ML20024F368

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IE Insp Repts 50-324/83-17 & 50-325/83-17 on 830509-0609. Noncompliance Noted:Failure to Comply W/Tech Spec Action Statement Re Initiation of Hot Shutdown within 20 H When Augmented Offgas Sys Out of Svc
ML20024F368
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 07/06/1983
From: Bemis P, Garner W, Myers D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20024F355 List:
References
50-324-83-17, 50-325-83-17, NUDOCS 8309090318
Download: ML20024F368 (6)


See also: IR 05000324/1983017

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGION 11

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101 MARIETTA ST N.W SUITE 3100

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ATLANTA. GEORGIA 30303

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Report Nos.: 50-325/83-17 and 50-324/83-17

Licensee:

Carolina Power and Light Company

411 Fayetteville Street

Raleigh, NC 27602

Docket Nos.:

50-324 and 50-325

License Nos.:

DPR-62 and DPR-71

Facility Name: Brunswick 1 and 2

Inspection at Brunswick site near Wilmington, North Carolina

Inspectors:

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D. O. Myers, Senior Resident Inspector

Date ' Signed

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4/30/93

L. W. Garner, Resident Inspector

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Approved by: 64 k,

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P. Bemis, Section Chief 0

Date Signed

Division of Project and Resident Programs

SUMMARY

Inspection during the period May 9 - June 9,1983

Areas Inspected

This special, unannounced inspection involved 50 inspector hours on site in the

review of the circumstances surrounding the condenser off gas radiation monitor-

ing system inoperability and the off gas stack isolation valve inoperability.

Results

Of the 2 areas inspected, one violation was identified in one area; (Failure to

comply with Technical Specification action statement, paragraph 5.)

8309090318 830829

PDR ADOCK 05000324

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REPORT DETAILS

1.

Persons Contacted

Licensee Employees

A. Bishop, Technical Support Manager

J. Boone, Engineering Supervisor

L. Boyer, Assistant to General Manager

T. Brown, I&C/ Electrical Maintenance Supervisor (Unit 1)

G. Campbell, Mechanical Maintenance Supervisor (Unit 2)

  • J. Chase, Manager - Operations

G. Cheatham, E&RC Manager

R. Coburn, Director QA/QC

J. Cook, E&RC Foreman

R. Creech, I&C/ Electrical Maintenance Supervisor (Unit )

  • C. Dietz, General Manager

J. Dimmette, Maintenance Manager

W. Dorman, QA Supervisor

  • K. Enzor, Director Regulatory Compliance
  • J. Harness, Plant Operations Manager

W. Hatcher, Security Specialist

A. Hegler, Manager - Operations

P. Howe, Vice President, Brunswick Nuclear Project

W. Martin, Principle Engineer / Operations

G. Milligan, Principle Engineer /0nsite Nuclear Safety Section

D. Novotny, Regulatory Specialist

  • J. O'Sullivan, Prcject Specialist

R. Poulk, Senior Regulatory Specialist

C. Treubel, Mechanical Maintenance Supervisor (Unit 1)

L. Tripp, RC Supervisor

Other licensee employees contacted included technicians, operators and

engineering staff personnel.

  • Attended exit interview

2.

Exit Interview

The inspection scope and findings were summarized on June 10, 1983 with

those persons indicated in paragraph I above. Meetings were also held with

senior facility management periodically during the course of this inspection

to discuss the inspection scope and findings.

3.

Licensee Action on Previous Inspection Findings

Not inspected.

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Unresolved Items

Unresolved items were not identified during this inspection.

5.

Condenser Off-Gas Radiation Monitoring System Inoperability

On May 10, 1983, the licensee notified the NRC, via a 10 CFR 50.72 Immediate

Report, that the Unit 2 condenser off gas radiation monitors had been

isolated when they were required by Technical Specification (TS) 2.5.2.d to

have been operable. Unit 2 was at 55% power at the time of this discovery;

Unit I was in cold shutdown and was unaffected by this event. The condenser

off gas radiation monitors were promptly returned to their proper operable

alignment and a licensee investigation was initiated.

The condenser off gas radiation monitoring system is one of two process

radiation monitoring systems designed to initiate automatic actions to limit

the release of radioactive gaseous effluents from the reactor via the main

stack.

The condenser off gas radiation monitors sample tha non-condensible gaseous

discharge of the steam jet air ejectors (SJAE) enroute to the off gas

system's 30 minute hold-up line.

The radiation monitors (DIZ-K601 A & B)

have alarms that alert the operator if the activity of the condenser

non-condensible gaseous discharge reaches a level that, if continued, could

allow the annual discharge rate to be exceeded. Also, the monitors provide

a radiation Hi-Hi alarm which initiates an isolation of the off gas system

(by closing valves A0G-HCV-102 after a fifteen minute time delay) to prevent

exceeding TS short term gaseous release rates.

In the event of a significant fuel failure the main steam line radiation

monitors would provide a redundant action of limiting off site releases by

initiating the closure of the main steam isolation valves. This action

stops the supply of fission products and reduces the transport of these

fission products to the environs through the condenser by securing the steam

supply to the SJAE, causing them to isolate - effectively " bottling-up" the

condenser. The Unit 2 main steamline radiation monitoring system was

operable and capable of providing this isolation function during this event.

Subsequent licensee investigation of this event determined that as the

result of the failure to complete the proper restoration of clearance 2-506,

several valves were mispositioned including off gas radiation monitor

iselation valves OG-V35 and 0G-V36. The improper valve position of OG-V35

and OG-V36 resulted in the inoperability of the monitors.

Clearance 2-506 was established on April 10, 1983, for plant modification

80-2288. This was an extensive clearance for an off gas system modification

and was subsequently pcrtially restored to support restart of the Unit 2

reactor, which was shutdown for an equipment maintenance outage.

It was

this partial restoration, which occurred on April 17, 1983, that called for

the opening of valves OG-V35 and OG-V36. The licensee's post-event

investigation determined that four valves which were expected to have been

reopened were left closed during the clearance restoration. Two of these

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valves (OG-V35 and OG-V36) isolated the radiation monitors.

The remaining

two valves isolated a sample vial which had no adverse effect on plant or

processes.

Interviews with the personnel responsible for restoration of

this. clearance determined that a lack of concise communications between the

control operator ordering the restoration and the auxiliary operator

- performing the restoration resulted in the valves being left closed.

Unit 2

did not restart from the equipment maintenance outage until May 8, 1983.

As a consequence of OG-V35 and 0G-V36 being closed, a low flow condition

existed in the monitoring system when the SJAE were placed into service,

during restart of Unit 2 on May 8, 1983. During the period May 8-10, 1983,

several control room indications that should have alerted them to this

condition were repeatedly overlooked or misinterpreted by the operations

staff. These indications included:

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The abnormally low off gas activity level indicated by the SJAE

monitors (<10 mr/hr. versus normal 100 mr/hr.) for the existing power

level.

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Failure of the SJAE monitor strip chart recorders to indicate an

increasing activity level consistent with the increasing levels

indicated by the main stack monitor and the main steam line radiation

monitors as. plant power increased. These monitor strip chart recorders

are located on the main control board in the control room.

The continued presence of the annunciator indicating a hi/ low flow

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condition in the monitor sample lines after the SJAE had been placed in

service.

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Recording in the Daily Surveillance Report (DSR) of virtually the same

once per shift readings, for the SJAE monitors, for several consecutive

shifts even though power had increased from 0% to approximately 55%.

The closed radiation monitor isolation valves were discovered on May 10, as

a result of a concern noted by the shift supervisor, during shift turnover

at 11:30 p.m. on May 9, that the SJAE radiation monitors did not appear to

be responding normally for increasing reactor power.

Subsequent investi-

gations by the operating shift personnel lead to the identification of the

closed isolation valves and the presence of the hi/lo flow alarm. The

isolation valves were reopened and the monitors returned to operable status

at 4:00 a.m. on May 10, 1983.

Technical Specification Appendix B, paragraph 2.5.2.e, requires that if the

augmented off gas (A0G) is out of service and the air ejector off gas

monitors are inoperative, a reactor shutdown shall be initiated so that the

reactor will be in the hot shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Contrary to the above, during the period from 11:00 p.m. , on May 8,1983, to

4:00 a.m., on May 10, 1983, with the Unit 2 augmented off gas system out of

service and the air ejector off gas monitors inoperative, a reactor shutdown

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was not initiated and the reactor was not in hot shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,

although, sufficient information existed to alert the operator to the

conditions existing which required the reactor shutdown.

This is a violation and applies to Unit 2.

6.

Off-Gas Stack Isolation Valve Inoperable

On May 21, 1983, the licensee reported that control power to the Unit 2

solenoid controlled, air operated off gas stack isolation valve was found

off, rendering the valve inoperable.

For the existing plant conditions, the

Unit 2 off gas stack isolation valve was required by Technical Specification 2.5.2.d. to have been operable.

The control power for the solenoid was

promptly restored returning the stack isolation valve to an operable status

and a licensee investigation of this event was initiated.

Unit 2 was at 90%

of rated thermal power at the time of this event; Unit I was shutdown for

refueling. The Unit 1 stack isolation valve, although similarly affected,

was not required to be operable in the existing plant condition.

The off gas stack isolation valves are designed to close, after a 15 minute

time delay, in response to a radiation Hi-Hi level trip of the condenser

off gas radiation monitors.

This valve closure isolates the 30 minute

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hold-up line from the main stack to prevent exceeding short term gaseous

release limits. These stack isolation valves (1-A0G-H0V-102 for Unit I

and 2-A0G-H0V-102 for Unit 2) are air (to close) operated valves with their

air signals controlled by its respective solenoid valve.

The solenoid valve

must energize to cause a stack isolation valve to close.

At approximately 12:30 p.m. on May 21, 1983, a contractor startup engineer,

working on the installation of the augmented off gas system, notified the

Unit 2 shift foreman that electric panels HB5 and HB8 were deenergized. An

auxiliary operator (AO) was dispatched to the panels and they were

immediately reenergized. The HB5 and HB8 electric distribution panels,

which are physically located in the augmented off gas building, provide

control power to the Unit 1 and Unit 2 off gas stack isolation valve

solenoids.

The licensee began an immediate investigation of this event, conducting

extensive interviews with operations and construction personnel to determine

when and by whom panels HB5 and HB8 were deenergized. This investigation

has failed to determine the exact time at which the panels were deenergized

or by whom, although, it has been determined that the panels were known to

be energized at approximately 1:00 a.m. on May 21, 1983 (12 1/2 hours prior

to their being found deenergized). Additionally, it has been determined that

these panels had been deenergized and then reenergized several times during

the previous week.

At the time of the event, panels HB5 and HB8 were undergoing extensive

modification in conjunction with the installation of the augmented off gas

system. The associated modification procedures required that these panels

be worked in the energized condition.

Interviews with the contractor

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startup engineers, working on newly installed systems powered from these

panels, revealed that during the week prior to May 21, these newly installed

systems had beenf ound deenergized on several occasions. These occurrences

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were not reported _to the plant staff as the startup engineers attributed the

deenergized status to wiring problems in the newly installed equipment. The

startup engineer who reported-the deenergized panels to the control room on

May 21 did so as a result of trouble shooting associated with these modifi-

cations being denergized.

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Despite the inability to identify the specific individual or individuals

responsible for deenergizing panels HB5 and HB8, the licensee has attributed

the repositioning of these breakers to construction personnel not desiring

to work on the associated modifications in the energized condition. Breaker

and valve lineup checks of other systems located in the A0G building have

not identified any additional deficiencies.

It is noted'that no remote indication of control power availability for

these valves, valve position indication is powered from a separate circuit

which remained energized throughout this event, thus, no information was

available which should have alerted the operator to this condition.

No

other equipment important to safety was affected by deenergizing these

panel s.

As a-result of_this event, the licensee has initiated increased administra-

tive control designed to minimize the potential for reoccurrence of this or

similar type events.

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Technical Specifications'2.5.2.e require that if the condenser off gas

monitors are incapable of initiating automatic closure of the stack

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isolaticn~ valves, a shutdown shall be initiated so that the reactor will be

~in hot shutdown.within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. .Since the_ licensee took.immediate

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corrective action'(reenergizing panels HB5 and HBS) following the identifi-

cation'of the deenergized panels and' subsequent investigation indicated that

the licensee did not have knowledge of this condition nor did other means

(remote breaker position indication) exist which should have alerted the

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licensee, the' action required by Technical Specification 2.5.2.e were

satisfied within the allotted time interval.

No violations or deviations occurred in this area.

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