ML20113J093
| ML20113J093 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/03/1992 |
| From: | Spencer J CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9208070021 | |
| Download: ML20113J093 (10) | |
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CP&L Carclina Power & Light Company EWEETeminummnemmaissmastmas Brunswick Nuclear Project P. O. Box 10429 Southport, N.C.
28461-0429 AUG 31992 FILE:
B09-13510C 10CFR2.201 U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washington, D.
C.
20555 i
BRUNSWICK STEAh ELECTHIC PLANT UNITS 1 AND 2 DOCKET NOS., 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 REPLY TO A NOTICE OF VIOLATION Gentlemen The Brunswick Steam Electric Plant (BSEP) has received NRC Inspection Report 50-325/92-15 and 50-324/92-15 and finds that it does not contair. information of a proprietary nature. This report included a Notice Of Violation.
Enclosed is Cerolina Power & Light Company's response to that Notice Of Violation.
As discussed in a July 17, 1992, telephone conversation with Mr. H. O. Christensen - Chief Project Section lA, Reactor Projects Branch No.1, Division of Reactor Projects, the due date for this violation response was 4
l extended two weeks, to August 3,1992, to allow for a more detailed review of the response.
f Very truly yours,
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- Spencer, e eral Manager E q wick Nucle Project i
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f' Enclosure cca Mr.
S. D. Ebneter Mr. R. H. Lo i
BSEP NRC Resident Office l
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Q D O O 9* N 9200070021 920803 gj l
PDR-ADOCK 05000324 PDR g
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ENCLOSURE BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATINO LICENSE NOS. DPR-71 & DPR-62 REPLY TO NOTICE OF VIOLATION y10LAT10N A Failure to Include Safety Related Supports in the ISI Program 10 CFR 50.55a(g) and T3 4.0.5 require that an inservice inspection program be implemented for ASME Code Class 1, 2, and 3 components and piping. ASME Section XI, Article IWA-1310 requires that the licensee maintain an inspection plan and provide the scheduling requirements. Article IWF-1100 requires supports which
" support the weight of or provide the structural stability to components and
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piping" be included 1.
the inservice inspection program.
Contrary to the above, the Brunswick second ten year inspection program (which-started in 1986) did not include nn in gectlan plan for pump bases, heat exchanger supports and pump turbines in Unit 2, and the reactor vessel skirt and lateral supports in Units 1 and 2.
This is a Severity Level IV violation (Supp1sment 1).
RESPONSE TO VIOLATION As Admission or Denial of Violatient Carolina Power and Light (CP&L) admits the second ten year inspection program did not include the stated component supports.
Egason for the Violation:
CP&L updated the Brunswick Nuclear PrJject (BNP) Inservice _ Inspection (ISI) program in 1986, for the second ten year inspection interval, to the 1980 Edition through the winter of 1981 Addenda of the ASME Section XI Code.
During the initial iuentification of component supports to be included in the program, CP&L failed to recognize and incorporate the Unit 1 and Unit 2 Reactor Vessel Skirt support, Reactor Lateral support, and the Residual Heat Removal (RHR) A and B Heat Exchanger supports 9to the inspection pregram.
The determination that the Reactor Vessel Skirt support was not included in the inspection program was made in response to an NRC query. The latter three items were identified during an additional review of the BNP program conducted by the ISI staff.
The ISI staff also determined that equipment supports for certain pumps. heat exchangers, and pump turbines were not incorporated into the Unit 2 inspection program; however, these components were included. in the Unit 1 program.
The cause of the omitted component supports is a failure to perform a thorough review when the components were initially identified and when both Unit 1 and 2 componento were transferred onto a computer tracking system.. A recent conversation with a prior CP&L em-2cyee who developed the program indicated he did consider the reactor vessel itirt support as a " component support'; no explanation was available as to why it was not incorporated into the program.
ENCLOSURE PAGE 1
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j The individual attributed the failure to completely transfer the Unit 2 information to diversion of resources.
t forrective Steps Which Have Been Takgn and Resulto Achieved:
I CP&L reviewed the approved ISI isometric drawings which resulted in 31 supports (4 in Unit 1 and 27 in Unit 2) being added to the ISI program.
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gorrective Stros Which Will Be Taken to Avoid Further Vlointions -
An ISI Engineer with over nineteen years of commercial nuclear plant experience has been contracted to perform an independent review of the BNP program to ensure that the appropriats components are identified for examination / testing as required by the 1980 Edition through the winter of 1981 Addenda of the ASME Section XI Code.
i In recognition that the root cauna of this violr.sion is managument's f ailure to establish appropriate standards for the project or to properly resource it, CP&L
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will:
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Develop a standard (s) which defines and establishes controle j
for " complex" programs including review requirements.
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A review of existing programs will be conducted to identify
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other complex programs which would be subject to -the standard (s).
l CP&L will_ provide the status of this offort in a supplemental _responou in six_
month.i.
i Date When Full Compliance Will Be Achieved:
The equipment identified during the review as requiring inspection has been added to the current inspection plan.
CP&L is presently in conformance with the required percentages of inspections and scheduled inspections of the outstanding percentages of A, B, and C categories of IWF component supports for the current inspection interval.
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ENCLOSURE PAGE 2
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4 VIOLATION B Failure to Perform an Enaineerina Evaluation Within the Beauired Tip_e Limite i
10 CFR 50, Appe x B, Criterion V, requires that activities af fecting quality be prescribed by oocumented procedures and shall be accomplished in accordance with the procedures.
Operations Instruction CI-04, LCO Evaluation and Follow-up, Revision 41, Section 6.1.1.5.D requires that ident!fied deficiencies of seismic supports receive a i
preliminary evaluation within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and a full engineering evaluation for structural integrity within 30 days.
Contrary to the above an identified deficiency did not receive a full engineering evaluation for structural integrity within 30 days in that the evaluation for a deficiency concerning Unit 1 Core Spray instrument rack H21-P019 identified on April 5, 1992, was not completed on June 1, 1992.
This is a Severity 1,evel IV violation (Supplement I).
BESPONSE TO VIOLATION B:
Admission or Denial of Violation:
CP&L admits the identified deficiency did not receive a full engineerirg evaluation for structural integrity within 30 days.
Reason for the Violations The Nuclear Engineering Department (NED) did not produce the STSI evaluation within the LCO time constraint for the following reason:
During che time period the deficiency associated with rack 1-H21-P019 was noticod, a large number of other structural deficiencies ware identified in many areas of the plant.
The responsible manager, supervisor and engineer in NED failed to comply with the 30 day requirement.
porrective Actions Taken To Date and Results Achieved:
EER-92-120 and calculations ICS-0001 which document and evaluate the STSI condition are complete.
Corrective Actions That Will Be Taken To Avoid Further Violations This Notice of Violation will be reviewed with the appropriate managers, supervisors and engineering personnel within NED to emphasize the LCO Evaluation and Follow-up Operations Instruction, 04, requirement to finalize STSI evaluations within the 30 day time limit.
Date of Full ComollARF28 CP&L is in full compliance.
ENCLOSURE PACE 3
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VIOLATION _gi Inadeauste Procedatal Controls Over Plant Systemg Technical Specification 6.8.1.a requires that written procedures shall be e
established, implemented, and maintained, covering the applicable procedures
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recommended in Appendix "A" of Regulatory Guide 1.33, November 1972, including l
Administrative Procedures, Procedures for Operation of Safety Related Systems,
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and Procedures for Performing Maintenance, j
Technical Specification 6.8.1.c requires that written procedures shall be i
established, Jmplemented and maintained covering surveillance and test activitiac of safety related equipment.
1 Technical Specification 6.5.2.1 requires that a safety evaluation shall be prepared for changes to procedures required by Specification 6.8 and for proposed J
tests that effect nuclear safety.
Plant Operating Manual Volume, Book I, paragraph 5.8.4 requires first and second l'
party Technical and fluclear Safety reviews for new procedures or for changes to existing procedures in the Operating Hanual.
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Contrary to the above these requirements were not properly established and/or f
implemented as evidenced by the following examples:
(1)
On May 10, 1992, Technical Specification surveillance testing was performed in accordance with Work Request / Job Order 92-AJJX1, Drywell-cooling Unit IA supply fan, which had_not received the required Technical
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and Safety Reviews prior to its implementation with Maintenance l
Surveillance Test 1-MST-DG11R, Diesel Generator 1 Loading Test.
j (2)
On May 27, 1992, the Unit 1 Residual Heat Removal pump 1D failed to start in shutdown cooling because its suction valve had not been aligned open by
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the Operator.
Operating Procedure OP-17, Revision 41, Residual Heat
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Removal System, did not include complete instructions for manipulating the nystem eceponents once shutdown cooling had been established.
This is a Severity Level IV violation (Supplement I).
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PESPONSE TO VIOLATION C
.b Admission or Denial of Violations f
i CP&L adn..ta the referenced requirements ware tiot properly established and/or t
implemented as evidenced by the two examples.
i Reason for the Violations f
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EXAMPLE,J f
i The WR/JO included testing requirements which were provided by.the Maintenance Proceduraa Group via a memorandum.-
Personnel involved believed maintenance testing associated with non technics 1 specification related, non Q componente did
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not have to meet the same Technical and Safety review requirements as technical specification related testing (MST) and that a memo-would be sufficient.
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bypassed the barriers which insure pror ar technical-and safety reviews are accomplished for MST testing. Upon ecmpletion of the WR/JO, the original. test, combined with the WR/JO, were then assumed to constitute a satisfactory MST.
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t EXAMPLE 2 shif ting of pumps within the operating shutdown cooling loop has been considered l
a " simple evolution"; therefore, no specific procedure steps were established.
Corrective Steps Which Have Been Taken and Results Achieved:
EXAMPLE 1 Specific instructions for testing should not be placed in the body of a WR/Jo.
Changes have been identified for OMMM-003, Corrective Maintenance-(Automated Maintenance Management System) which limit the planner's capability to place such step by otep instructions into the body of the WR/JO An overview of changes to OMMM-003 will be given to Maintenance personnel prior to implementation scheduled for August 14, 1992.
EXAMPLE._2 No interim corrective actions were necessary.
Corrective Steos Whlph Will Be Taken_to Avoid Further Violations:
EXAMPLE _1 The changes to OKMM-003 have been made and are scheduled to be implemented by August 14, 1992.
In addition to the changes to-OMMM-003 noted above OMMM-002, Standards For Preparing and Maintaining Maintenance Procedures, is being revised to more clearly define Special Procedures and their uses. An overview on the guidance in OMMM-002-will be given to the procedure writers prior to full implementation.
This change is scheduled to be completed by August 31, 1992.
OMMM-001, Maintenat.ce: Conduct of Operations, will be reviewed and revised to conform with the changes being made to OMMM-003.
This-change is scheduled to be implemented by October 15, 1992.
OMMM-013, Maintenance Surveillance Test User's Guide, will be revised to provide clearer instructions to tr.e users for actions to perform when there is a failed or unsatisfactory MST, or portion thereof. This revision will also include instructions on procedural requiremento necessary to perform all or portions of a f ailed MST to meet Technical Specifications including the necesulty of a Special i
Procedure. This change is scheduled to be implemented by December l
31, 1992.
j EXAMPLE 2 operating Procedures will be reviewed to identify and evaluate whether other procedures r.aed revision for swapping running equipment by August 13, 1992.
The Manager - Operations Staff will evaluate and determine the adequacy of the program in place to define and control simple evolutions by October 22, 1992.
Date When Full Compliance Will Be Achieved:
CP&L will be in compliance by December 31, 1992.
ENCLOSURE PAGE 5
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1 VIOLATION D _
Failure to Maintain Confiouration Control over Plant Svetejng Technical Spe ification 6.8.1.a requires that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972, including Administrative Procedures, Procedures for Operation of Safety Related Systems, and procedures for performing Maintenance.
Administrative Instruction AI-58, Equipment Clearance Procedure, Revision 36, implements the requirements for developing, placing, an( maintaining system and component clearances.
Operating Instruction 01-01, operating principles and Philosophy, Pavision 43, Section 4.1 requires that plant evolutions be conducted in accordance with approved procedures.
Maintenanca Management Manual OMMM-001, Maintenance, Conduct of - operations, Revision 17, Section b.0 requires that maintenance be perfcrmed under the guidelines of plant procedures or specific written instructions.
Contrary to the above these requirements were not prope.ly established and/or ireplemented as evidenced by the following examples:
(1) on May 12, 1992, the 1B2 battery charger was removed from service without disconnecting all loads from the battery as required by Operations Work Procedure OWP-51/1, Removal of 125 VDC Battery System From Service Including DC Control Power Alignment, resulting in excessive battery discharge and polarity reversal of two cells.
(2) on May 21, 1992, the Diesel Generator No. 4 barring gear lever was manipulated by plant personnel without authorization, resulting in lockout of the Diesel Generator.
(3)
On May 30, 1992, Local Clearance 2092-1091, Hydraulle Control Unit (HCU) 38-11, was incorrectly placed on the corresponding valve for HCU 42-15 d3 spite double /erification performed for the proper component.
This is a Severity Level IV violation (supplement I)
RESPONSE TO VIOLATION Da Admission or Denial of_ylolations CP&L ad. tits the referenced requirements were not properly established and/or implemented as evidenced by the three examples.
Brason for the Violation:
EXAMPLI_1 SEQUENCE OF EVENTS 05/03/92 A 1B-2 battery load was transferred to an alternate power source to support a battery surveillance.
05/06/92 Cleara.nce to support maintenance activities on emergency power busses was completed. The power supply for the 1B-2 battery charger was included.
ENCLOSURE PAGE 6
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05/07/92 OWp-51/1 was reviewed and the applicable steps for removing the transferred battery load were marked N/A because the load was already transferred on 05/03/92.
The maintenance on the emergency power busses was postponed.
05/11/92 The battery surveillance was completed and the load was transferred I
to its normal source (i.e., the 18-2 battery charger).
05/12/92 The OWP-51/1 was performed as marked up and the maintenence was begun on the emergency bus.
Excessive battery discharge was noted by Operations; Maintenance and Technical Support were contacted.
Operations was advised by Technical support to not allow the battery to fall below 105 VDC.
05/13/92 Sattery voltage fell below 105 VDC. Operations elected to expedite recovery of the emergency power source.
Battery damage occurred.
Communication and work practices were inadequate. Information concerning plant status was not adequately trannmitted during Operations turn over and the continued use of a procedure which was started five days earlier was authorized i
without Ldequately ensuring plant conditions had not changed. Additionally, no procedural guidance was available concerning needed actions when battery voltage fell below 105 VDC.
Technical support was contacted af ter battery voltage decreased below 115 Vcc and verbal guidance was given to maintain voltage above i
105 VDC to prevent cell reversal. It was not understood that cell reversal could result in permanent battery damage.
Operations decided to continue with the t
written guidance provided (i.e.,
the procedure started five days earlier) and battery voltage was allowed to fall to 85 VDC before the battery charger was returned to service resulting in damage to three battery cells.
EXAMPLE 2 Root cause analysis has resulted in the determination that a primary contributing f actor to this event was that incorrect assumptions were made on the part of the j
Technical Support sngineers investigating the barring gear problem for I
engineering evaluation.
These engineers had been informed that the diesel generator was being placed under clearance for maintenance activities.
Upon visiting the diesel generator building for problem investigation about four hours later, these engineers observed various activities being performed on DG #4.
They incorrectly assumed that the DG had been cleared'and that work on the machine was authorized.
This resulted in the inappropriate action on the part I
of one of the Technical Support engineers which caused this event.
The Technical Support engineer and the Haintenance mechanic did not properly
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determine the status of the diesel generator nor did they properly communicate t
the scope of activity to be performed immediately prior to the inappropriate action causing the event.
Additionally, the individual responsible for this event did not perform appropriate self-checking to ensure that the intended
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action associated with operation of the barring gear lever was correct prior to operation of the lever.
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i EXAMPLE 3 r
A suf ficient degree c,/ attention was not applied to ensure the poper component l
was placed under clearance by both the individual hanging the clearance tag and l
the individual double verifying the tt;g. The individual hanging the clearance
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was inexperienced and perceived pressure to complete the task prior to turnover.
Corrective Steos Which Have Been Taken and Results Achieved EXAMPLE 1 The battery charger was restored to service on 5/13/92 at 0555.
The damaged battery enlis were replaced.
EXANPLE 2 The individud responsible for the inappropriate actions which caused this event has been strongly counseled concerr.ing the importance of the application of appropriate self-checking error dett: tion practices in relation to task completion. The significance of this issue and the potential severity associated with this event has been discussed by and is well understood by the parties involved in this issue.
Technical Support personnel participated in real time training (RTT) concerning this event on July 17, 1992. The purpose of this RTT was to reinforce the need r
for clear determination of an activity's status and the actions allowed to be performed prior to any hands on assistance.
EXAMPLE 3 The Unit Manager has discussed this event with involved individuals including the need for experieaced operators to ensure inexperienced operators are adequately briefed before performing a task, to ask for direction when excessive pressure to complete a task is perceived, and to employ the principles of PLEASE LISTiV during activities.
Corrective Steps Which Will Be Taken to Avoid Further Violationst EXAMPLE 1 Applicable procedures will-be reviewed and revised as necessary by October 22, 1992, to provide required actions when the 125 VDC Dattery voltages are less than 105 VDC.
This event will be included in the Industry Events section of the-125/250 VDC Distribution lesson plan by December 12, 1992.
p The Operations sub-Unit Managers will discuss expectations and requirements regarding control of evolutions which have been interrupted with on-shif t Senior Reactor Operators by September 10, 1992.
The need to ensure that the ef fect of changing operating parameters is completely evaluated and the importance of accarate and complete communications as demonstrated by this event will be raviewed with on-shif t operators by September 17, 1992.
ENCLOSURE PAGE 8
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1 EXAMPLE 2 CP&L will continue to track and trend data in our Corrective Action Program to determine if further additional corrective action is needed.
EXAMPLE 3 The event will be discussed with on-shift operators by August 27, 1992.
This discussion will include the need for experienced operators to ensure inexperienced operators are adequately briefed before performing a task, to ask for direction when excessive pressure to complete a task is perceived, and to j
employ the principles of PLEASE LISTEN during activities.
CP&L will change the practica of certain clearance activities from " double verification" to " independent verification" to further minimize clearance errors by September 24, 1992. Double verification will continue to be used coincident with the first independent ~ check for instances where positioning the wrong equipment could cause an immediate adverse consequence.
The=use of double verification will be a supervisory decision based upon the benefit of - the additional check.
Subsequent to completion of the first independent check, including double verification where appropriate, a second independent check will be performed.
Date When Full Compliance Will Be Achieved:
CP&L will be in compliance October 22, 1992.
Additional Comments The Notice of Violation cover letter requested that our response address what actions are being taken to reverse the " apparent negative trend in systems control" exhibited by vin 1ations C and D.
As discussed in our response to violations C and D, CP&L is implementing a number of fundamental changes to our work processes in an ef fort to reverse the adverse trend in systems control.
In addition, the Staff Assistance Team (SAT) has identified 71 process improvements; 27 of these process improvements are enhancements to work practices related to improving systems control.
The following is a listing of the 27 initiatives by project number TS7 Engineering Work Request TS4 Technical Support Memon TS6 Temporary Modifications A7 Pt ;cedure Revisiott Process A9 Vendor Tech Manual control OM2A Summary Pronse_
OM2B Project Planning OM2C System Plannin(,
OM2D Integrate Proj./ System Plaus OM2E Monitor / Report / Control OM3C,D Design / Turnover / Closeout OP1 Clearance Procedure OP2 Independent Verification OP4 LCOs OPS Clearance Use OP6 Post Maintenance Tests T1 Site Work Force Control M1 Work Request / Job Orders M2 Conduct of Operations (WR/JOs)
M3 Preventive Maintenance M6 Planner Training M10 ISI Programs M13 UA/70 Review
-M14 Post Maintenance Tests M16 Clearance Use M19 WR/JO Operations Instruction M20 WR/JO 01-39.1 (OI) 39 These improvements have been includvd in the Corporate Improvement Program communicated to the NRC in our letter of July 23, 1992. As indicated in our July 23, 1992 letter, the plan for implementing the SAT recommendations will be developed by November 30, 1992.
ENCLOSURE PAGE 9
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