the CA The licensee initiated CR 97-04058 to document and disposition the deficiencies in the EQ CAP identified in the violation examples. The licensee also initiated CR 97-03933 to address the potential generic issues associated with timeliness of actions on a site-wide basis as well as within the EQ task grou .

The licensee's corrective actions associated with CR 97-04058 included prioritizing and scheduling overdue action items, as well as counseling the EO Supervisor, Manager, and Chief Engineer on meeting due dates, and the need to generate CRs for concerns that warrant condition reports. As part of the corrective action for a previous problem, the licensee had initiated CR 97-01927 to address concerns that CRs were not initiated when warranted. To disposition CR 97-01927, the licensee conducted training of Design Control Unit (DCU) personnel to reinforce when CRs should be written, the process for identifying issues, and the importance of documenting concerns / issues. The training was completed in July 1997. A licensee assessment in November 1997 of this training determined that the training had been effective. The inspectors had reviewed this assessment during a previous inspectio CR 97-03037 was initiated to disposition two ESRs approved by non-qualified personnel. Corrective action included review and approval of ESRs 97-00238 and 97-00343 by qualified reviewers. Additional training was also provided for the EO task force by review of the documents listed below to ensure awareness and compliance with the engineering support personnel (ESP) training program. Documents reviewed included TI-116 ESP Training Program, EO Technical Personnel Training List, CP&L Procedure EGR-NGGC-0003," Design Review Requirements," and CP&L Procedure EGR-NGGC-0005, " Engineering Service Requests."

The inspectors reviewed CR 96-03693, CR 97-01436, CR 97-01905, CR 97-03305, CR 97-3307, CR 97-01927, CR 97-04058, CR 97-03933, CR 97-03037, ESR 97-00238, ESR 97-00343, and the licensee's corrective actions and verified that they were complete. In addition, the inspectors reviewed the following ESRs and verified they were prepared and reviewed by qualified engineers or by engineers in training using qualified mentors: ESR 97-00713, ESR 98-00005, ESR 98-00211, ESR 98-00221, ESR 98-00043, ESR 98-00060, ESR 98-00368, ESR 98-00384, ESR 98- 00403, ESR 98-00404, ESR 98-00408, ESR 98-00067, ESR 98-00190, and ESR 98-00710. Eight of the above ESRs were EO ESR E8.4 (Closed) Violation 50-325(324)/97-12-06: Failure to Prepare ESRs/JCOs to Evaluate Equipment Operability. The violation involved the licensee's failure to document operability determinations and/or JCOs of EQ equipment in a timely manner. The licensee responded to the violation by letter dated January 7,1998. The root cause for the violation was attributed to ineffective management of the EO Program during the EQ Reconstitution effort. The corrective action taken by the licensee included making organizational changes to improve EO programmatic oversight during the EO Reconstitution Project, completion of the engineering evaluations for the deficiencies noted in the Notice of Violation, and performing an assessment of other EO Condition Reports assigned to engineering for similar deficiencies of excessive extensions, protracted due dates, etc. The licensee completed the above cor,ective actions and is now in full complianc E8.5 (Closed) Violation 50-325(324)/97-13-02: Inadequate Procedure for Conduct of EO Preventive Maintenance. The licensee responded to this violation by letter dated February 23,1998. The violation contained two examples of inadequate procedures for the conduct of EO preventive maintenance. Procedure OPM-MCC002," Preventive Maintenance of GE Motor Control Centers and Switch

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l 19 l Boards," did not contain the requirements of ODP 67 to repair or replace disturbed Nelson flame seal putty. In the second example, Maintenance Procedure MMM-053," Equipment Lubrication Guidance and Lubricant Listing,"

specified the use of Mobil lubricant in Joy / Reliance Electric motors contrary to the Chevron SRI grease specified in ODP 2 The licensee initiated CR 97-04121 to document and disposition the deficiencies in Maintenance Procedure OPM-MCC002. The licensee's corrective actions included revisions to procedure OPM-MCC002, and to procedure OAP-003, " Procedure Preparation, Review and Approval." OPM-MCC002 was revised to include inspection and repair as necessary of Nelson flame seals. 0AP-003 revision added EO screening questions, the use of Procedure Action Requests (PAR)in the procedural review cycle to ensure all aspects of the PAR were included in the revision, and a list of site programs (including EO) that need to be considered when requesting review Additionally, the licensee provided awareness training of this issue to individuals responsible for procedure developmen The licensee initiated CR 97-04015 to document and disposition the deficiencies in the lubrication maintenance procedure, MMM-053," Equipment Lubrication Application Guidance and Lubrication Listing." The licensee's corrective actions included l performance of an engineering evaluation to document the acceptability of using Mobil l

lubricants in environmentally qualified motors and performing a review to ensure that ;

lubricant requirements were being maintained in accordance with ODP requirement '

ODP 26 was revised to specify the use of Mobil lubricant. MMM-053 was revised to require an engineering evaluation when changing the type of lubricant used in O-list or EO equipment. The licensee determined that the motors addressed in ODP 68 contain sealed bearings and therefore, required no lubrication. No other deficiencies were identified by the license l The inspectors reviewed OPM-MCC002 (Rev. 8 dated January 21,1998), OAP-003 (Rev.13 dated August 14,1998), CR 97-04121, CR 97-04015, MMM-053 (Rev. 9 dated June 18,1998), ODP 26 (Rev. 2 dated July 29,1998), ODP 68 (Rev. 6 dated July 29, 1998), ESR 97-00710, and ESR 97-00723 and the licensee's corrective actions and I verified that they had been complete l E8.6 (Closed) Inspection Followup Item 50-325(324)/97-13-07: Review Technical Evaluation of Terminal Block Current Leakage and the Effect on EO Equipmen The licensee evaluated the effects of terminal block leakage current on 120 VAC and 125 VDC control circuits. The evaluations for AC and DC control circuits were documented in ESR numbers 97-00440 and 97-00441, respectively. The licensee concluded in ESR 97 00440 that leakage currents would have no adverse effects on AC control circuits. However, the evaluation of DC control circuits documented in ESR 97-00441 identified three types of relays that were noted to be sensitive to leakage current in that they would not be expected to dropout. The specific application of these relays in EO circuits was evaluated by the licensee in ESR 97-00510, Revision 0. The licensee concluded in ESR 97-00510 that the applications in which these relays were used in the plant did not require that they dropout to mitigate a LOCA or High-Energy Line Break (HELB)

event. Therefore, the licensee concluded from the above reviews and

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evaluations that the terminal block leakage current issue was not a credible concern at Brunswick Nuclear Plant. The inspectors reviewed the above evaluations and found them to be technically adequat E8.7 (Closed) Violation 50-325(324)/98-04-05: Use of ED (Engineering Disposition)

ESR to Change Plant Design Documents. The licensee responded to this violation by letter dated May 18,1998. The cause of the violation was attributed ,

to a lack of clear guidance in the ESR procedure, EGR-NGGC-0005, regarding the requirements for generating new sources of design information. The licensee's corrective actions included revision of the ESR procedure, preparation of an engineering evaluation to replace the ED ESR, and communication of this issue to all engineering personnel. The inspectors reviewed Engineering Evaluation ESR 98-00168, which was prepared to evaluate the design temperatures in the drywells and the effect on environmental qualification of equipment. This ESR superseded the ED ESR and was referenced in DR-227, +

Environmental Qualification Service Condition. The inspectors also reviewed Revision 9 to EGR-NGGC-0005, dated July 13,1998, and verified that the requirements for creating new design source documents, including the need for

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design verification, have been clarified in the procedure. The inspectors j reviewed the licensee's ESP training records and verified that this issue had been communicated to engineering personnel as part of their continuing training program.

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E8.8 (Closed) Insoection Followuo item 50-325(324)/98-06-05: Repair of RTD Drain

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Wires. During an EO inspection of splices in electrical Penetration 1-X-104F, the licensee found that the T95 tape applied over the shield / drain wires for drywell resistance temperature devices (RTDs),1-CAC-TE-1258-24 and 1-CAC-TE-

1258-20, had deteriorated to the point where bare conductor was exposed on each splice, making the splice unqualified. The same condition was also found on the drain wires in the opposite Division 1 Penetration 1-X-104A. The licensee

evaluated the degraded condition in ESR 98-00225 and concluded that the as-found condition did not effect operability of the RTD circuits. The licensee found

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that plant configuration documents indicated that it was acceptable for

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temperature element shield / drain wires to be left exposed. However, this condition was not considered desirable because it could lead to intermittent grounds and ground loops. Although the as-found condition was acceptable, the licensee revised the design to be more consistent with the specification 048-004 to require that the shield wires be provided with a protective cover using materials that have been demonstrated by testing to maintain their integrity in harsh environments for which the RTDs are required to operate. Both penetrations on Unit 1 were reworked using the guidance of ESR 98-00225. A work order (WR/JO 98-ACPZ1) was issued to inspect Unit 2 Penetration 2-X-104A during the next Unit 2 outage to ensure that the enclosed shield wires are not in a configuration that could produce ground loop E8.9 (Closed) Escalated Enforcement item 50-325(3241/98-04-01: Inadequate 10 l CFR 50.59 Evaluations which Resulted in Deletion of TS Response Time Testing Requirement ,

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(Closed) Escalated Enforcement item 50-325(3241/98-04-02: Failure to Perform RTT for Reactor Protection System Instrumentation as Required by TS 4.3. (Closed) Escalated Enforcement item 50-325(324)/98-04-03: Failure to Perform RTT for Actuation of the Primary and Secondary Containment isolation Systems as Required by TS 4.3. (Closed) Escalated Enforcement item 50-325(324)/98-04-04: Failure to Perform RTT for Actuation of ECCS as Required by TS 4.3. In the letter which transmitted the inspection report, the licensee was requested to respond to the four apparent violations (Eels) listed above. The licensee responded to this request in a letter dated May 18,1998. In their letter, the licensee discussed the 1 causes of the violations, their corrective actions, and their safety and regulatory j significance. Based on the information developed during the inspection, as well as on ,

consideration of the information provided by the licensee in their May 18,1998, letter, the NRC concluded that a violation of 10 CFR 50.59 did occur which resulted in the !

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three apparent violations of the Technical Specifications for failure to conduct response time testing (RTT). NRC review disclosed the following circumstances regarding the apparent violations:

(1) The licensee was performing RTT in accordance with other methods which had been approved by the NRC. The licensee's methodology was approved by the NRC in a subsequent TS amendmen (2) The inadequate 10 CFR 50.59 evaluation was an isolated cas l (3) The safety significance of the apparent TS violations was low since the licensee was performing RTT using other methods approved by NR (4) The licensee identified the inadequate 10 CFR 50.59 evaluation in March 1997, and reported these issues to the NR (5) There was no adverse impact on plant safety or operability of the affected systems, in a letter to the licensee dated July 10,1998, Subject: NRC Inspection Report Nos. 50-325/98-04 and 50-324/98-04, the licensee was informed that the inadequate 10 CFR 50.59 evaluation would be dispositioned as a Non-Cited Violation in accordance with the NRC Enforcement Polic IV Plant Support S8 Miscellaneous Security and Safeguards lasues (92904)

S8.1 (Closed) Violation 50-325(324)/97-12-10: Protected Area Personnel Access Control Deficiency. A violation was cited for inadequacies in site security procedures. The

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licensee denied the violation in a letter dated January 7,1998. In a letter dated February 13,1998, the NRC upheld the violation as written. The licensee's response to the violation was contained in a letter dated March 16,1998. The inspectors reviewed i the response and the associated corrective actions contained in root cause ana ysis 97- l 03964, Plant Access Turnstile Area. The actions included revisions of the affected procedures and Member of Security Force (MSF) training material and the placement of  ;

signs indicating the requirement to stay behind the half-length turnstile until the  ;

individual clears the full-length turnstile. In addition, a site-wide message on turnstile

. usage was issued. The inspectors noted several CRs initiated by security regarding similar incidents. in all the events noted, appropriate actions were taken consistent with the revised procedural guidanc F2 Status of Fire Protection Facilities and Equipment l l

F Storaae of Transient Combustibles l Inspection Scope (71750)

The inspectors reviewed several critical areas and the requirements for transient combustibles to assess the control of transient combustibles and adequacy of l

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housekeeping. The requirements for transient combustibles were designated in Fire Protection Procedure OFPP-14," Control of Combustible, Transient Fire Loads, and Ignition Sources," Revision 1 i Observations and Findinas On September 1, during routine inspection activities, the inspectors observed two unattended canisters near Division l Motor Control Center (MCC) 1 PA on the 20 foot (ft)

elevation of the SW Building. The cans were in the vicinity of the Unit 1 nuclear service water pumps as well as components important to safety located on MCC 1PA. The NSW pumps provide cooling for the EDGs under accident condition The inspectors noted that the cans were not contained in a designated work area and no work activities or work areas were observed on the entire elevation. The canisters'

labels indicated that the contents were DTE Heavy Medium and DTE 797 fubricating oil; the inspectors subsequently verified that the labels were accurate. Proceda 0FPP-14 required in Section 6.3.4.2 that, "[a]Il storage of flammable / combustible liquids in critical buildings shall be in approved flammable liquid storage lockers." Section 5.3 defined critical buildings to include the SW Building. After multiple notifications by the inspectors of the discrepancy, the canisters were eventually removed. This issue was described in CR 98-2206, Housekeeping Control. The inspectors were informed that the cans were believed to have been improperly stored in the building since the end of Hurricane Bonnie around August 2 On September 30,1998, the inspectors were performing routine inspection activities on the 50 ft elevation of the Unit 1 reactor building. The inspectors observed the inappropriate storage of a resin bucket in the fire separation zone as marked by the yellow line on the floor. A maintenance supervisor in the area was notified and the

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bucket was promptly relocated. The licensee initiated CR 98-2353, Transient Combustibles. The licensee conducted a review of the other separation zones in the building for improper storage of transient combustibles. No additional examples were identified. These failures to control combustiables constitute a violation of minor significance and is not subject to formal enforcement actio The inspectors noted improvement in the licensee's control of transient combustibles in response to previous violations as described in irs 50-325(324)/96-04 and 50-325(324)/97-08. Further corrective actions for these examples are being taken in conjunction with the corrective actions identified in the Fire Protection Improvement Plan.

Conclusions Control of transient combustibles has improved. Two instances of improper storage of combustible materials were identified by the inspectors. Proper dispositioning of the items was satisfactorily accomplishe V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on October 16. Post-inspection briefings were conducted on September 18 and October 9. The licensee acknowledged the findings presented. Dissenting comments were not received from the licensee. The licensee did not identify any materials used during the inspection as proprietary informatio .

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PARTIAL LIST OF PERSONS CONTACTED Licensee G. Attarian, Chief Electrical Engineer, Nuclear Engineering A. Brittain, Manager, Security  ;

R. Deacy, Manager, Outage and Scheduling l N. Gannon, Manager, Maintenance J. Gawron, Manager, Nuclear Assessment M. Herrell, Manager, Training ,

E. Hux, Director of Site Operations I

K. Jury, Manager, Regulatory Affairs J. Keenan, Site Vice President B. Lindgren, Manager, Site Support Services J. Lyash, Plant General Manager G. Miller, Manager, Brunswick Engineering Support Section R. Mullis, Manager, Operations INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726: Surveillance Observations l IP 62707: Maintenance Observations l IP 71001: Licensed Operator Requalification Program Evaluation l lP 71707: Plant Operations IP 71750: Plant Support Activities ,

IP 92901: Followup - Operations i

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IP 92902: Followup - Maintenance IP 92903: Followup - Engineering IP 92904: Followup - Plant Support i

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l 25 ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-325(3?4)/98-09-01 VIO Failure to implement Procedures (Sections M1.2, E3.1, E3.2)

50-325/98-09-04 VIO Inadequate Review of Valve Degradation (Section E2.1)

50-325(324)/98-09-02 NCV EDG Testing During Shutdown (Section M8.1) )

50-325(324)/98-09-03 NCV Surveillance Test Interval Exceeded (Section M8.2) 1

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Closed 50-324/97-12-01 VIO Clearance Errors (Section 08.1) l 50-325(324)/97-010-00,01 LER Failure to Comply with Surveillance Requirements to Test Emergency Diesel Generators During Shutdown (Section M8.1)

50-325(324)/98-09-02 NCV EDG Testing During Shutdown (Section M8.1) l

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50-325(324)/97-012-00 LER Standby Gas Treatment System Fire Protection System Deluge Valve Surveillance Interval Exceeded (Section M8.2) l 50-325(324)/98-09-03 NCV Surveillance Test Interval Exceeded (Section M8.2)

50-324/97-001-00 LER Containment Atmospheric Control Monitor inoperability Due to Thermoelectric Cooler Failure (Section M8.3)

50-325(324)/96-14-01 VIO Failure to Maintain the Environmental Qualification Program in Accordance with 10 CFR 50.49 (Section E8.1)

50-325(324)/96-14-04 VIO Failure to Promptly identify and Correct Nonconforming Conditions (Section E8.2)

l 50-325(324)/97-12-05 VIO Failure to implement Corrective Actions in

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Accordance with the Corrective Action Program (Section E8.3)

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50-325(324)/97-12-06 VIO Failure to Prepare ESRs/JCOs to Evaluate Equipment Operability (Section E8.4)

50-325(324)/97-13-02 VIO Inadequate Procedure for Conduct of EQ -

Preventive Maintenance (Section E8.5)

50-325(324)/97-13-07 IFl Review Technical Evaluation of Terminal Block Current Leakage and the Effect on EQ Equipment (Section E8.6)

50-325(324)/98-04-05 VIO Use of ED ESR to Change Plant Design Documents (Section E8.7)

50-325(324)/98-06-05 IFl Repair of RTD Drain Wires (Section E8.8)

50-325(324)/98-04-01 eel inadequate 10 CFR 50.59 Evaluations which Resulted in Deletion of TS Response Time Testing Requirements (Section E8.9)

50-325(324)/98-04-02 eel Failure to Perform RTT for Reactor Protection System Instrumentation as Required by TS 4.3. (Section E8.9)

50-325(324)/98-04-03 eel Failure to Perform RTT for Actuation of the Primary and Secondary Containment isolation Systems as Required by TS 4.3.2.3 (Section E8.9)

50-325(324)/98-04-04 eel Failure to Perform RTT for Actuation of ECCS as Required by TS 4.3.3.3 (Section E8.9)

50-325(324)/97-12-10 VIO Protected Area Personnel Access Control Deficiency (Section S8.1)