IR 05000324/1998010
| ML20198P033 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/21/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20198P024 | List: |
| References | |
| 50-324-98-10, 50-325-98-10, NUDOCS 9901060281 | |
| Download: ML20198P033 (26) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION 11 .
Docket Nos: 50-325,50-324 License Nos: DPR-71, DPR-62 Report No: 50-325/98-10,50-324/98-10
l Licensee: Carolina Power & Light (CP&L)
Facility: Brunswick Steam Electric Plant, Units 1 & 2 l
Location: P. O. Box 10429 l Southport, NC 28461 1 Dates: October 11 - November 21,1998 i
Inspectors: C. Patterson, Senior Resident inspector E. Brown, Resident inspector E. Guthrie, Resident inspector E. Girard, Reactor Inspector (Sections E2.2 and E8.4)
E. Testa, Senior Radiation Specialist (Sections R1, R2, R3, and i R8)
Approved by: B. Bonser, Chief l Projects Branch 4 Division of Reactor Projects Enclosure 2 9901060281 981221 PDR ADOCK 05000324 G PDR
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EXECUTIVE SUMMARY l Brunswick Steam Electric Plant, Units 1 & 2 NRC Inspection Report 50-325/98-10,50-324/98-10-This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 6-week period of resident inspection; (.) addition, it includes the results of an engineering and health physics inspection by regionalinspector Operations
- Prompt operator response and followup actions for a control room annunciator and
' securing a leaking Electro-Hydraulic Control (EHC) system pump prevented a Unit 1 trip
- due to a low EHC tank level (Section 01.1).
- Licensee management expectations were not being met for identified Reactor Turbine Gage Board (RTGB) deficiencies. Operations did not ensure that RTGB deficiencies were identified by caution ta]s and administratively tracked by the caution tag process L (Section 01.2).
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- Operator inattention resulted in a failure to follow procedure violation. Procedure steps o
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necessary to restore and verify that the Unit 1 Standby Gas Treatment system was in a correct standby lineup were not completed. Frequent licensee panel walkdowns failed to detect the misaligned valves (Section O2.1). l Maintenance
- Selected surveillance activities observed were completed with no deficiencies.
l Technicians reemphasized a lesson-learned before performing steps that had resulted in previous equipment inoperability. Three-part communication; cautious and deliberate procedural usage; good practices concerning work on a contaminated system, and
! maintaining dose received as low as reasonably achievable were observe Technicians demonstrated satisfactory understanding of the test process and equipment usage (Sections M1.1 and M1.2).
l * A detailed review of the Maintenance Rule (MR) h story and performance criteria for the Service Water system identified several reoccurring problems with the pump motor oil cooler transition piece that the licensee had not considered for overall system MR performance. As a result of the transition piece problems, the licensee upgraded an existing Condition Report to a significant adverse condition (Section M1.3).
.- The inspectors observed well planned and executed maintenance activities associated with the on-line repair and restoration of the Unit 2,4B and 5B feedwater heaters. This
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was demonstra:ed by a slow and careful approach for work preparation and work activities. A special procedure developed for the activity identified special precautions and limitations as well as contingency plans for unexpected conditions (Section M2.1).
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The licensee did not adequately consider all aspects of Standby Liquid Control (SLC)
' system maintenance work activities. As a result, maintenance to repair a drain line leak resulted in rendering both loops of the SLC system inoperable. Events associated with the SLC system leaking drain valve problems were not always logged into the MR event log and system and component unavailability times were not accurately tracked (Section M3.1),
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Engineering reviews of the SLC system heat trace modifications were thorough an'd properly reviewed (Section E2.1)
L Deficiencies were identified in the licensee's hardware investigation and corrective i
actions for the surveillance test failures of 1-SW-V106, Reactor Building Closed Cooling Water Heat Exchanger Service Water inlet Valve. The inspectors identified a violation
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. for the licensee's failure to establish that the torque switch of this valve was set correctly and to test or otherwise evaluate the condition of the spring pack believed to have contributed to the failure (Section E2.2).
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The inspectors determined that the Turbine Stop Valve / Turbine Control Valve (TSVUCV) closure automatic scram function could be bypassed at reactor power levels
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greater than that allowed by TS. An Inspection Followup Item was opened pending
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response to questions concerning whether the TSVRCV closure automatic scram
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function disablement at powers greater than the TS allowed value was considered in the
- plant design basis and its effect on the Minimum Critical Power Ratio limit (Section E3.1).
L Plant Sucoort
.' Little performance improvement was noted during the recent fire dnes as compared to drill performance noted in the licensee's July,1998 triennial fire protection assessmen Deficiencies observed in previous drills were still occurring. Omission of drill performance issues from the written drill critiques allowed a misrepresentation of actual fire brigade performance documented in the written drill critiques. Some fire drill objectives were not well defined and lacked objective criteria to accurately measure satisfactory performance. Based on observed performance and reviews, a weakness
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- Radiological controls in radioactive material storage areas, the instrument calibration area, and the " hot" machine shop, were appropriate. These areas were properly posted and radioactive materials were appropriately labeled (Section R1.1).
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- Radiation and process effluent and environmental monitors were being maintained in an L operational condition in compliance with TS requirements and Updated Final Safety l Analysis Report commitments (Section R2.1).
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The licensee effectively implemented a program for shipping and receiving radioactive
- materials as required by NRC and Department Of Transportation regulations (Section l R3.1).
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'A weakness existed in the procedure to restore inoperable Alternate Safe Shutdown (ASSD)
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equipment. The procedure lacked specific instructions for actions to be taken if multiple trains
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of ASSD equipment were inoperable and did not address compensatory measures. The licensee revised the procedure to correct the weaknesses (Section F8.1). I l
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Report Details
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1 Summary of Plant Status i Unit 1 operated at or near 100 percent Rated Thermal Power (RTP) during the report period
! except for planned testing activities. At the end of the report period the unit had been on-line continuously for 82 days.
, Unit 2 began the report period at 100 percent RTP. Power was reduced to about 90 percent l RTP on October 10 in preparation for feedwater heater repair activities. Power was returned to i 100 percent RTP the next day. P >wer was reduced to 95 percent RTP on October 13 to remove the 4B and SB feedwater heaters from service for corrective maintenance. Power was returned to 100 percent RTP the same day. Power was reduced to 83 percent RTP on October 22 in preparation for returning the heaters to service. Power was returned to 100 percent RTP on October 24 following corrective maintenance to repair heater tube leaks. At the end of the report period the unit had been on-line continuously for 83 days. The unit operated with two control rods inserted to suppress power around a leaking fuel assembl l 1. Operations l
01 Conduct of Operations 0 Review of Operator Response to Unit 1 Electro-Hvdraulic Control (EHC) System Oil Leak (71707)
The inspectors reviewed the operator logs and Condition Report (CR) associated with the EHC oilleak that occurred on October 13. An annunciator, EHC Tank Level High-Low, actuated in the control room and an auxiliary operator was dispatched to the EHC room to determine the cause of the alarm. The auxiliary operator reported a leak on the running 1B EHC pump. Control room personnel started 1 A EHC pump and secured 1B EHC pump to stop the leak. The EHC tank level had decreased several inches during "
the leak. The licensee determined the leak was due to an "O" ring seal failur Corrective action to assess the "O" ring seal size and installation of lock tabs on fittings !
was initiate The inspectors concluded that prompt operator response and followup actions for the ;
control room annunciator and securing the leaking EHC pump prevented a plant trip due j to a low EHC tank level conditio i
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l 2 l O1.2 Reactor Turbine Gaae Board (RTGB) Deficiencies 1 Inspection Scooe (71707) i The inspectors reviewed the licensee's control of known deficiencies on the RTG I l Observations and Findinas l
i l The inspectors reviewed a CR generated for the Unit 1 Drywell Equipment Drain pump operating switch on October 27. The inspectors observed that the defective switch was not identified with a caution tag. Operating Instruction 001-01.09 " Equipment Tagging,"
Rev. 2 stated that caution tags were generally used to provide specified precautionary information for manipulation of a component. The inspectors discussed the absence of a caution tag with the Operations Manage The licensee stated during a meeting that the switch condition had been known for some time and that the operators should have been aware of the deficiency prior to October 27. A work order already existed for the switch. This switch was a spring return switch which was stuck in the "on" position. This caused the pump to operate at low sump levels instead of when the sump level instruments indicated the level should be decreased. Operators were not aware of the stuck switch and pump operation but later recognized the problem when pump flow data was recorded. The inspectors concluded that the excessive pump operation did not give false indications for the total volume of water removed from the sump and was not indicativo of excessive drywell inleakag The Operations Manager informed the inspectors that operator performance did not meet management expectations for control board awareness and the use of caution tags. The licensee initided a detailed walkdown of the control room panels and determined that there were five other RTGB deficiencies that did not have caution tag The licensee initiated CR 98-02591, Caution Tags. The CR noted an observed declining trend for the operations group for not placing caution tags for RTGB equipment problem The inspectors reviewed the licensee identified deficiencies and determined that none of the deficiencies hindered the operation of safety significant systems. The inspectors observed that the licensee initiated caution tags for the identified deficiencies and a memorandum was issued which reiterated the management expectation for the use of caution tag Conclusions Licensee management expectations were not being met for identified RTGB deficiencies in that operations did not ensure that RTGB det iencies were administratively tracked i
by caution tags.
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02 Operational Status of Facilities and Equipment O2.1 Standbv Gas Treatment (SBGT) Svstem Valve Misalianment insoection Scope (71707)
The inspectors conducted a daily control room panel walkoown on October 30 to verify correct switch and component alignment.
l i Qbservations and Findinas The inspectors observed that the SBGT post-Loss of Coolant Accident (LOCA) vent
- valves SGT-V8 and SGT-V9 indicated full open. The inspectors discussed the open
! valves with operations personnel. The operators promptly determined that the valves should be closed and placed the valves in their correct position. Additional RTGB deficiencies are discussed in Section 01.2 of this repor The operators had completed a Reactor Core Isolation Cooling (RCIC) system
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surveillance the previous shift and the vent valves were opened per the procedure to support the test. The inspectors reviewed Operating Procedure 10P-10," Standby Gas Treatment System Operating Procedure, " Rev. 40, and observed that step 7.1. specified the system be placed in a standby condition following system shutdown and to verify that SGT-V8 and SGT-V9 were in the closed position as part of the standby system alignment. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and verified that the two open valves did not render the system inoperable and that the system would perform its designed safety function. The two open valves did not introduce any new flow path following an automatic start signal of the system and presented little safety significance for plant operatio The licensee initiated a CR as a result of the SGT-V8 and SGT-V9 valves being left open. The licensee's root cause investigation determined that the operator was ,
distracted during the performance of the procedure lineup and never completed the required steps. Additionally, the root cause investigation addressed the concern that multiple licensee personnel performed panel walkdowns to detect this type of deficiency and failed to detect the misaligned valve The licensee initiated corrective actions to prevent recurrence. Procedures which were used during the evolution were enhanced, the individuals involved received counseling, and all operations personnel reviewed the event with respect to procedure adherenc j The licensee developed an " Operations improvement Plan" based on this event, management observations of weaknesses, and recent Nuclear Assessment Section (NAS) assessment findings. The plan included individual, shift and management observations, assessments, individualized shift improvement initiatives, and visits to other sites to review specific areas for improvement. The licensee's goal was to complete the action plan having improvements and initiatives implemented by January 1999.
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l Technical Specification (TS) 5.4.1.a requires that written procedures shall be I established, implemented, and maintained covering activities which are recommended in Regulatory Guide 1.33, Appendix A, November 1972, for operation and shutdown of l safety-related equipment. The failure to close SGT-V8 and SGT-V9, as required by l section 7.1, of procedure 10P-10, was a violation of TS 5.4.1.a. This issue was '
identified as Violation 50-325/98-10-01, Standby Gas Treatment Valve Misalignmen Conclusions Operator inattention resulted in a failure to follow procedure violation. Procedure steps i necessary to restore and verify that the Unit 1 SBGT system was in correct standby l status were not completed. Frequent licensee panel walkdowns failed to detect the misaligned valve O2.2 Control Rod Drive (CRD) System Walkdown (71707) !
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The inspectors performed a verification of proper system alignment and indication on November 6. The inspectors verified local valve, component, and indications were in their correct position and operating properly. Selected system TS setpoints were verified to meet the TS acceptance criteria. No deficiencies were observe Miscellaneous Operational Issues (92901)
0 (Closed) Licensee Event Report (LER) 50-325/98-002-00: Operation Prohibited by Technical Specification (TS) 3.0.4. On April 26,1998, Unit 1 entered Operational Condition 5, Refueling, from Operational Condition 4, Cold Shutdown, without meeting the Limiting Conditions For Operation (LCO) specified in TS 3.5.4, Suppression Poo The Unit 1 Senior Reactor Operator (SRO) did not follow General Procedure OGP-06,
" Cold Shutdown to Refueling (Head Unbolted)," which specified the positioning of the reactor mode switch to the Refuel positio The LER indicated that the licensee did not recognize this event as reportable until May 13,1998. The licensee did not consider TS 3.0.4 in their original reportability determination. This LER was not submitted until June 6,1998. The licensee took prompt action to initiate an active LCO when the condition was found and the mode switch was positioned to the Refueling position when ongoing testing allowed. All of the TS action statements were met while the reactor mode switch was not in the Refuel position. The SRO was counseled. This issue was reviewed in licensed operator requalification trainin The inspectors concluded that a plant mode change was made without meeting the LCO established by TS 3.5.4.b and was therefore prohibited by TS 3.0.4. This 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 50-325/98-10-02, Operation Prohibited by TS 3.0.4.
( 08.2 LClosed) Unresolved item (URI) 50-325(324)/98-07-01: Elevated Temperatures. The inspectors observed that temperature limits established in the UFSAR for the Reactor Building Closed Cooling Water (RBCCW) system supply temperature and the
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recirculation pump motor ambient temperature had been exceeded. The RBCCW J
, temperature increase was determined to be a result of hot weather conditions. The
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recirculation pump motor ambient temperature stated in the UFSAR was determined to be incorrect. The inspectors reviewed the corrective actions for the elevated
, temperatures and determined that no violation of regulatory requirements occurred.
The temperature changes either were under licensee evaluation or had no significant
- a.dverse impact on the performance of any safety related function. The licensee initiated actions to revise the UFSAR temperature setpoints.
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II. Maintenance M1 Conduct of Maintenance l l
l' M1.1 Condensate Storaae Tank (CST) Surveillance Test (61726) j
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- The inspectors observed the performance of Maintenance Surveillance Test OMST-
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RLE260, "RLE CST Water Level Functional Test and Channel Calibration," Rev. 2, on
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October 14. The inspectors observed that technicians reemphasized a lesson-learned
- before performing steps that had resulted in past equipment inoperability. No
deficiencies were identifie M1.2 Hioh Pressure Coolant inlection (HPCl) Pressure Instrument Channel Calibratiorj
> (61726)
! On November 19, the inspectors observed the channel calibration of the HPCI low j pressure instruments 1-E41-N001B(D). Test equipment used was verified to be within
its current calibration cycle. Selected test data was independently verified for accurac The inspectors observed good communication and procedural usage. The inspectors noted good worker practices concerning work on a contaminated system and '
maintaining dose received as low as reasonably achievable. The test was completed satisfactorily with no deficiencies noted. The technicians demonstrated satisfactory understanding of the test process and equipment usag M1.3 Conventional Service Water Pumo Maintenance Insoection Scooe (62707)
On October 28 the inspectors observed maintenance activities on the 2A Conventional Service Water (CSW) pump motor oil cooling coil Observations and Findinos The licensee identified water in the oil of the 2A CSW Pump from a predictive maintenance oil sample test. The motor was disassembled and the cooling coils were tested for leaks. The leak test indicated a small leak at the threads of an inlet transition piece to the cooling coil. The licensee stated that the transition piece may not have been installed properly since February 13,1997, when the cooling coil was replaced on as part of corrective actions in accordance with the requirements of the Maintenance
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Rule (MR),10 CFR 50.65(a)(1). There were several problems identified concerning the erosion failure of the cooling coils. The licensee had taken appropriate actions to remedy the erosion problems in accordance with the MR requirement The inspectors reviewed the performance history of the Service Water system regarding water getting into the oil of the pump motors. The inspectors reviewed three years of MR data including logs and MR Expert Panel meeting activities. The inspectors identified four occasions where water got into the oil as a result of erosion or installation problems on cooling coil transition piece The inspectors discussed the performance history of the transition piece erosion and installation problems with the licensee. As a result of that discussion the licensee conducted a historical review of the transition piece problems and upgraded an existing CR to a significant adverse condition based on the transition piece erosion and installation problems being considered a MR repetitive functional failure. The licensee informed the inspectors that a MR panel will review this problem to determine the corrective actions required to meet the MR requirement Conclusions A detailed review of the MR history and performance criteria for the CSW system identified several reoccurring problems with the oil cooler transition piece that the licensee had not considered for overall system Maintenance Rule performance. As a result of the transition piece problems, the licensee upgraded an existing CR to a significant adverse conditio M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Unit 2 On-Line Feedwater (FW) Heater Maintenance Insoection Scope (62707)
The inspectors observed on-line maintenance activities on the Unit 2,4B and 5B FW heaters on October Observations and Findinas On October 6, the licensee isolated the 4B and SB FW heaters due to the inability to controllevelin the heaters. The licensee aligned the plant for reduced FW temperature operations. The 4B and SB FW heaters were isolated, drained, inspected. The licensee determined that tubes were leaking. The necessary tubes were plugged and the FW heaters were returned to service on October 2 The inspectors observed that the FW heater maintenance activities were well planned
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the restoration of drained heaters that had been opened for maintenance with the unit l operating. The licensee took a careful approach to the heater restoration to ensure no challenges to the plant occurred during the evolution. The inspectors observed no l problems or deficiencies with the FW heater maintenance.
l Conclusions l The inspectors observed well planned and executed maintenance activities associated l with the on-line repair and restoration of the Unit 2,4B and 5B FW heaters. This was l demonstrated by a slow and careful approach for work preparation and work activities.
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A special procedure developed for the activity identified special precautions and l limitations as well as contingency plans for unexpected condition M3 Maintenance Procedures and Documentation M3.1 Standby Liauid Control (SLC) System Deficiencies l insoection Scope (62707)
The inspectors reviewed performance issues for recent licensee identified deficiencies for the SLC syste Observations and Findinas During a routine document review the inspectors noted several deficiencies on the SLC system. The inspectors reviewed the MR Scoping and Performance Criteria and the MR Event Log Report for the system. The inspectors identified three occasions where the 1-C41-F015, SLC Pump Suction Header Drain Valve, was noted to be leaking by the seat. To repair the valve would require a system outage. To prevent system leakage, the licensee installed a pipe cap on the system drain line. The leaking valve problems were not recorded in the MR event log. Over a period of time, the leaking valve and later the leaking pipe cap, caused an unintentional loss of SLC tank inventory. The inspectors questioned the licensee regarding the absence of these leaking valve events (tank level decrease) in the MR event lo The licensee conducted a review of the events and MR event log entries and subsequently included one of the inspector identified items as a functional f ailure. In addition, unavailability time was added to the SLC system for two events noted previously by the inspectors and for a greater than expected loss of tank contents on October On October 9, the licensee performed maintenance activities to replace the leaking pipe cap that was located down stream of valve 1-C41 F015. To stop the leak, the SLC tank outlet valve was closed. This rendered both loops of SLC inoperable and the licensee entered the appropriate TS Limiting Condition for Operation. The inspectors observed that the maintenance work was viewed as minor maintenance and had not been formally scheduled and reviewed. The inspectors concluded the licensee took prompt and appropriate corrective actions for this even .
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8 Conclusions The licensee did not adequately consider all aspects of SLC system maintenance work activities. As a result, maintenance to repair a drain line leak resulted in rendering both loops of the SLC system inoperable. Events associated with the SLC system leaking drain valve problems were not always logged into the MR event log and system and component unavailability times were not accurately tracke M8 Miscellaneous Maintenance issues (92902)
M8.1 (Closed) Violation (VIO) 50-325/98-05-01: Scaffolding Erection Noncompliance. The licensee corrected all the discrepant scaffolding at the time of discovery. The contract supervisor was counseled. A work standdown was conducted for training of all personnel qualified to work with scaffolding and actions were taken to ensure training and lessons learned would be reviewed for each refueling outage. Procedural enhancements were made specifying precautions, clarifying requirements for erecting scaffolding near safety-related equipment. The inspectors concluded that the licensee's corrective actions were appropriat M8.2 (Closed) Inspection Followuo item (IFI) 50 325(324)/96-15-04: Condition of Remote Shutdown Panels. This item identified adverse material conditions in the Unit 1 and Unit 2 Remote Shutdown Panels (RSDP). On November 20, the inspectors observed the material condition of the RSDPs and found that the material condition was improve The licensee rewired the 2-CAC-TR-778, Primary Containment isolation system temperature recorder, restored the overall wiring condition of both cabinets, changed a power supply on Unit 1 because of excessive corrosion, and restored the overall cabinet condition by thorough painting and cleaning inside the cabinet Ill. Enaineerina E2 Engineering Support of Facilities and Equipment E Standbv Licuid Control Heat Trace (37551)
The inspectors reviewed the modifications made to the SLC heat trace system made by Engineering Service Request (ESR) 98-00144, SLC Insulation Replacement. The inspectors reviewed the ESRs with emphasis on approvals, screening criteria, and UFSAR changes. No discrepancies were identifie E2.2 Investiaation and Corrective Action for Neclear Service Water Isolation Valve Failure [nspection Scope (92903)
The inspectors reviewed the licensee's hardware investigation and corrective action for the repeated surveillance test failures of 1-SW-V106, Reactor Building Closed-Cooling Water (RBCCW) Heat Exchanger Service Water inlet Valve. The licensee's investigation of the cause of the failure of this Motor-Operated Valve (MOV) was documented in Significant Adverse Condition Evaluation (SACE) CR 98-01845. The
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, I inspectors reviewed this SACE and relevant information described in Engineering !
Service Request (ESR) 98-00538, "1-SW-V106 Operability," Revision 0 dated i October 14,1998; and in "DP Test Evaluation for 1-SW-V106," dated September 30, j 1998, which evaluated recent dynamic testing performed on 1-SW-V106. Additional !
information was obtained through interviews with licensee personne !
b. Observations and Findinas The safety function of the 1-SW-V106 valve was to close to assure sufficient cooling flow for safety related equipment, such as emergency diesel generators. In a July 24, i 1998 quarterly stroke tima surveillance test, this valve failed to fully close, resulting in a l
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leak of approximately 2000 gallons per minute (gpm), later progressing to 3200 gpm in a subsequent test. The licensee's evaluation determined that closure was adequate to consider the valve operable. (Note: As discussed in NRC Inspection Report (IR)
50-325(324)/98-09, the inspectors previously reviewed the licensee's evaluation of valve operability.)
The inspectors noted that the licensee's review of the valve's maintenance history revealed repeated failures to fully close during stroke time testing. According to ESR 98-00538, after instellation on October 22,1996,1-SW-V106 failed every quarterly surveillance test performed up to and including the July 24,1998 test, except for one test performed during the May 1998 Unit 1 refueling outage. ESR 98-00538 indicated that the closing of this motor-operated valve was intended to be controlled by the actuator's limit switch. The licensee stated that the actuator's torque switch was still in the control circuit but that it was required to be set at its highest torque setting (5), such that it would not prevent closure of the valve. The valve was stroked again on September 23 as part of the licensee's investigation. During that test, the licensee found that the closing motor current measured was relatively low and could be indicative of either a collapsed spring pack or improper torque switch setting. Licensee engineering personnel initially informed the inspectors that they believed that the valve failures were caused by a torque switch trip of the valve motor and that this was due, at least in part, to a weak spring pack. However, the inspectors noted that, following a May 30,1997, surveillance test failure of the valve, the licensee had verified the proper operation of the torque switch, limit switch, and spring pack. On September 30, licensee personnel replaced the spring pack and torque switch, and installed a Teledyne Smartstem to permit more accurate diagnostic evaluation of valve performance through measurement of operating torque. The licensee stroked the valve after replacement of the torque switch and spring pack and found that, while it closed successfully, the closing torque exceeded the value predicted by the valve sendor by about 55 percen As additional corrective action, the licensee increased the surveillance test frequency for this valve from quarterly to monthly anr1 initiated plans to replace and evaluate the valve at the next refueling outag The inspectors questioned wheth,er the licensee had adequately evaluated the repeated failures of the valve. The licensee's reliance on motor current to assess operating torque i was particularly questioned, as the inspectors considered this method inaccurate. The l inspectors asked if the spring pack removed from the valve had been tested, since it was believed to have been weak. They were informed that the licensee intended to test the spring pack but that the test had not been performed yet, though approximately one
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month had passed since replacement of the spring pack. As the spring pack had been presumed to be a cause or contributor to the torque switch trip, the inspectors l
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expressed concern with the delay. The inspectors noted that the spring pack test would provide data which could bc used to more accurately assess the torque that resulted during the failure. If the spring pack was found to be satisfactory, excessive torque could have occurred during the torque switch trips, possibly resulting in unevaluated damage to the valve's actuato In response to the inspectors' concern, the licensee promptly tested the spring pack together with the torque switch removed from valve 1-SW-V106 and found that they functioned properly. The licensee also inspected the valve actuator to verify that there was no damage due to any excessive torque. During a subsequent licensee evaluation, maintenance personnel indicated their belief that, due to an unusual installation, they had failed to recognize that the closing torque switch on valve 1-SW-V106 had been set at 2.5 rather than the required setting of 5. This lower setting was a plausible cause of the previous repeated failures of the valve to clos The inspectors found that a number of the licensee's actions in responding to the recent failure of this valve were appropriate and conservative. Examples included post-failure diagnostic testing, replacement of the spring pack and torque switch, increased monitoring frequency, and plans to replace the valve at the next refueling outag However, two deficiencies were noted:
1) In spite of repeated failures of the valve to fully close due to torque switch trips, the licensee had failed to verify that the torque switch was set correctly at its highest torque setting; and 2) The valve actuator spring pack was replaced because it was believed to be weak and, therefore, a potential cause of the failure of the valve to fully clos However, until questioned by the inspectors, the licensee did not test or otherwise evaluate the removed spring pack to determine if it had contributed to the valve failur The above deficiencies in the licensee's actions to identify and correct the repeated failure of valve 1-SW-V106 were considered representative of noncompliance with the requirements of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. This noncompliance was identified as Violation 50-325/98-10-03, inadequate Evaluation of Valve Failur c. Conclusions Deficiencies were identified in the licensee's hardware investigation and corrective actions for the surveillance test failures of 1-SW-V106, RBCCW Heat Exchanger Service Water Inlet Valve. The inspectors identified a violation for the licensee's failure to establish that the torque switch of this valve was set correctly at its highest torque setting and to test or otherwise evaluate the condition of the spring pack believed to have contributed to the failure.
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E3 Engineering Procedures and Documentation E Turbine Stoo Valve (TSV) Closure and Turbine Control Valve (TCV) Fast Closure Reactor Protective System (RPS) Scram Function Inspection Scooe (37551. 71707)
The inspectors reviewed the effect of plant evolutions on the TSVRCV automatic scram functio Observations and Findinas On October 22, the inspectors reviewed engineering design input Calculation 2C72-0022, "84 deg F Final Feedwater Temperature Reduction, Effects on Turbine Control Valve Fast Closure & Turbine Stop Valve Closure Scram Setpoints, at Power Uprated Conditions," Revision 1. The inspectors found that the calculation assumed that the mass flow rate of the steam at the main turbine was equal to the mass flow rate of the FW. The inspectors questioned this assumption by considering the effect of evolutions which diverted significant portions of steam from the main turbine, such as the HPCI and RCIC systems and the opening of turbine bypass valve The inspectors found that the operation of HPCI, RCIC, and turbine bypass valves while in reduced FW temperature operations, at low power levels of between 30 to 40 percent, would cause the TSVRCV automatic scram features to be bypassed, and therefore inoperable, at a reactor power of approximately 30 percent reactor power. The TS require that the TSVRCV scram features be enabled whenever reactor power is equal to or greater than 30 percent. The inspectors determined that during normal plant operations it was possible to bypass the TSVRCV scram features if the turbine bypass valves were open and certain plant conditions existe The inspectors found no examples in the past three years of being in the plant conditions when the TSV\TCV scram was bypassed. The inspectors questioned the acceptability of operating the plant during licensed operations and evolutions knowing that a TS required automatic scram feature may be bypassed. The inspectors questioned if the plant design basis considered disabling of this scram function above 30 percent RTP and if this had an impact on the Minimum Critical Power Ratio (MCPR)
limi The licensee generated CR 98-02565, TSV/TCV RPS bypass. The licensee acknowledged that the TSVRCV scram function could be bypassed as described when reactor power was greater than 30 percent. At the close of the inspection period, the licensee had not determined whether the TSVRCV closure automatic scram function disablement at powers greater than the TS allowed value was considered in the plant design basis and its effect on MCPR limit. This is being tracked as IFl 50-325(324)/98-10-04, TSV/TCV Scram Function Operability.
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12 Conclusions The inspectors determined that the TSV/TCV closure automatic scram function could be bypassed at reactor power levels greater than that allowed by TS. An IFl was opened pending response to questions concerning whether the TSVUCV closure automatic scram function disablement at powers greater than the TS allowed value was considered in the plant design basis and its effect on the MCPR limi E8 Miscellaneous Engineering issues (92903)
E (Closed) VIO 50-325(324)/97-12-08: MCPR Database Error. The licensee performed a comprehensive review of the database to verify that no additional errors existed. A review was initiated for the B2C13 and B1C11 databases to ensure that other errors had not been introduced in to the databases. To prevent future errors, the method which caused the introduction of the error was automated. The non-10 CFR 50 Appendix B guidelines used to control this activity were identified as a contributing factor for this error and upgraded to 10 CFR 50 Appendix B procedures. This issue resulted in identification that some safety-related activities performed by licensee corporate groups were not always implemented or controlled in accordance with 10 CFR 50, Appendix These programmatic deficiencies are being tracked through a violation issued for the Shearon Harris Nuclear Plant in NRC IR 50-400/97-1 E8.2 (Closed) VIO 50-325(324)/97-520: Failure to Take Corrective Action for High Drywell Temperature. The licensee responded to this VIO in correspondence dated February 26,1998, in conjunction with VIO 50-325/97-13-03. The licensee addressed the elevated temperatures by replacing the failed drywell cooler fans in a maintenance outage. The snubber seallife program was revised to be based on actual snubber samples taken during refueling outages. ~i raining concerning this event was conducte Out-of-specification readings for drywell temperatures are now tracked on the morning status sheet E8.3 (Ocen) IFl 50-32_5K3J_4)/97-08-10: Review of Control Room Ventilation Issues. The licensee has performed some sealing in the control room to improve the marginal positive pressures which have historically existed during operation in the smoke / radiation protection mode. The sealing has not resulted in the improvement desired and additional efforts are planned to increase the positive pressure margin. The licensee has initiated ESR 97-00474, Closure of 2-VA-2J-D-CB, to provide a permanent modification to afford greater positive pressure in the control room by permanently closing the control emergency recirculation omper,2-VA-2J-D-CB. Testing planned in 1999 will confirm the success of this modification. This IFl will remain open until efforts to improve the margin are complet E8.4 (Open) IFl 50-325(324)/98-03-01: Completion of MOV Program Followup item Inspection Scope This followup item was opened to track the licensee's completion of commitments that addressed issues raised during NRC inspections of the licensee's implementation of Generic Letter (GL) 89-10, " Safety-Related Motor-Operated Valve Testing and
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Surveillance." The commitments were documented in letters from the licensee dated
, October 2,1997 (BSEP 97-0408) and March 20,1998 (BSEP 98-0058). The NRC inspectors assessed the status of the commitments through a review of related documentation and interviews with licensee personne b. Observations and Findinas
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BSEP 98-0058. Commitment 1 - Marain Enhancement Modifications The licensee committed to implement modifications to increase the thrust capability margins of seven Unit 1 and six Unit 2 MOVs. Three of the Unit 1 MOVs were scheduled to be modified prior to the current inspection. The Unit 2 modifications were scheduled for completion in 199 The inspectors found that the licensee was completing the modifications on schedul The three Urdt 1 MOV modifications were complete. In addition, one Unit 2 MOV
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modification had been completed ahead of schedule. The inspectors verified j satisfactory completion of the modifications through a review of the engineering, work,
and tests documented in the following records:
- ESR 98-00068, " Increase Gear Ratio for Valve 1-E51-F007," Revision Work Request / Job Order (WR/JO) 98 AAZR1, field complete 5/4/9 WR/JO AGHA 0001, dated 5/3/98.
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e ESR 98-00069," Replace Motor for 1-G31-F001 to increase Torque," Revision WR/JO 98-00AAZS1, field complete 5/9/9 e ESR 98-00070," Replace Motor for 1-G31-F004 to increase Torque," Revision WR/JO 98-AAZT1, field complete 5/9/9 * ESR 98-00199, "2-E11-F004A, B, C, & D Full Stroke Bypass," Revision WR/JO 98-ACBR1, field complete 8/19/9 (Note: The modification had only been completed for valve "D". The licensee's commitment was to complete the modifications in 1999.)
About 30 percent of the modifications had been completed. The remaining modifications were scheduled to be completed by the end of outages commencing in 1999 and 2000. The inspectors reviewed the licensee's " Action item Assignment" database and verified that the incomplete commitment actions were scheduled and being tracked to completio BSEP 98-0058. Commitment 2 - Differential Pressure Tests of Gate. Globe, and Butterfiv Valves The licensee committed to conduct differential pressure tests of 27 gate, globe, and butterfly valves and provided a completion schedule. The schedule specified completion of tests on six valves within the current quarte .. . - -. . . . .
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The inspectors found that the tests scheduled for completion in the current quarter had been performed. In addition, the licensee had tested one valve scheduled to be tested in the next quarter. The results of one of the tests (on valve 1-E11-PDV F068B) were questioned by the licensee and a retest had been recommended. The inspectors found that the licensee's " Action item Assignment" database identified and tracked the remaining tests, which were scheduled to be completed in 1999 and 2000. The inspectors verified completion of the tests through a review of the following records:
e "DP Test Evaluation for 1-E11-PDV-F068A," test date 7/24/98; evaluation review date 10/23/9 e "DP Test Evaluation for 1-E11-PDV-F0688," test date 8/20/98; evaluation review date 10/22/98. (Licensee evaluation recommended retest.)
e "DP Test Evaluation for 1-E21-F031 A," test date 8/13/98; evaluation review date 10/23/9 * "DP Test Evaluation for 1-E21-F0318," test date 9/10/98; evaluation review date 10/23/9 e "DP Test Evaluation for 1-E41-F001," test date 5/25/98; evaluation review date 10/23/9 e "DP Test Evaluation for 1-SW-V19," test date 9/9/98; evaluation review date 10/23/9 e "DP Test Evaluation for 1-SW-V106," test date 9/30/98; evaluation review date 10/23/9 About 20 percent of the differential pressure tests had been successfully complete However, one of the two butterfly valves tested,1-SW-V106, RBCCW Heat Exchanger Service Water inlet Valve, may not have provided test results representative of expected performance. This valve experienced a failure preceding the differential pressure test that was inadequately evaluated, as discussed in Section E3.1. Three similar valves are scheduled for testing in 199 BSEP 98-0058. Commitment 3 - Ball Screw Rate of Loadina and Efficiency Tests The licensee committed to conduct tests on eight MOVs with ball screw stem nuts to establish rate of loading and efficiency values for these MOVs. The commitment specified completion of tests on three valves within the current quarte The inspectors found that the licensee had completed the three MOV tests scheduled
, for the current quarter and that the licensee's " Action item Assignment" database l tracked the tests remaining to be completed. The completed tests had been performed on valves 1-E11-PDV-F068A,1-E11-PDV-F068B, and 1-E41-F001. The rate of loading identified was estentially zero, consistent with the licensee's prediction. The efficiency values calculated from the test results varied widely but were not of concern because
the licensee relied on the measured stem factors.
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15 BSEP 98-0058. Commitment 4 - Reactor Water Cleanuo (RWCU) System Valve 1-G31- l F004 Packina Adiustment :
The licensee committed to diagnostically test this valve to verify that the packing load !
was acceptable following a previous packing adjustment. The test was to be completed '
l in the second quarter of 1998. The inspectors verified that the licensee had :
diagnostically tested this valve', as committed, through a review of the test record. The j test was completed on May 9 and documented on WR/JO 97-AFEG1. The packing load ,
was acceptabl l BSEP 98 0058. Commitment 5 - Safety Evaluation (SE) Limitations of Electric Power j
Research Institute (EPRI) Performance Prediction Methodoloav (PPM)
The licensee had used the EPRI PPM to predict thrust requirements for Anchor Darling Double Disk (AD DD) gate valves but had not documented meeting the limitations specified by the NRC SE for use of the PPM. The licensee committed to review the setup calculatlons for AD DD gate valves and incorporate the SE limitations by August 1,199 The inspectors found that the licensee had satisfactorily performed the review but that the review was documented as a response (dated June 22,1998) to CR 97-02911, Task 66, rather than in the setup calculations. The inspectors questioned whether incorporation into a document that was not part of the MOV program was appropriat In response, the licensee initiated Action item Assignment Project ID 97-02911, Task ID 66.01, specifying incorporation of limitations review into MOV Valve Factor Calculation BNP-MECH-MOV-VF. The inspectors considered this an adequate alternative document in which to incorporate the revie BSEP 98-0058. Commitment 6 - Industry Survey of Globe Valves to Confirm Acceotability of Valve Factor Assumotion The licensee committed to perform an industry survey by July 1,1998, to confirm the
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adequacy of the 1.1 valve factor it had applied in calculating globe valve thrust requirements. The inspectors found inat the licensee had completed the survey and reviewed the results, which were included and assessed in the following documents:
- " Resolution of BNP Globe Valve Survey, CR 97-02911 Task #67," dated 6/12/98 e "CR 97-02911 Task 67.01," dated 9/3/98
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67.01," dated 10/23/98 e Calculation BNP-MECH MOV-VF," Review of BNP As Tested Valve Factors &
. Determination of VF Values to be Used for BNP GL 89-10 Motor-Operated
, Valves," Revision 3 l \
The inspectors reviewed the survey and assessment documents and found various aspects that were unclear or contained errors. These problems prevented the inspectors from determining whether the licensee had fulfilled this commitment. As a l result, the licensee generated a CR task to assure that the documents incorporating the globe valve survey information would be satisfactory for audit. The task was scheduled for completion by January 16,199 BSEP 98-0058. Commitment 7 - Residual Heat Removal System Valve 2-E11-FC24B Toraue Switch Adiustment i j
The licensee committed to adjust the torque switch for MOV 2-E11-F024B to reduce excess seating torque. This commitment was scheduled to be completed during the Unit 2 refueling outage planned for the second quarter of 1999. The NRC inspectors verified that the licensee had identified and was tracking this commitment in the " Action item Assignment" databas ~
BSEP 98-0058. Commitments 8 and 9 - Commitment Status Submittals The licensee committed to provide submittals to the NRC at specified dates detailing the status of the commitment actions stated in the March 20,1998 (BSEP 98-0058)
commitment letter. The first submittalis to be provided to the NRC by January 29, i 1999, and a full completion status submittal is to be provided by January 31,200 l BSEP 97-0408. Commitment 12 - DC Powered MCV Stroke Time Test Methodoloav l
The licensee committed to evaluate the methodology that had been used to determine the stroke times of DC MOVs under design basis loads. As described in Inspection NRC IR 50-325(324)/98-03, the inspectors found that the evaluation had been completed but had not resolved previous concerns regarding the independence of stroke times from loading conditione. In response, the licensee initiated CR 98-00541 to address these concern The inspectors found that the licensee had completed ar' extensive study in response to their concerns, which was documented in ESR 98-00438, " Evaluate DC MOV Stroke Time Methodology," Revision 0, dated August 19,1998. This study incrementally evaluated the stroke times of the licensee's MOVs under the predicted design basis
- loading. The inspectors reviewed this study and determined that it resolved their I concerns.
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17 Conclusions The inspectors concluded that this item will remain open pending completion of the licensee's commitment actions. Specifically, the planned butterfly valve testing and the I licensee's globe valve survey documents will be reviewed during a subsequent i
' inspection. For the butterfly valves, ~a future review was planned due to the limited testing that had been completed and due to interest in the additional results related to a i recently-failed valve (1-SW-V106). For the globe valve survey, this was due to the ;
review difficulties resulting from errors and/or unclear document' entrie ]
l IV. Plant Suonort R1 Radiological Protection and Chemistry (RP&C) Controls R Occuoational Radiation Exoosure
- Insoection Scope (83750) '
The inspectors reviewed personnel monitoring, radiological postings, posted radiation dose rates, contamination controls within the Radiologically Controlled Area (RCA), and container labeling. The inspectors also reviewed licensee records of personnel radiation exposure and discussed ALARA program details, implementation and goals with licensee representatives. In addition, the inspectors toured the health physics -
single point access location, instrument calibration area, exit portal monitors, radioactive waste storage areas, and " hot" machine shop to evaluate health physics practice ' Observations and Findinos Records reviewed showed that the licensee was tracking and trending Personnel Contamination Events (PCEs). The licensee had tracked approximately 77 PCEs for the 1998 calender year to date which included both skin and clothing contamination Radiologically controlled areas including the radioactive waste storage area and " hot" machine shop were appropriately posted and radioactive material was appropriately stored and labeled.'
The Calender Year 1998 site exposure goal had been set at 400 person-rem. As of November 20, the site cumulative dose was estimated at 369 person-re Conclusions Radiological controls in radioactive material storage areas, the instrument calibration area, and the " hot" machine shop, were appropriate. These areas were properly posted and radioactive materials were appropriately labele !
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R2 Status of Radiation Protection (RP) Facilities and Equipment R2.1 Process and Effluent Radiation Monitors trisoection Scone (84750)
The inspectors reviewed selected licensee procedures for, and records of, required surveillances on process and effluent radiation monitors in order to evaluate monitor performance. The inspectors also reviewed licensee records regarding radiation monitor availabilit Observations and Findinos The monitors required by TS were available 94.9 percent of the time for the month of July. The monitor with the most time unavailable was the Main Stack Gas Monitor, which was out-of-service for about 4.5 days during this period. Compensatory sampling was performed at this sample location by the licensee during the out-of-service time. The licensee has set on cverage operability goal of 98 perc"* 'or these monitors. The i monitors' year-to-date (1998) average operability was 98.9 perce Conclusions Radiation and process effluent and environmental monitors were being maintained in an operational condition in compliance with TS requirements and UFSAR commitment R3 Transportation of Radioactive Materials R3.1 Review of Transoortation Proaram Ln_soection Scope (86750)
The inspectors evaluated the licensee's radioactive material transportation program for proper implementation of the revised Department of Transportation (DOT) and NRC transportation regulations for shipment of radioactive materials (10 CFR 71.5 and 49 CFR Parts 100 through 177). Observations and Findinas The inspectors reviewed selected procedures and determined that they adequately addressed the following: 1) assuring that the receiver has a license to receive the material being shipped; 2) assigning the form, quantity, type, and proper shipping name of the material to be shipped; 3) classifying waste destined for burial; 4) selecting the type of packaging required; 5) assuring that the appropriate radiation and contamination limits were met; and 6) preparing shipping paper The inspectors reviewed a sample of shipping papers and receipt surveys. The inspectors determined that the shipping papers were complete and that the shipping and receipt surveys were complete and met the requirement ,
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19 Conclusions The licensee effectively implemented a program for shipping and receiving radioactive materials as required by NRC and DOT regulation i R8 Miscellaneous RP&C issues (92904)
I R (Closed) Violation 50-325(324)/98-06-09: Failure to Perform Procedurally Required :
Surveys. This violation concerned a failure to perform approximately nine required l routine monthly radiation surveys during the months of March and April 1998. The l inspectors reviewed the licensee's Reply to a Notice of Violation dated August 5,199 l The inspectors selectively reviewed the corrective actions which included the revision of l Procedure OE&RC-0100," Routine /Special Dose Rate Survey." The items verified and I reviewed by the inspectors were found to be satisfactor R8.2 (Closed) Violation 50-325(324)/97-14-01: Failure to Control a Locked High Radiation '
Area in Accordance with Procedure. A Locked High Radiation Area (LHRA) was left unattended and the entrance was not secured with designated special cal-core locks prior to leaving the area unguarded. The inspectors reviewed the licensee's Reply to a Notice of Violation dated January 30,1998. The inspectors observed the corrective actions and controls established by the licensee. The inspectors found that the controls, which ensured that the Instrument Calibration Room would not become a LHRA, were satisfactor R8.3 (Closed) Violation 50-325(324)/97-14-02: Failure to initiate a Condition Report Upon identifying a LHRA Not Controlled in Accordance with Procedure. The inspectors reviewed the licensee's Reply to a Notice of Violation dated January 30,1998. The inspectors selectively observed the corrective actions and independently verified that those actions were satisfactor R8.4 (Closed) Violation 50-3?5(324)/97-11-07: Failure to Label Containers of Radioactive Material in Accordance with Procedure. The inspectors reviewed the licensee's Reply to a Notice of Violation dated November 26,1997. The inspectors selectively observed the corrective actions and independently verified the training conducted to correct knowledge deficiencies. The inspectors found the closure package complete and independent verification did not identify any discrepancie R8.5 (Closed) Violation 50-325(324)/97-09-06: Failure to Comply with Transportation of Radioactive Material Audit Requirements Per 10 CFR 71.137. The inspectors reviewed the licensee's Reply to a Natice of Violation dated October 15,1997. The inspectors reviewed Condition Report 97-01275, dated March 27,1997, and selectively observed the corrective actions and independently verified that actions stated in the reply were implemented. The inspectors found the closure package complete and independent verification did not identify any discrepancie R8.6 (Closed) Inspection Followuo item 50-325(324)/97-15-01: Test Fixture Discrepancie The inspectors reviewed the licensee's actions to control contamination of pressure testing instruments. The inspectors selectively observed the corrective actions and independently verified that those actions were satisfactor .
R8.7 (Closed) Inspection Followuo item 50-325(324)/98-06-10: Review the Licensee Resolution of the Elevated and Variations of Background on Friskers and Exit Portal Monitors. The inspectors reviewed the licensee's actions to resolve the elevated and variable background of friskers and exit portal monitors. The inspectors selectively observed the corrective actions and independently verified that the relocation and planned additional shielding would reduce background dose rates and consequenti/
increase detection capabilities of exit portal monitor R8.8 (Closed) Unresolved item 50-325(324)/98-06-11: Evaluation of Detection of Fe-55 l Concentrations or Quantities of Radioactive Material and Calibrate Instruments for Radiation Monitored. The inspectors reviewed the licensee's repod, "An Evaluation of the Instrumentation Used to Unconditionally Release Material from the Brunswick l Nuclear Plant," Revision 1, dated September 4,1998, and the recent Low Level '
Radioactive Waste Analysis dated November 10,1998. The inspectors determined that the licensee had adjusted the detection limits and was using the stated equipment at the l equipment's detection limit capabilities. The inspectors also determined, based on the l licensee's recent waste characterization, that iron-55 was traceable using the more l easily detected Cobalt-6 l S2 Status of Security Facilities and Equipment l
S Security Fence (71750)
On November 10, the security fence was inspected with emphasis on relocation of a l section of the protected area fence. The protected area was inspected and found to be I intact. The isolation zone was found to be clear with no obstructions. The work l activities for relocation of a section of the protected area fence were to incorporate the I security and administrative buildings into the protected area. The transition plan for relocation of the fence was reviewed. The work activities were carried out in accordance with the Security Plan and no problems were identifie l l
F4 Fire Protection Staff Knowledge and Performance F Diesel Generator (DG) Buildina Announced Fire Drills Inspection Scope (71750)
l The inspectors observed and reviewed several"back shift" fire drills to assess fire brigade performance, reviewed the adequacy of drill controls, and the performance of l drill controllers and evaluator I Observations and Findinas I
The inspectors observed fire drills on November 3 and 17 and reviewed the results of a l fire drill conducted on November 21. The inspectors observed that a fire brigade member did not follow procedural safety precautions for backaraft protection in accordance with the drill procedure. The inspectors observed that the controller intervened and prompted a brigade member to take correct actions. The inspectors later discussed the incorrect actions with the controller and evaluator. A CR was
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l initiated to address the inspectors' observation. The inspectors reviewed the CR and observed that the inappropriate influencing of a drill participant by the controller was not recorded as a deficienc l On November 11, the inspectors observed another fire drill and noted that two drill objectives were not met. Fire drill objective criteria 4 required that all members report in full turn-out gear. The Shift incident Commander never donned turn-out gear. Drill objective criteria 6 required the use of prefire plans to direct activities. The plans ;
required that certain doors be verified closed and backup hose teams be establishe '
These actions were not complete l The inspectors attended the verbal drill critique and reviewed the written drill critique and observed that many verbal drill critique deficiencies were not included in the written critique. Additionally, all objectives were considered by the licensee to be satisfactor i After review of the written drill critique and discussion with the licensee the inspectors determined that similar issues were noted by the licensee during the November 21 dril The inspectors reviewed NAS Assessment B-FP-98-01, Brunswick Fire Protection -
Triennial, issued July 27,1998. The inspectors observed that the assessment identified i some of the same concerns that the inspectors had identified. This included prompting by the drill controller and that, although many of the drill performance weaknesses were discussed in the post drill critique, the .vritten drill critique did not adequately reflect the needed improvement The inspectors concluded that little improvement was observed from the observations l identified in the July triennial fire protection assessment. Deficiencies observed in l previous drills were still occurring. The inspectors noted that the omission of drill performance issues from the written drill critiques allowed a misrepresentation of actual brigade performance. In addition, the inspectors observed that the drill objectives were not weil defined and lacked objective criteria to accurately measure satisfactory performance. Based on observed performance and review of several drills with brigade !
performance problems similar to those identified in July 1998, and additional concerns with the adequacy of drill controls, a weakness was identified. The licensee indicated that a reevaluation of the adequacy of the drill objectives was underway and revisions to ;
the drill procedures were pendin l l
c. Conclusion I Little performance improvement was noted during the recent fire drills as compared to I previous drills and the licensee July,1998, triennial fire protection assessmen Deficiencies observed in previous drills were still occurring. Omission of drill performance issues from the written drill critiques allowed a misrepresentation of actual brigade performance. Some fire drill objectives were not well defined and lacked objective criteria to accurately measure satisfactory performance. Based on observed performance and reviews a weakness was identified for fire brigade performanc ;
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F8.1 (Closed) URI 50-325(3241/97-07-03: Lack of ASSD Compensatory Measures. During
inspection activities described in NRC IR 50-325(324)/97-07, the inspectors observed that two Alternate Safe Shutdown (ASSD) impairments had been generated. These two impairments were associated with the RCIC and HPCI systems and had the potential to affect their operability. These systems were identified in the site Safe Shutdown Analysis Report for reactor level and pressure control during ASSD action One of the systems was assigned to each of the safe shutdown trains identified in the analysi The inspectors reviewed Plant Program Procedure OPLP-1.5 " Alternate Safe Shutdown Capability Controls," Rev. 7, which was the required procedure at the time and observed that the procedure contained weaknesses with respect to having multiple systems out of service. The procedure stated, in part, that inoperable components should be restored to operable status within 14 days or prepare a report to the plant General Manager within 30 days outlining the actions taken, the cause of the inoperability, and the plans and schedules for restoring the components to operable status. The procedure lacked specific instructions for actions to be taken if multiple trains required for alternate safe shutdown capability were inoperable and did not address compensatory measure Based upon the inspectors concerns about procedure weakrasses that allowed multiple ,
train inoperabilities and the lack of specific actions to be taken, the licensee revised the applicable procedur The inspectors reviewed Rev. 3 of Plant Program Procedure OPLP-1.5, dated September 12,1997, and observed that the licensee had included elements of NRC Information Notice IN 97-48 " inadequate or inappropriate Interim Fire Protection Compensatory Measures." Additionally, the procedure included specific actions to be taken if one or both trains of alternate shutdown equipment on a unit were inoperabl The procedure required that the Operations Manager and Plant General Manager be informed when certain train inoperabilities were identifie The inspectors concluded that procedure weaknesses existed. The licensee later took action to correct the procedure weaknesses and revised Plant Program Procedure OPLP-1.5 " Alternate Safe Shutdown Capability Controls."
V. Manaaement Meetinas XI Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on December 2,1998. The licensee acknowledged the findings presente . - - .. - - , - . . . . - -. - . - . -.
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PARTIAL LIST OF PERSONS CONTACTED Licensee A. Brittain, Manager Security R. Deacy, Manager Outage and Scheduling N. Gannon, Manager Maintenance J. Gawron, Manager Nuclear Assessment M. Herrell, Training Manager E. Hux, Director Site Operations 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 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operations IP 71750: Plant Support Activities IP 83750: Occupational Radiation Exposure IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 92901: Followup - Operations IP 92902: Followup - Maintenance IP 92903: Followup - Engineering IP 92904: Followup - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-325/98-10-01 VIO Standby Gas Treatment Valve Misalignment (Section O2.1)
50-325/98-10-02 NCV Operation Prohibited by TS 3.0.4 (Section 08.1)
50-325/98-10-03 VIO Inadequate Evaluation of Valve Failure (Section E2.1)
50-325(324)/98-10-04 IFl TSV/TCV Scram Function Bypass (Section E3.1)
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Qloped 50-325/98-002-00 LER Operation Prohibited By Technical Specification 3. (Section 08.1) 1 50-325/98-10-02 NCV Operation Prohibited by TS 3.0.4 (Section 08.1)
50-325(324)/98-07-01 URI Elevated Temperatures (Section 08.2)
50-325/98-05-01 VIO Scaffolding Erection Noncompliance (Section M8.1)
50-325(324)/96-15-04 IFl Condition of Remote Shutdown Panels (Section M8.2)
50-325(324)/97-12-08 VIO MCPR Database Error (Section E8.1)
50-325(324)/97-520 VIO Failure to Take Correction Action for High Drywell Temperature (Section E8.2) l l
50-325(324)/98-06-09 VIO Failure to Perform Procedurally Required Surveys (Section R8.1) l 50-325(324)/97-14-01 VIO Failure to Control a Locked High Radiation Area in .
I Accordance with Procedure (Section R8.2)
50-325(324)/97-14-02 VIO Failure to initiate a Condition Report upon Identifying a LHRA not Controlled in Accordance with Procedure ,
(Section R8.3)
50-325(324)/97-11-07 VIO Failure to Label Containers of Radioactive Materialin Accordance with Procedure (Section R8.4)
50-325(324)/97-09-06 VIO Failure to Comply with Transportation of Radioactive Material Audit Requirements Per 10 CFR 71.137 (Section R8.5)
50-325(324)/97-15-01 IFl Test Fixture Discrepancies (Section R8.6)
50-325(324)/98-06-10 IFl Review the Licensee Resolution of the Elevated and Variations of Background on Friskers and Exit Portal Monitors (Section R8.7)
50-325(324)/98-06-11 URI Evaluation of Detection of Fe-55 Concentrations or Quantities of Radioactive Material and Calibrate Instruments for Radiation Monitored (Section R8.8)
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- Dispssed 50-325(324)/97-08-10 IFl Review of Control Room Ventilation issues (Section E8.3)
50-325(324)/98-03-01 IFl Completion of MOV Program Followup Item (Section E8.4) l l
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.h-i 25-Discussed 50-325(324)/97-08-10 'lFI Review of Control Room Ventilation Issues (Section E8.3)
50-325(324)/98-03-01 IFl Completion of MOV Program Followup Item i (Section E8.4)
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