ML20050A611
| ML20050A611 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/11/1982 |
| From: | Furr B CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20050A610 | List: |
| References | |
| NUDOCS 8204010490 | |
| Download: ML20050A611 (6) | |
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89&L Carolina Power & Light Compatiy:C %,: 8
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MAR 111982 /i' ' FT A
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Mr. James P. O'Reilly, Regional Administrator United States Nuclear Regulatory Commission Region II 101 Marietta Street, N.W., Suite 3100 Atlanta, GA 30303 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS
Dear Mr. O'Reilly:
Carolina Power & Light Company (CP&L) has received I.E. Inspection Report 50-324/82-01 and 50-325/82-01 for the Brunswick Steam Electric Plant Unit Nos. 1 and 2, and finds that it does not contain any information of a proprietary nature.
The report identified two items in noncompliance with NRC require-ments and one item that deviates from commitments made to the NRC. These items sud CP&L's response to each are addressed in the attachments to this letter.
Should you have any questions concerning this letter or the attachments, please contact my staff.
Yours very truly, B.
. Furr Vice President Nuclear Operations MSG /1r (nec9)
Attachments cc:
Mr. J. Van Vliet (NRC)
B. J. Furr, having been first 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 Notary (Seal)
My commission expires:
Mr Cwmmuion fgira 6 5 86 8204010490 820324 PDR ADOCK 05000 street. P. o. Box 1551
- Raleigh. N. C. 27602 G
ATTACHMENT A BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 IE INSPECTION REPORT 50-324/82-01 AND 50-325/82-01 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS As a result of the NRC inspection conducted on December 15, 1981 - January 15, 1982 and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violations were identified at Carolina Power & Light Company's (CP&L) Brunswick Steam Electric Plant (BSEP) Unit Nos. 1 and 2.
Violation A (Severity Level IV)
Technical Specification 3.4.5, action statement b.1, requires, when primary coolant specific activity exceeds 0.2 uCi/ gram dose equivalent I-131, coolant samples shall be taken and analysis is to be performed at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> until the activity returns within the limit.
Contrary to the above, on December 18, 1981, a primary coolant sample taken at 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> exceeded 0.2 uCi/ gram dose equivalent I-131 and the subsequent required samples once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> were not taken.
Carolina Power & Light Company's Response CP&L acknowledges BSEP was in violation of NRC requirements. On December 18, 1981, following a greater than 15 percent planned reduction in reactor power level, a reactor coolant I-131 dose equivalent analysis was performed in accordance with technical specifications and established procedures. This analysis revealed an I-131 dose equivalent of 0.04171 uCi/gm. Later that day following a reactor scram, another reactor coolant sample was obtained for a I-131 dose equivalent analysis. The responsible technician found a qualitative analysis of the sample could not be performed due to masking of energy spectrum peaks of constituent iodine isotopes. In accordance with established procedures, the sample was held for recounting at a later time.
On December 19, 1981, another technician performed an iodine dose equivalent analysis on the sample; however, that technician also encountered energy spectrum masking of the iodine isotopes. He also set aside the sample for reanalysis at a later time in accordance with plant procedures.
On December 20, 1981, while reviewing the results of the previous dose equivalent analyses performed on the December 18, 1981, post-scram sample, a Senior Technician determined that the overall qualitative analysis of the sample had exceeded the specified limit with a value of 0.2665 uCi/gm. His review indicated that although all the iodine isotopes could not be identified on the analyses performed on December 18 and December 19 due to masking, the obtainable isotope values were high enough to indicate that the limit of
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0.2 uCi/gm would be exceeded if all values were identified.
It was then determined that the nine subsequent dose equivalent analyses had not been performed within the required time frames as required by Technical Specifi-cation 3.4.5, action statement b.1.
Following this discovery, a once-per-three-hour sampling frequency, in lieu of the required once-per-four-hour sampling frequency, was imposed until the iodine dose equivalent returned to within specified activity limits.
The involved personnel were counseled to be aware of fluctuating isotope energy spectrums while performing iodine dose equivalent analyses. In addition, a specific training class concerning counting and calculating requirements associated with performing iodine dose equivalent analyses was conducted in order to better familiarize class participants with identifying and reporting iodine dose equivalent fluctuations. Plant procedures appli-cable to performing radioiodine analysis have been reviewed and revised as required in order to help prevent similar events in the future, i
A similar event involving iodine sampling occurred on January 18, 1982, when an iodine sample was not taken within six hours as required following a recirculation pump trip which resulted in a greater than 15 percent power change. A sample was taken approximately 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> after the transient and the results showed that I-131 dose equivalent was less than 0.2 uCi/gm.
An investigation of this event determined the Control Operator and Senior Control Operator failed to notify plant Chemistry personnel that a sample was required due to the power transient. The involved personnel were counseled on the failure to have a required surveillance performed. Plant procedures were reviewed and it was determined the procedures did not provide adequate guidance to the operators to ensure that the required samples be taken.
Appropriate procedures were then revised to provide the operators with required guidance to ensure compliance following future power changes.
Violation B (Severity Level IV)
Technical Specification 6.8.1.a requires written procedures to be implemented for items recommended in Appendix A of NRC Regulatory Guide 1 33, November, 1972.
Item E of Appendix A specifies each safety-related annunciator should have its own written procedure.
Contrary to the above, the written procedure for safety-related annunciator HPCI ROOM DOOR OPEN was not implemented frem December P8 to December 30, 1981, in that the procedure allows only one door to be open, whereas, both doors were open during the aforementioned period.
Carolina Power & Light Company's Response CP&L acknowledges BSEP was in violation of an NRC requirement.
When this item was identified, the doors were immediately closed. An investigation of the event determined that procedures were not adequate to assure that only one l
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HPCI door was open at any one time, and that the Shift Foreman was aware of why that door was open. To prevent having both doors open at one time, signs are-being placed on the doors to warn all personnel of the necessity to keep the doors closed. Also, the Auxiliary Operator's Daily Surveillance Report (DSR) is being revised to provide better clarity on what actions he should take if any of these doors are found open. Engineering is also reviewing the problem to determine if additional annunciation for "both doors open" should be considered or other possible engineering actions should be implemented.
The signs and revisions to procedures will be completed by March 31, 1982.
Any engineering actions will be performed when and as deemed appropriate.
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BRUNSWICK STEAM ELECTRIC PLANT, Uh1T NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 IE INSPECTION REPORT 50-324/82-01 AND 50-325/82-01 RESPONSE TO DEVIATION FROM COMMITMENT ATTACHMENT B i
Based on the results of NRC inspection conducted on December 15, 1981 through January 15, 1982, the NRC found that certain BSEP activities appeared to deviate from commitments to the Commission as indicated below:
COMMITMENT Appendix M, Response MS.33 of the Final Safety Analysis Report states that complete isolation of each core spray room exists up to Elevation 20'; that pipe chases exist between core spray and residual heat removal (RHR) pump rooms, however the pipe chases are sealed to prevent flooding; that the RHR and high pressure coolant injection (HPCI) pump rooms are separated by walls from -17' up to Elevation +5'; and that no single, postulated event could occur which would compromise this mechanical separation. Water tight bulk head doors are provided for access to the HPCI room from each RHR room.
DEVIATION Contrary to the above, on December 22-23, 1981, during power operation a pipe chase between the north core spray and north residual heat removal rooms was opened to allow pumping water from the north RHR sump to the ncrth core spray sump. Additionally, on December 28-30, 1981, both watertight doors to the HPCI room were open during reactor operation. With both HPCI room doors open, common mode flooding could occur between the north RHR, HPCI, and south RHR rooms.
Carolina Power & Light Company's Response CP&L acknowledges a deviation from commitments made to the NRC. The problem of the HPCI doors being open is addressed in Attachment A, Violation B of this report. The pipe chase between the RHR and core spray rooms has been closed.
The pipe chase between the RHR and core spray rooms was allowed open by a Shift Foreman to permit the removal of water in the RHR room using the core spray sump pumps. The Shift Foreman failed to recognize the FSAR requirement and that removing these covers would violate a commitment. To prevent a future occurrence, signs are being placed on the pipe chase covers stating that Shift Foreman permission is required to remove the cover. The signs will also reference the FSAR requirement for those covers to be in place. Also, all licensed personnel will be reinstructed on this requirement through the required reading log and the Daily Night Order book so that inadvertent
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f removal of the covers can be eliminated. The signs will be installed by i
March 19, 1982. An entry was placed in the Operation Daily Night Order book on March 8, 1982, for all Operations personnel to review, and a copy of this report will be placed in the required reading files.
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