ML20054G994
| ML20054G994 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/24/1982 |
| From: | Furr B CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20054G982 | List: |
| References | |
| NUDOCS 8206220475 | |
| Download: ML20054G994 (6) | |
Text
l.
l.
3 ! '; N -
Carolina PciselNIl@t QOlupany,
g MAY 2 41982 02 MAY 28 AIO : 2 0 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 50-324/82-10 and 50-325/82-10 for the Brunswick Ster.m Electric Plant Unit Nos. 1 and 2, and finds that it does not contain any information of a proprietary nature.
The report identified four items that appear to be in noncompliance with NRC requirements. These items and CP&L's response to each are addressed in the attachments to this letter.
As discussed previously with your staff, our response date to this report was extended to May 24, 1982.
Should you have any questions concerning this letter or the attachments, please contact my staff.
Yours very truly, B.s. Furr Vice President Nuclear Operations MSG /lr (n-58)
Attachments cc:
Mr. R. C. DeYoung (NRC)
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 upon information and belief.
L ech Notary (Seal)
My commission expires: u, unuma hun 6 8 56 mmy-.r m m
,m a#--
ux.
1
% mop mn e. naw. N c2m2 8206220475 820609 PDR ADOCK 05000324 C Z ~ ~ ~ "'~ " -' ~ 2 C N C O M G
f ATTACHMENT 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 50-324/82-10 AND 50-325/82-10 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS As a result of the NRC inspection conducted on January 19-21, 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)
A NRC order issued July 10, 1981 to CP&L confirmed implementation by January 1, 1981 of procedures to verify correct performance of operating activities as specified by NUREG-0737 Clarification of TMI Action Plan Requirements item I.C.6.
In a CP&L letter of December 31, 1980 to Darrell G.
Eisenhut, Director of Licensing that was submitted in response to NUREG-0737, the following statement with regard to item I.C.6 (Verify correct performance of operating activities) was made.
"When returning equipment to service which has not been under clearance, for example, instruments or hydraulic snubbers removed for surveillance testing, a second person will verify proper system alignment unless functional testing can be performed without compromising plant safety, and can prove that all equipment, valves, and switches involved in the activity are currently aligned. The person performing the verification will have the qualifications necessary for returning the equipment to service or will be a QA inspector."
Contrary to the above, as of January 21, 1982, procedure OP-43 Service Water System, Rev 20, approved September 30, 1981, section G directs removal from service and restoration of the Residual Heat Removal Service Water sub-systems, but does not require a second person to verify proper system alignment nor provide for functional testing following restoration.
Failure to require a second person to verify proper restoration directly contributed to the inoperability of both redundant RHR Service Water subsystems on January 16, 1982, when called upon to function.
Carolina Power & Light Company's Response Carolina Power & Light acknowledges that this was a violation of NRC require-ments. This event occurred due to an insufficient review and revision program developed in 1980 when the double verification requirement was established.
As noted in the CP&L letter of December 31, 1980, to Mr. Eisenhut, CP&L felt that it was in compliance with the requirements for double verification.
This violation has necessitated a re-evaluation of safety-related procedural steps with respect to compliance with regulatory requirements. The Brunswick site has established a three-phase program to ensure that all required independent verification steps are accomplished in total compliance with
previous commitments during the course of the procedural re-evaluation. This three-phase program encompasses the following:
1.
Instructions will be developed as part of the Plant Operating Manual to provide specific guidance regarding implementation of independent verification procedures including specific methods for accomplishing independent verifications.
These instructions will be written and approved by May 25, 1982.
2.
Independent verification training will be provided for Operations, Maintenance, Engineering and Environmental & Radiation Control personnel i
to ensure their understanding of the instructions developed in Step No. 1 above.
This training will be completed by June 1, 1982, for all personnel designated to identify verification steps and/or to physically complete an independent verification function. Those personnel on rotational assignment will complete independent verification training as soon as practical following their return to an active work assignment.
3 All safety-related procedures utilized in testing and surveillance activities to be performed after June 1, 1982, will be reviewed to determine the requirements, if any, for completion of independent verification. If a determination is made that independent verification is required, that procedure will be identified acccedingly and those steps requiring independent verification will be marked by the reviewer in the margin adjacent to the original signoff. Subsequent procedural revisions will incorporate the independent verification steps as a permanent part of the procedure.
Several methods to verify that components related to safety are restored to an operable standby status may be utilized at the Brunswick site. Any method or combination of methods listed below may be used to complete this activity.
1.
Physical verification by " hands-on" confirmatory movement to an open/ closed position.
2.
Visual verification of the components' position by direct observation or remote indication.
3 Visual verification of the components' position by system process parameter changes as indicated by direct or remote indication or annunciation.
4.
Functional testing of the integrated system.
4 The above actions will ensure total compliance with regulatory requirements pertaining to independent verification by correction of the observed program inadequacies noted in Violation A.
e Violation B (Severity Level IV - Applicable to Unit 2 only)
Technical Specification 6.8.1 requires that written procedures for the operation of safety-related equipment shall be implemented. Procedure OP-43, Service Water System, Revision 20 step G.3.10 requires that previously opened circuit breakers be reclosed following the well water flush of the Residual Heat (RHR) Service Water piping.
Contrary to the above, procedure OP-43 was not implemented in that, on January 16, 1982 circuit breaker 19 was not reclosed as required by step G.3 10.
This failure rendered the "B" RHR Service Water subsystem inoperable on January 16, 1982.
Carolina Power & Light Company's Response Carolina Power & Light acknowledges that this was a violation of NRC requirements as addressed in the plant technical specifications. Failure to return circuit breaker 19 to the closed position following a flush on the B RHR service water subsystem was caused by poor communications by personnel performing the flush and by an inadequate procedure.
An Auxiliary Operator (AO) other than the A0 assigned to perform the flush per OP-43 was requested to open circuit breaker 19 (located in the Control Building) so that the flush could be performed in the Reactor Building. Upon opening circuit breaker 19, the A0 performing the flush did not check to see if circuit breaker 19 was closed, since he assumed it would be closed by the A0 who opened it.
The Control Operator did not follow up on the event to assure its proper completion.
To prevent circuit breaker 19 (circuit breaker 22 on the A loop) from being left open on future system flushing, a new procedure PT-8.2.6, has been written which provides adequate guidance for performing the flush.
Included in this procedure is the requirement for a double verification signoff assuring that the breakers are returned to their correct position.
Full compliance has been achieved for this item.
i l
2
t Violation C (Severity Level IV) 10 CFR 50, Appendix B, paragraph XVI, Corrective Action, requires that when conditions adverse to quality occur, the licensee shall determine the cause and take corrective action to preclude repetition. The CP&L Corporate Quality Assurance Program, Section 15 requires for significant conditions adverse to quality, the cause and corrective actions taken to preclude recurrence be determined, recorded and reported to appropriate levels of management.
Contrary to the above, adequate corrective action was not taken when safety-related pressure switches SW-PS-1175 and SW-PS-1176 were repeatedly found inoperable between December 26, 1979 and January 16, 1982.
Carolina Power & Light Company's Response Carolina Power & Light Company acknowledges that this was a violation of NRC requirements. This occurred due to improper emphasis on the evaluation of equipment failures and maintenance during the referenced period for the aforementioned safety-related pressure switches.
Several actions have been established tc correct this problem and to prevent events of this nature in the future. First, the instruments have been placed on a monthly calibration schedule until either a more reliable history has been established, the switches are replaced with more reliable switches, or the switches are removed from the RHRSW pump logic. An engineering work r quest (EWR) has been issued to Plant Engineering to devise a permanent solution to identify and correct these switches.
Also, future maintenance on these switches will consist of a total switch replacement instead of an individual component replacement to assure that the diaphragm fluid seal is properly in place before a switch is returned to service following maintenance. Second, a Work Order Tracking System (WOTS) was put into operation on January 1, 1982.
WOTS will allow Maintenance personnel to readily access post-maintenance work orders to allow early recognition of repetitive failures. This item is considered closed.
)
l l
l l
Violation D (Severity Level V)
Technical Specification 6.8.1.c requires that written procedures for the surveillance and test activities of safety-related equipment shall be implemented. Procedure MI3-3A34 titled S.W.-P.S. 1175 and 1176, Service Water Pressure Switch, Revision 0, December 26, 1979 was reviewed and approved by the licensee for the semiannual calibration of the RHR Service Water pressure switches.
Contrary to the above, procedure MI3-3A34 was not fully implemented as of January 21, 1982 in that the following discrepancies occurred.
(1) Of 24 calibrations performed on these pressure switches on both units, since December 26, 1979 only 5 of the calibrations performed utilized the correct procedure (MI3-3A34) and the rest utilized a non safety-related procedure (MI3-3A).
(2) The procedure MI3-3A34 requires that a semiannual calibration of the pressure switches be performed. However, during the interval of September 3, 1980 through July 11, 1981 a calibration of pressure switch 2-SW-PS-1176 was not performed.
Carolina Power & Light Company Response Carolina Power & Light Company acknowledges that these events violate NRC requirements. The first event occurred due to an outdated procedure defining Q-list instrumentation. Tables I and IA in book 2 of Volume XI to the Plant Operating Manual both contain a delineation of Q-list equipment; however, Table IA did not list these instruments as being Q-listed.
When it was established that the instruments were non-Q (by use of the wrong table), they were not entered on the Periodic Maintenance Scheduling Program and therefore were not performed with the required semi-annual periodicity (second event).
The tables (I and IA) in Volume XI have been revised to assure that all Q-list equipment is correctly identified on both tables.
In addition, instructions for retrieving a correct maintenance instruction for a particular instrument have been provided at each maintenance computer console. All Q-listed instrumentation has been entered into the Periodic Maintenance Scheduling Program to assure a proper calibration schedule. This item is considered closed.