ML20082K466
| ML20082K466 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/30/1991 |
| From: | Spencer J CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9108300061 | |
| Download: ML20082K466 (4) | |
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CP&L Carolina Power & Light Company rearmannananmassumsmammwwm Brunswick Nuclear Project P. O.-Box 10429 Southport, N.C.
28461-0429 30 FILE:
B09-135100 10CFR2.201 i
U.S. Nuclear Regulatory Commission ATTN:. Document Control Desk L
Washington, D. C, 20555 4
- BRUNSWICK STEAM ELECTRIC PIANT UNIT 1 DOCKET NOS. 50-325 4
i LICENSE NOS. DPR-71 REPLY TQ A NOTICE OF VIO1ATION Gentlemen:
The Brunswick Steam Electric Plant (BSEP) has received NRC Inspection Report 325/91-16 and finds that it does not ' contain information of a proprietary nature. This report included a Notice Of Violation.
Enclosed is Carolina Power 6 -Light Company's response to that Notice of Violation.
Very truly yours,
.W Spencer, G.
.ral Manager-Bt 1swick Nuclear Project RSK/.
-Enclosure
-- cc :
Mr. S. D.-Ebneter Mr. N. B. Le BSEP NRC Resident Office 270018
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ENCLOSURE BRUNSWICK STEAM ELECTR'C PLANT, UNIT 1 NRC DOCKET NOS. 50-325 OPERATING LICENSE NOS. DPR-71 REPLY T0-N0DCE OF VIOLATION VIOLATION During' an NRC inspection conducted on June 1-28, 1991, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the violation is listed below:
Technical Specification 6.8.1.a requires that written procedures be established, implemented, and maintained for applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements, November 1972. Appendix A to Regulatory Guide 1.33
-requires that maintenance which can affect the performance of safety-related equipmer.t be performed in accordance with written procedures, documented instructions, or drawings. appropriate to the circumstances.
GMM-001, Maintenance, Conduct of Operations, Revision 15, Section 5, states that all maintenance will be performed under the guidelines of approved plant procedures or specific written instructions on a Work Request / Job Order.
Contrary to the above, maintenance was conducted that was not under the guidelines of approved plant procedures or specific written instructions on a Work Request / Job Order in that on June 10, 1991, an electrical connection within the circuitry for' the Unit 1 High Pressure Coolant Injection Steam Leak Detection System was manipulated by maintenance personnel without procedural or work request / job order instructions. This led to an unnecessary engineered safety features HPCI isolation.
This violation applies to Unit 1.
This is a severity level IV violation.
Reference:
Inspection Report 91-16
o e
RESP _QNSE TO VIOLATION:
Admission or Denial of Violation:
CP&L admits to this violation.
REASON FOR THE_ VIOLATION:
The event was caused by a personnel error which resulted in breaking of the electrical continuity at an engineered safety feature input module. The module tripped causing an isolation.
The technician considered himself to be
" evaluating" an unexpected annunciator condition. His evaluation focused on re-verification to determine if the steps he had performed in a test procedure had in some way resulted in the condition - a practice encouraged by CP&L and recently reinforced by "Please Listen" training. The technician's actions should have been limited to passive verification of the wiring. In this case, the technician unintentionally went beyond passive re-verification activities.
Several factors contributed to this error. The technician knew that:
- 1. He had been performing work that involved the observed annunciation.
- 2. H'e and the Reactor Operator had determined that the time frame associated with the annunciaticn coincided with the re-connection of the wires.
- 3. There have been past difficulties making a good electrical connection at the involved terminal point. The terminal point has three wire connections and a good connection is sometimes difficult to achieve.
Based on this knowledge, the technician re-checked this module connection by backing its screw out slightly (ie. approximately one sixteenth of an inch),
prossing the wires into the connection and then tightening the screw again. This movement was sufficient to break the electrical connection, trip the module, and generate a Group 4, Primary Containment Isolation System B channel isolation signal. This resulted in a closure of the High Pressure Coolant Injection steam e; ply trb::rd isolation valve as designed.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTE ACHIEVED:
The technician was counselled and appropriate disciplinary action was taken.
This event was discussed with maintenance personnel during " pre" and " post" job briefings.
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W CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER V10t ATI.0M1 Training on this event will be provided to appropriate maintenance personnel.
This is scheduled to be completed by January 15, 1992.
The Maintenance Surveillance Test Users Guide will be revised to include definitions and directions for self-assessment and passive verification.
DATE WHENll)LL COMPLIANCE WI1LBE ACHIEVfD:_
CP&L is in full compliance.
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