ML20095G118
| ML20095G118 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/23/1992 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS-92-112, NUDOCS 9204280411 | |
| Download: ML20095G118 (5) | |
Text
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Carolina Power & Light Company P o. Boa 1651 *- nanegh. N c 27602 MPR 231992 SERIAL: NLS 92112 R. A. WATSON Sena vee President Nx6 ear Generstm United States Nuclear Regulatory Commission ATTENTION: Document Contro' Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50 325 & 50 324/ LICENSE NOS. DPR 71 & DP9 62 REPLY TO NOTICE O
OLATION (EA 92-024)
Gentlemen:
On March 24,1992, the Nucker Regulatory Commission issued a Notice of Violation (EA 92 024) for an issue at the Brunswick Stea.m Electric Ptarit, Units 1 and 2. Details of the NRC inspections are provided in Inspection Report Nos. 50-325/92-01 and 50 324/92 01 dated February 13,1992.
Carolina Power & Light Company hereby resoonds to the Notice of Violation. The enclosure to this letter provides CP&L's reply to the Notice of Violation in accordance with the provisions of 10 CFR 2.201. Also enclosed is a check payable to the Treasurer of the United States in the amount of One Hundred Thousand Dollars ($100,000.00).
Please refer any questions regarding this submittal to Mr. D. C. McCarthy at (919) 546 6901.
Yours very truly, fh gZb'~6}U R. A. Watson WRM/wrm (\\wpiea92024.006)
Enclosures cc:
Mr. S. D. Ebneter Mr. N. B. Le Mr. R. L. Prevatte R. A. Watson, having been first duly sworn, did depose and say that the informa ion contained herein is true and correct to the best of his information, knowledge and belief; and the sources of
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I his information are officers, employees, contractors, and agents of Carolina Power & Light y
f Company.
h M 44w h-My commission expires: f.) 3 -7 3 ~
ANotary (Sealy/ /
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9204200411 920423 PDR ADOCK 05000324
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ENCLOSURE BRUNSWICK STEAM ELECTRIC PLANT. UNITS 1 AND 2 NRC DOCKET NOS. 50-325 & 50-324
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OPERATING LICENSE NOS. DPR-71 & DPR-62 g* ~
REPLY TO NOTICE OF VIOLA *ilON AND PROPOSED IMPOSITION OF CIVIL PENALTY 3
spection et,nducted on Januay 4-31, and February 3,1992, a violation of NRC re wn os identified, in accordance with the " General Statement of Policy and P ocedure nnent Actions," 10 CFR Part 2, Appendix C (1991), the Nuclear Regulatory f.
N; Cer" proposes to impose a civil penalty pursuant to secticn 234 of the Atomic Energy Act of
~ mended (Act),42 U.S.C. 2282, and 10 CFR 2.205. The rarticular violadon and s
asscNuc; penalty are set forth below:
Techtucal Speci6 cation 6.8.1.a requires written procedures shall be established and Implemented as recommended in Appendix "A" of NRC Regulatory Guide 1.33, November 1972. Ser e 1.1 of Appendix "A" requires that procedures for maintenance which can affect the parormance of safetyeelated equipment be propGly preplan.ied and performed within written procedures or instructions appropriate to the circumstances.
Contrar/ to the above, on January 3,1992, tns licensee performed a maintenance work activity on Emergency Diesel Generator (EDG) No. 2, a safety-related component, using a procedure that w
- nct Tpropriate to the circumstances. Specifically, the procedua, Rer': sting Diesat Ut rawors, dated May 16,1991 and updated January 2,1992, old nr t receive an adequw rmew to evaluate the ! J. pact of the preplanned work on the ol..tiability of EDv' No. 2. The snaintenance work activity performed under this procedure resulted in the f>.are of EDG No. 2 to start upon receipt of a valid start signal on January 6,1992.
This is a Severity Level 111 violation (Supplement I).
Civil Peri i / - $100.000 BJSPONSL TO VIOLATION:
Adrr:ission or Denial of Violation:
Carolins Power & Light Companv admits to this vg>lation.
Reasa' for the V olation:
On January 3,1992, while Emergency Diesel Generator No. 2 was operable, Project Support Services (formerly thnt Services) personnel completed spray cleaning of the emergency diesel generator in prepamtion for painting in accordance with an infonnal written work instruction. At El-1 I
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0045 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> onJanuary 6,1992, during testing of the Unit 2 Main Turbine overspeed trip function, a component failure of the primary electrical lockout logic circuitry initiated an automatic start of all four emergency diesel get:erators. Emergency DMsel Generator Nos.1,3, and 4 started as designed, but Emergency Diesel Generator No. 2 fa:!ed to start.
- An investigation revealed that the No. 2 Emergency Diesel Generator failed to start due to binding of the fuel racks resulting from the dried residue of the cleaning agent Planisol-M. If not thoroughly rinsed and/or correctly mixed, the cleaning agent's meta-silicate component dries ta form a crystalline bond.
Previous responses to this violation have been presented to the NRC during the March 3,~ 1992, Brunswick Entarcement Conference and as an additional example in the response to Notice of
- Violation contained in Enforcement Action 91 158.
Event Cause:
Plant analysis has determined that failure of Emergency Diesel Generator No. 2 to auto start was due to the following:
(1)
Failure of the Project Support Services work control process to identify those types of cleaning activities which could potentially affect equipment operability. The specific technical cause of the event described in the violation above was the use of Planisol-M cleaning solve,t that caused binding of the emergency diesel gett
't e fuel racks.
(2)
The lack of a formal procedure resulted in post-maintenance testing not being performed, i
Consequently, the following normal processes required for activities affecting quality were not invoked:
(1) formal procedure technical and 10 CFR 50.59 reviews, (2) incorporation of the work intu the Automated Maintenance Management System and Site Work Force Control planning process,
-and (3) consideration of post mair.tenance testing.
Corrective Steos Which Have Been Take'l and Results Achiever,b 1.
Use of Planisol-M was immediately suspended at the Brunswick Plant site. Stores was prohibited from issuing Planisol-M until an evalus. tion of the effects of Planisol-M was completed and procedures providing guidanec for its use were issued.
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- 2.
Recocnizing the importance of this cent and the potential effect of the failure to
- follow normal processes required for activities affecting quality, management directed that Project Support Service (nrganization work be brought under the formal control of the Site Work Force Control Group Process Procedure (BSP-43).
An assessment of the Project Support Services work activities was performed to identify those activities'with the potential _for affecting the operability of safety i
related equipment. Based ori the results of this assessment, activities with the potential for affecting safety related equipment will require Site Work Force Control l
review and processing through the Automated Maintenance Management P"etem prior to Nplementation. These steps will provih the opportunity for greati.
managerial control of activities with the potential to impact safety related equipmet.
3.
D'etail'ed reviews of the event by management with involved personnel were conducted.
4.
Comrnunication of the event with other CP&L nuclear sites and the industry through a Nuclear Network entry was completed January 21,1992.
5.
A review of past similar activities by Project Support Services on Engineered Safeguards Feature equipment and systems was performed to identify potential inoperabilities. The results of this review revealed that no activities had been performed which could have degraded Engineered Safeguards Feature system operability.
6.
Prior to the event r.ited, Brunswick Plant management had recognized the need for improvement in the areas of work control and scif assessment. Plant management and the Nuclear Assessment Department have assessed work control and plant management has developed a corrective action plan in response to this assessment.
Additionally, Work Control and Nrrecti, Action Program assist visits by INPO scheduled for February 10,1992, and March 2,1992, have been conducted.
i lI Corrective Actions That Will Be Taken To Avoid Further Violations:
_ On January 3,1992, the Nuclear Regulatory Commission issued a Nutice of Violation (EA 91-158).
In addition tu the corrective actions described in the re,,ponse dated February 14,1992 (Serial:
' NLS-92-031) and the supplemental response letter dated March 30,1992 (Serial: N';S-92-098) to that enforcement action, the following corrective actions will be taken to avoM furtner recurrence of the problems identified in the violation recited herein:
.1.-
An approved procedure to control future Emergency Diesel Generator repainting activities is in the final review process and wi:: be implemented by July 31,1992.
This procedure will address the concern raised by use of Planisol-M and lubrication checks following cleaning.
2.
Formal controls for painting on Engineered Safeguards Feature systems is currently j-
_being evaluated. The results of this evaluation and the recently completed El-3
assessment identifying Site Work Force Control and Automated Maintenance Management System requirements for activities afiecting safety related equipment will be formally incorporated within formal procedures by July 24,1992.
Date When Full Comoliance Will Be Achieved:
- Based on ertablishment of_ interim controls including suspension of diesel generator cleaning and painting work activities until an approved procedure is complete and the incorporation of the Project Support Services organization into the Site Work Force Control process, the company believes that full compliance has been achieved To e'nsure continued compliance, the corrective actions delineated within the preceding section will be implemented by July 31,1992.
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