ML19347E828

Responds to NRC 810316 Ltr Re Violations Noted in IE Insp Repts 50-324/81-02 & 50-325/81-02.Corrective Actions:Tech Spec Change Requested Re Svc Water Sys Operability & Operators Trained on Svc Water Specs

ML19347E828
Person / Time
Site:	Brunswick
Issue date:	04/14/1981
From:	Furr B CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19347E827	List: ML19347E828
References
NO-81-624, NUDOCS 8105130461
Download: ML19347E828 (4)

Text

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Carolina Power & Light Companj ,

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, 20 FILE: NG-3513(B) SERIAL: NO-81-624 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street, N.W.

Atlanta, GA 30303 -

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 & 2 LICENSE NOS. DPR-71 AND DPR-62 DOCKET NOS. 50-325 AND 50-324 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS

Dear Mr. O'Reilly:

The Brunswick Steam Electric Plant (BSEP) has received IE Inspection Report 50-324/81-02-and 50-325/81-02 and finds that it does not contain any information of a proprietary nature.

The report identified two items that appear to violate NRC requirements. These items and Carolina Power & Light Company's response to each are addressed in the following text:

Violation A Technical Specification 3.7.1.2.b requires that, in condition 4 (cold shutdown) with only one service water pump operable, ~

restore at least two service water pumps'to operable status within seven days or declare the core spray system (CSS), the Low-Pressure Coolant Injection (LPCI) system, and the diesel generators inoperable and take the action' required tur Specifi-cations 3.5.3.1, 3.5.3.2, and 3.8.1.2. Technical Specification 3.5.3.1 requires that, "with both CSS subsystems inoperable, ...

verify that at least one LPCI subsystem is operable within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />." Technical Specification 3.5.3.2 requires that with one or more LPCI subsystems inoperable, take the action required by Specification 3.5.3.1. Technical Specification 3.8.1.2.b requires two diesel generators be operable, as required to operate ECCS Systems.

Contrary to the above, with the plant at cold shutdown, at 1420. hours on December 9, 1980, the conventional and nuclear service water systems were secured to effect repairs on an unisolable check valve. This action rendered all service water

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'Mr. Jcmes P. O'R2 illy April 14, 1981 pumps for Unit No. 2 inoperable resulting in LPCI, CSS, and che diesel generators becoming inoperable. The nuclear and conventional service water systems were not returned to service until 2015 hours0.0233 days <br />0.56 hours <br />0.00333 weeks <br />7.667075e-4 months <br />. Tha CSS subsystems, LPCI Systems, and the diesel gene-rators were not declared inoperable during this time period; and no verification was made to ensure at least one LPCI subsystem was operable.

~ Carolina Power & Light Company's Response Carolina Power & Light Company (CP&L) acknowledges that this event was a violation of NRC requirements. This violation -

occurred due to an incorrect interpretation of Technical Speci, fication 3.7.1.2.b. The site interpretation perceived that the diesel generators should be declared inoperable if service water was secured; the Core Spray and LPCI Systems should also be declared inoperable because the diesel generators were inoperable. At the time of the occurrence, four operable service water pumps were available on the Unit No. I nuclear header. Since only three-pumps are required to support Unit No. 1 operation, the fourth pump was considered available to support compliance with the Unit No. 2 Technical Specifications requiring one pump to be available. With this service water

supply available to the diesels (the diesels can receive service water from either unit through parallel supplies), the diesel generator could be declared operable; and therefore, Core Spray and LPCI Systems could also be considered operable. Therefore, all Unit No. 2 service water was secured.

In an effort to prevent this and other similar problems in the

future, several actions have been or are being t,aken. mA request for a Technical Specificaton change with respect to. Service Water System operability has been submitted which wi1L , allow -

a work on any portion of either the conventional or nuclear header. A conference was held with NRR on this' requested change, and an amendment is expected following our providing additional information as discussed in the meeting. The

s. procedure regulating the use of Operating Work Permits has been i revised to require a PNSC review prior to implementation. This will help assure that the correct and safe interpretation of the Technical Specifications has been reached. All licensed operators are receiving training on the interpretation of the service water specifications to better understand the basis. l

! This training will be complete by April 30, 1981.

, Violation B l -l

. Technical. Specification.6.9.1.8 requires that certain types of events shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirmed oy telegraph, mailgram, or facsimile transmission to the Director of the Regional Office no later than the first working day following the event.

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14- e Mr..Jamez P. O'Railly April 14, 1981' Technical Specification 6.9.1.8.b requires such a report for operation of the unit or affected systems when any parameter or operation subject to a limiting condition for operation is less conservative than the least conservative aspect of the limiting

, conditions for operation established in the Technical Specifications.

, i Contrary to the above, the event described in Violation A was reported by telephone via-the NRC Emergency Notification System and to the Region II office; but the follow-up confirmation by facsimile was not transmitted until December 22, 1980.

Carolina Power & Light Company's Response .

Carolina Power & Light Company denies that it violated the NRC requirement of failing to submit a written report in a timely manner as required by Technical Specifications. As described in Violation A, it was believed by those knowledgeable in the service water event that a violation was not occurring with the

, service water pumps secured. On December 9, 1980, at 2033, when service water and shutdown cooling had been restored, it was discovered that primary coolant temperature was greater than 212 F, with primary containment not in effect. The NRC EmergencyNotificationgystem(ENS)wasutilized.atthistime to report exceeding 212 F with primary containment not estab-lished. The ENS was not used to report " . . . operation less I

conservative than the least conservative aspect of the limiting condition for operation . . . " in relation to the Service Water System.

While reviewing information in preparation .for submitting LER 2-80-107, exceeding 212 F with primary containment not set, on December 19, 1980, it was determined t_ hat ~the most 1,imiting condition of Technical Specification 3.7.1.2.b had been exceeded. ~

This was discussed with the General Manager and reported to Mr. Austin Hardin at 1630 on December 19, 1980; and a facsimile was submitted on the first working day following the identi-fication of the event.

! The management control systems that allowed Violation A to j

occur have been reviewed and changes have been made in that OWP's must be approved by PNSC prior to Laplementation. This will ensure that the' proper interpretation of technical specifiiations has been reached prior to taking a system out of service. In addition, a detailed review is being conducted of the reporting requirements and the mechanisms for that reporting in existing plant procedures. Following

, this review, a dedicated effort will.be.made to combine, revise,. .

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i and/or establish procedures to make reportability assessments more. effective. Training will then be given to appropriate personnel with the integrated effort to be completed by June 30, 1981.

Yours very t. ly,

. J. Furr Vice President Nuclear Operations .

DCS: jab

• b.Q. M , having been first duly sworn, did depose and siy that the information contained herein is true and correct to his own personal knowledge or based upon in'ormation and belief.

a My commission expires: h, h ggg Ndfary (Seal) /

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