ML20040C196

Responds to NRC 811001 Ltr Re Violations Noted in IE Insp Repts 50-324/81-23 & 50-325/81-23.Corrective Actions:Visual Insp of Fire Barrier Penetrations to Be Developed,Scheduled & Tracked & Fire Brigade Members Trained

ML20040C196
Person / Time
Site:	Brunswick
Issue date:	12/23/1981
From:	Dietz C CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20040C193	List: ML20040C196 ML20040C197
References
BSEP-81-2235, NUDOCS 8201270382
Download: ML20040C196 (3)

Text

'

t' Cp&L Mw'w DEDQgg Carolina Power & Light Company 0I 000 20 P j , 53 Brunswick Steam Electric Plant P. O. Box 10429 Southport, NC 28461-0429-December 23, 1981 FILE: B09 '.3514 SERIAL: BEEP /81-2235 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Ccmmission Region II, Suite 3100 101 Marietta Street N.W.

Atlanta, GA 30303

Dear Mr. O'Reilly:

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 & 2 LICENSE NOS. DPR-71 AND DPR-62 DOCKET NOS. 50-325 AND 50-324 SUPPLEMENTAL RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS Following the submittal of our response on November 5, 1981, to IE Inspection Report 50-324/81-23 and 50-325/81-23, an error was identified with respect to the response to Violation A. Also, during follow-up telephone conversations between Mr. B. J. Furr, Vice President - Nuclear Operations, Mr. C.~ R. Dietz, General Plant Manager, and Mr. R. C. Lewis, of your office, discussing the response to this inspection report, it was agreed that a supplemental commitment was to be made relative to Violation B. Accordingly, a revised response to Violations A and B is hereby submitted. The responses to Violations C and D remain as initially submitted.

A. Violation (Level V)

Technical Specification Section 4.7.8.a requires the fire barrier penetrations protecting safety-related areas to be verified functional by a visual inspection at least once per 18 months.

Contrary to the above, fire barrier penetrations protecting safety-related areas of Unit No. 1 Reactor Building, Control Building, 23-foot elevation of Diesel Generator Building and A0G Building had not been verified functional by a visual inspection within 18 months following the June 5, 1979 inspection.

8201270382 820105 3 PDR ADOCK 05000324 .m G PDR in; c _n

q .., _

CP&L Response (Revised)

With respect to all of the structures identified, CP&L agrees that a violation of the technical specifications occurred. The violations which did occur have been previously addressed in Licensee Event Report 1-81-60. In summary, the failure to have the surveillance completed was the result of personnel error.

The surveillances have now been completed, proper scheduling and tracking to prevent a recurrence of the violatiot has been established, and full compliance has been achieved except for the A0G Building.

In the case of the A0G Building, plant personnel had not developed surveillance procedures since the A0G System had been deactivated and a new system, with attendant structural changes, was planned for future installation. Due to the location of the CAD System in a portion of the

. structure, however, this action was not entirely correct. Following identification of this problem, a fire watch was instituted per Technical Specification 3.7.8 in the areas of the building where CAD System components are installed. Action is being taken to develop the requisite surveillance procedure, and comp 12 tion is planned for March 31, 1982.

B. Violation (Level V)

Technical Specification Section 6.8.1.f requires written procedures to be established, implemented and maintained on the fire protection program.

Contrary to the above, the procedures for the fire protection program were not met in that:

(1) All of the fire brigade members had not received the initial fire brigade training as required by Fire Protection Procedure FP-1, Plant Fire BrigadesSection III.B.

(2) Fire brigade drills were not conducted for each quarter of 1979, 1980 and 1981 as required by Fire Protection Procedure FP-1, Plant Fire BrigadesSection III.C.l.

CP&L Response We concur that the first of the items listed above is an item of significant concern and we do not deny this citation. Each specific item is discussed below.

(1) The status of fire brigade members regarding initial training was discussed previously in our response to I&E Inspection Report (50-324, 325; 77-18) dated November 7, 1977. Our letter of response was dated December 2, 1977. In essence, our response at that time stated that FP-1 was not intended to specify that initial training would be provided prior to assignment to the Fire Brigade, only that it would be provided.

m. )

f\ N.

• We do feel, however, that a problem of significant concern was identified by Mr. Miller with respect to the training of Shift Foremen.

Accordingly, Brunswick is changing its policy, effective February 1, 1982, to require initial fire brigade training as a prerequisite for brigade membership, not only for Shift Foremen but all members.

Additionally, initial fire brigade training courses are in progress per schedules established before the inspection. Attendance of the untrained Shift Foremen is being emphasized and all will have completed this training by the February 1, 1982 date.

(2) This statement was based on Revision 3 of FP-1 which requires a fire drill each quarter; however, Revision 3 was not approved for use until May 14, 1981. The previous revisions of FP-1 stated that drills would be conducted on a basis of four per year, not. one per quarter. Since four drills per year were held in 1979 and 1980, no violation occurred. In 1981, compliance with FP-1, Revision 3, could not be required until after the procedure's approval date. Allowing a reasonable time for implementation, this means that the third quarter of 1981 marked the first quarter to which FP-1, Revision 3, was applicable. A drill was held during that quarter and two drills were held during the fourth quarter. Therefore, we do not believe that this item of the violation is appropriate.

A subsequent review of FP-1, Revision 3, and follow-up communications with members of your staff indicate that the procedure does not provide sufficient assurance that all fire brigade members receive adequate drill training.

Therefore, FP-1 will be revised by January 1, 1982, to include the following requirements:

1. At least one drill will be held per quarter by each operating shift.

2. As a minimum, all fire brigade members will participate in at least two drills per year.

Very truly yours, C '

y C. R. Dietz, General Manager Brunswick Steam Electric Plant RMP/gvc cc: Mr. R. A. Hartfield Mr. V. Stello, Jr.

Mr. C. R. Dietz, having first been duly sworn, did depose and say that the information contained herein is true and correct to his own personal knowledge or based on information and belief.

u, =-

,b?vo $. Saa Ndtary)Public Commission Expires My$% /3 lMGL C1

.