ML20055G677

Responds to NRC Re Violations Noted in Insp Repts 50-324/90-14 & 50-325/90-14.Corrective Actions:Event Included in Third Quarter Real Time Training for Personnel, Emphasizing Importance of Detection of Plant Deficiencies

ML20055G677
Person / Time
Site:	Brunswick
Issue date:	07/20/1990
From:	Harness J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9007240063
Download: ML20055G677 (4)

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P. O. Box 10429.

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July 20,1990 FILE:- 'B09-135100 . 100FR2.201 SERIAL: BSEP/9,0 0515-iU.S. Nuclear Regulatory Commission-4 1 ATTN: Doewnent Control Desk it Washington,-D. C. 20555' 4

BRUNSWICK STEAM- ELEJTRIC PIANT UNITS l' AND 2 i o

DOCKET NOS. 50 325 AND 50 324

[ ' LICENSE'NOS. DPR-71 AND DPR 62

) jtEPLY TO A= NOTICE OF VIOLATION L.

=centlemen:

.$ Attached is an update to CP&L's initial response to the NOTICE OF VIOLATION.

H. issued on May .7,- 1990 in IER 50-325/9014 and 50-324/90 14, ' addressing : the '

L actions to be- taken by the' Brunswick staff to . improve the detection ~of equipment anomalies. This update fulfills the commitment identified in your letter dated

-June 26, 1990.: requesting'this_information.-

L Very truly yours, i p

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J. . arness,- Ieral Manager? .i

(.), B u swick Nucle . Proj ect '

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Mr. N..B. Le- .

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BRUNSVICK STEAM ELECTRIC PLANT DOCKET NOS. 50 325 AND 50 324 LICENSE NOS. DPR-71 AND DPR-62 Attachment 1 IER 90-14 SUPPLEMENTAL VIOLATION RESPONSE The following is an update of our response to the Notice of Violation issued on May 7, 1990 in IER 50-325/90-14 and 50-324/90-14, addressing the actions to be taken by the BSEP staff to improve the detection of equipment anomalies.

Reference:

Report Nos. 50-325/90-14 and 50-324/90-14.

EVENT REVIEW The event for which this violation was issued was for the failure of Instrumentation and Control (I&C) personnel who were completing a Maintenance Surveillance Test (MST) to properly complete the job, in that the involved personnel failed to reinstall junction box cover for box ESS-PN2, located in the

-17' elevation of the South RHR room. The box is used as a termination point in the testing, and houses both a pressure switch and pressure transi itter which are required to be environmentally qualified. With the box cover open, the qualification of the termirs1 block and, hence, the pressure switch and transmitter, are voided.

The junction box cover was lef t off the box for approximately 2 days. It was found open by the resident NRC inspector. Because of the fact that four shift changes had occurred during the time the box cover was left off, additional concerns were raised as to the failure of the Brunswick staff to identify this discrepancy during routine tours by the operations staff and other licensee personnel.

RESPONSE

A review was performed by the Brunswick staff relative to this issue. The findings and recommendations are discussed below.

A review was conducted of the personnel that entered the Unit 1 Reactor Bu .lding i during the time the junction box cover was missing. A review of the area and staff activities relative to this area was also performed. Since this area is not a frequently traveled area & 9 attached sketch), normal mansgement staff tours woulo not be expected to include this area. Both Operations and Health Physics shif t personnel enter this area on a once pe r shif t frequency to monitor the status of the High Radiation Door entrance t.o the Reactor Building Equipment Drain Tank Room.

Although the time frame for the deviation is not an acceprsble period, tte time frame is short relative to plant management staff fus cions. For the BSEP management staff to find deviations of this duration, the frequency of tours must be at 13ast on a daily basis. The only personnel who have defined responsibilities of a daily tour cf the -17' RHR roou areas are Health Physics and Operations shift personnel. Health Physics personnel are not typically sensitive to component deficiencies of this nature. Operations shif t personnel would be expected to be more sensitive to these types of problems during their normal rounds. We will, however, include this event in the Third Quarter Real Time Training for E&RC personnel, emphasizing their importance in the detection of plant deficiencies.

Operations management is aware of the importance of the Operations shift personnel rounds in detecting deficiencies in the plant, aspecially during routine operation. Operations management is sensitive to the , anction box issue ,

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Attachment 1 Page 2 of 2

'< and is seeking methods-to ensure that the Operations shift personnel increase their involvement in the day to day detection of deficiencies in the power plant

'during their routine tours and daily rounds. A review of the significance of this event relative to Operations shif t personnel will be included as a part of -

LOR-Phase III, Cycle 2, scheduled to be completed by the end of August, 1990.

This review will emphasize the importance of the Operations shift personnel in.

detecting deficiencies in the plant.

Brunswick management is also concerned about increases in site exposure that

' would be involved in the type of surveillance program that would be necessary to

" ensure that all deficiencies that could possibly result from a given day's work activities are - detected. It is the Brunswick management philosophy that the corrective actions involved with incidents such as this focus on the root-O cause(s) of a given personnel error in order to prevent recurrence, not on increasing the effectiveness of secondan barriers- (such as after the fact inspections) that would detect these deficiencies. This philosophy is also consistent with our ALARA philosophy and concerns about reducing exposure at the Brunswick facility. For this particular event,- Brunswick management feels that it would be ' much more effective to stress to the- personnel . responsible for

, performing the tasks 'their accountability in completing these tasks satisfactorily, rather than expanding our plant surveillance programs to ensure detection of these deficiencies. This event has been included as part of the Second Quarter of 1990 RTT program for Maintenance . personnel, along with -

counseling 'of the involved individuals as to their responsibility of craftsmanship as-described in Maintenance Procedure (MMM)-001.

Through SOP 03.8, Maintenance Work Force Audits and Post Maintenance Work Audits,

' the Brunswick Maintenance Unit has in place a program which involves an after-the-fact review of randomly selected work requests / job ' orders (WR/J0s) and a Maintenance Supervisors and Foremen. The 7R/JO review daily work of consists force at audit leastby3I

&C/ Electrical and 3 Mechanical WR/J0s per week. The intention of these activities is to enhance the overall quali:y of the Maintenance effort. We do-not feel that increasing d e acep:. of this review is either necessary. nor prudent from either ALARA- or resource management standpoints.

Brunswick management will continue to stress.to working level site personnel the importance of their involvement in daily detection of potential problems through the Plant Event-Identification process and the ' Human Performance Evaluation System program.

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