ML20054H055

Forwards Response to NRC Re Violations Noted in IE Insp Repts 50-324/82-05 & 50-325/82-05.Corrective Actions:Procedures Revised to Include safety-related Annunciator Alarm & Daily Surveillance Rept Sheets

ML20054H055
Person / Time
Site:	Brunswick
Issue date:	04/30/1982
From:	Furr B CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20054H031	List: IR 05000324/1982005 ML20054H030 ML20054H047 ML20054H055 ML20054H063 ML20054H069
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.2, TASK-TM GL-82-05, GL-82-5, NUDOCS 8206220529
Download: ML20054H055 (4)

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%pm i , Jf696hteqqpany APR 3 0 1982 Mr. James P. O'Reilly, RedfpM(L'l A6 min $a 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:

The Brunswick Steam Electric Plant (BSEP) Unit Nos.1 and 2 has received IE Inspection Report 50-324/82-05 and 50-325/82-05 and finds that it does not contain any information of a proprietary nature.

The report identified three items that appear to be in noncompliance with NRC requirements. The report also contained an item that appears to deviate from commitments made to the Commission. A response to the deviation will be forwarded to you May 7,1902 in a supplemental response to this Inspection Report. In our April 23, 1982 letter to Mr. D. G. Eisenhut concerning Generic Letter 82-05, CP&L agreed to provide information concerning interim actions associated with NUREG-0737, Item II.B.2 (Post-Accident Sampling) in our response to this Inspection Report. This information will also be provided in our supplemental response to this report.

Should you have any questions concerning this letter or the enclosure, please contact our staff.

Yours very truly, I -

I B. J. Furr Vice President Nuclear Operations MSG /lr (n-43) cc: Mr. J. Van Vliet (NRC)

Mr. D. G. Eisenhut (NRC)

B. J. r'urr, 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.

t CUv My commission expires: Notary (Seal)

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CAROLINA POWER & LIGHT COMPANY RESPONSE TO IE REPORT 50-324/82-05 AND 50-325/82-05 FOR BSEP UNIT NOS. 1 AND 2 Violation (Severity Level IV)

Technical Specification 6.8.1.a requires that written procedures shall be implemented covering the activities specified in Appendix A of Regulatory Guide 1.33, November 1972. Item A.2 of Appendix A requires procedures for responsibilities for safe operation. Procedure OI-4, LCO Evaluation and Followup, Step 4.1, requires that when any system with a technical specification LCO is found inoperable, the Shift Foreman shall complete appropriate portions of an Event Evaluation Check Sheet and note the malfunction in the Shift Foreman's 1o2 Contrary to the above, on January 8, 1982, the Shift Foreman did not complete an Event Evaluation Check Sheet nor make an entry in the Shift Foreman's log when informed that the Standby Liquid Control heat tracing circuits were inoperable. Verification of heat tracing operability is a daily surveillance requirement for Standby Liquid Control operability.

Carolina Power & Light Company Carolina Power & Light Company acknowledges that this was a violation of NRC requirements. The Shift Foreman failed to realize when reviewing the trouble ticket that the heat trace system on Standby Liquid Control (SLC) was required for the system to be operable. The LCO for SLC in the Technical Specifications only requires a flow path with two pumps and two inline injection valves, a proper volume-concentration solution, and a proper solution temperature. The requirement for the heat trace is found only in the surveillance section. It should be noted that an investigation of the heat trace operability as a result of this trouble ticket determined that the heat trace system was and had been operable on the SLC flow lines.

The personnel involved in this event were counseled to ensure they fully understood the problems identified and therefore could take the required actions in accordance with procedures. This is viewed as an isolated event and therefore no additional actions are required.

Violation (Severity Level V, Supplement I.E)

Technical Specification 6.8.1.a and c require written procedures to be established and implemented for items recommended in Appendix A of NRC Regulatory Guide 1.33 and for surveillance activities of safety-related equipment. Item E of Appendix A requires appropriate written procedures for each safety-related annunciator. Item E of Appendix A, Items D.1, F.18, D.6 and D.7 require appropriate written procedures for normal operator and

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, i expected transient shutdown of the recirculation system, operation of the Reactor Core Isolation Cooling (RCIC) System and energizing emergency core cooling systems.

Contrary to the above:

1. A written procedure had not been established as of February 9,1982 for the Unit No. 2 safety-related annunciator alarm 1-10 on panel 2A3,

" Safety / Relief Valve Open", following installation of a plant modification making that annunciator operable.

2. As of February 9,1982, the Unit Nos. 1 and 2 Operating Instruction 3 Daily Surveillance Report sheets were not properly revised to document the recently installed containment pressure instrument (CAC-PI-4176) surveillance checks required by Technical Specification Table 4.3.5.3-1.

3 Procedures EI-10 and OP-2 were not adequately established on January 18, 1982, in that compliance with them resulted in restart of an idle recirculation pump loop without meeting the requirement of Technical Specification 3.4.1.3 that the operating loop flow rate is less than or equal to 50 percent of rated loop flow.

4. Procedure PT-10.1.1 for the RCIC System was not adequately established on January 16, 1982, in that it did not contain an instruction to verify after testing that the flow controller is set in " auto" with a flow demand of 400 gpm.

5. Procedure OP-17 was not adequately established on January 12, 1982, in that it required the 1-E11-F010 valve breaker to be ON whereas Technical Specification 3.5.3.2.a.3 requires the valve to be deenergized. (Valve 1-E11-F010 was deenergized).

Carolina Power & Light Company's Response Carolina Power & Light Company acknowledges that the listed procedure inadequacies violate NRC requirements as provided in the Technical Specifications. While the examples presented in tnis violation are viewed as isolated in nature, the procedures addressed in examples 1 through 3 have been revised to correct the deficiencies noted. In addition, the procedures identified in examples 4 and 5 are currently being reviewed and will be revised by May 30, 1982. In an effort to identify other problems which may exist in plant operating procedures, a review of all operating and annunciator procedures is planned. The emergency procedures are currently being revised to a new format and any inadequacies noted are being corrected. The emergency procedure should be reviewed, revised, and in use by completion of the BSEP Unit 1 refueling outage. The review and rewrite of the operating and annunciator procedures should be completed during the summer of 1983

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Violation (Severity Level VI, Supplement I.F - Applicable to Unit 1 only)

Technical Specifications 6.10.1.b and d require maintenance and surveillance activity records be retained for at least five years.

Contrary to the above, records identifying what maintenance activities were performed on Main Steam Isolation Valves (MSIV) 1-B21-F022D and 28D to allow demonstration of leakage within Technical Specification 3.6.1.2.c limit on September 9, 1981, were unavailable on January 11, 1982.

Also contrary to the above, records documenting leak tests on MSIVs I-B21-F022D, 28D, 22B, and 28B between August 29 and 31, 1981, were unavailable on January 11, 1982.

Carolina Power & Light Company's Response Carolina Power & Light Company acknowledges that the failure to maintain documentation for the event of August 29-31 is a violation of NRC requirements; however, we deny that the event identified as occurring on September 9-10 violated NRC requirements.

On August 29-31, 1981, PT-20.3 (LLRT) was performed on MSIVs F022B(D) and F028B(D). Document sheets for this test were later determined not to be filed with the completed PT. It is believed that these document sheets were misplaced during the review / approval process, as a search of all possible locations could not locate the required documentation. Copies of these document sheets were obtained and placed with the PT in the vault.

The personnel involved with performing this test have since left the Company and are not available for questioning on this event. The personnel now responsible for performing this test have been instructed to ensure that all required documentation is on file with the test. Also, a memorandum has been written to all supervisors describing this event as a reminder that all documentation for testing must be filed.

On September 9, 1981, a post-maintenance LLRT performed on MSIVs F022D and F028D failed. The valves were cycled several times to assure a good seating su rface. Following these valve cyclings, the LLRT was performed successfully on these valves. As no maintenance activities were performed on these valves between the two tests, no maintenance records were generated.

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