ML20118B026

Responds to Violations Noted in Insp Repts 50-324/92-21 & 50-325/92-21.Corrective Actions:Mgt Directive Implemented Requiring Clearances to Be Hung on Test Boundary Isolation Valves Only & LLRT Procedure Test Lineup Revised

ML20118B026
Person / Time
Site:	Brunswick
Issue date:	09/21/1992
From:	Spencer J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BSEP-92-020, BSEP-92-20, NUDOCS 9209290259
Download: ML20118B026 (8)

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• CP&L Carottna Power & Light Company M3#&tsrat:r#awamrawancets Brunowick Huclear Project P. O. Dox 10429 Southport, N.C. 28461-0429 September 21, 1992 FILE: B09-13510c 10CFR2.201 SERIAL: BSEP-92-020 U.S. Nuclese Regulatory Commission ATTN Document Control Desk _

Washington, D, c. 20555 BRUNSWICK STEAM ELEC*tHIC PLANT UNITS 1 AND 2 DOCFET NOS. 50-325 AfrD 50-324 LICENSE NOS. DPR-71 AND DPR-62 MPLY TO A NOTICE __Qlr._y_LQMTION Gentlement The Brunswick Steam Electric Plant (ESEP) har received NRC Inspection Report 50-325/92-21 and 50-324/92-21 and finds that it does not contain information cf '

a proprietary nature. This report included a Notice of Violation.

Enclosed is Carolina Power (. Light Cotopany's response to that Notice Of Violation.

As discussed in a September 21, 1992, telephone conversation between Mr. H. O. Christenson - Chief Project fioction IA, Reactor Projects Branch No.1, Division of Reactor Projects, and Mr. S. D. Floyd - BSEP Manager Regulatory Compliance, the response to Violation A, exarnple 2 will be supplemented by October 12, 1992.

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Very truly yours,.

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J'4W} Spencer,

%<rupbwick u ral Manager Nuclear roject TMJ/

Enclosure cc t - fir. S. O. Ebneter Mr. R. H. Lo BSEP NRC Recident Office 9209290259 920921 //f'){=y PDR. ADOCK 05000324

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E tiCLOSURE BPUNSWICK GTEAM ELECTRIC PLANT, UtilTS 1 AND 2 IRC DOCKET 140s. 50-325 & 50-324 OPLE;TIf4G LICENSE fJOS. DPR-71 & DPR-62 F r PL't TO I40TICE OF VIOLATION Y3DLAILOILAi A. Technical S}ccification 6.8.1.h requiros that written procedures shall be cotablinhed, ire plomo nt ed and maintained covering the activities r ec onne nded in Appendix "A" of Regulatory Guide 1.33, November 1972 including proceoures for performing maintenance.

1. Maintenance Procedure, HP-12, General Cleanlinosa Procedure, Revision 13, Section L.4.2.3 requires that openings in hardware and piping shall to capped, covered, or pluggod when not in use.

Contrary to the above, HP-12 was not properly implemented in that on July 10, 1992 the 2C conventional service water pump discharge check valvo (2-SW-V23) was used as a work ourf ace with the valve internals exponed renulting in maintenance debrie being introduced to the '

internals.

2. Maintenanco Managomont Manual OHMM-004, Preventive Maintenance, Reviaton S, Section 5.1.3.14 requires that any deviations from manuf acturer's recorwoendation should be handled in accordance with E tiP- 2 0. Section 5.0 states that a Prevent at ive Maintenance (PM) exception f orm should be submitted as soon as it is determined a PM will not be performed. Engineering Precedura, ENP-20, Engineering Wor lk Requact (EWR), Revielon 14c, Secti n 10, states that if action not taken deviates from the vendor's re' xcnendation. a deviation form should ho attached to the EWR pat:kage., This paccago requires two levels of engineering supervieory approval, Nuclsar Assessment Department ( f t hD ) reviou and Plant General Managor approval.

Contrary to the above, as of July 31, 1992, the licensee failed to obtsin the two level engineering supervisory approval, the NAD review and Plant General Manager approval for deferring the preventive maintenance since 1983 on two safety-related 4160 volt circuit breakero.

This is a Severity Level IV violation (Supplement I).

PLST.007 1 9_._VlRLAIION A*

EEt0lME_Tfe.,XLOLAILQN A - EX6EEILD Carolina Power und Light (CP&L) admits that MP-12 was not properly implemented an evidenced by '.he stated example.

R$PONSit TO VIQlrATIQLA - EXAM 111_1 E n.t2n for the violations i

Event Sequenc2 July 2, 1992. Maintenance personnel began corrective maintenance procedure CM-VCK506, Technocheck Check Valves, on service water pump "C" .tischarge check valve 2-SW-V23 in accordance with preventive maintenance, wor 4 request / job order i (WR/JO) 92 VEE 182. The v5 : ., was removed and an "oponing internal inspection" was '

performed in accordance wath MP-12 step 5.5.3. Covers were placed on the system piping to prevent inadvertent inclusion of foreign material while the valve was removed. Pre-made aluminum plates were utilized to cover the valve whenever snaintenance was not in progress.

July 6,19N . Mtintensuc var comple ed on the valve a W a Quality Control (QC) inspector performed the " closing internal inspection" in accordance with MP-12 ntop 5.5.3.1. The QC inspector checked "no unusual conditions noted" on the cleanliness data sheet. After re-installing the valve into the SW system, Haintenance personnel performed a resistance measurement check on installed dielectric insulators with unacceptable results. Note, the fit of dielectric inculators is critical, any exposed metal causes a low insulator resistancs  !

reading on all the bolts in the flange connection. l l

July 7, 1992. Maintenance personnel began investigating the low insulation  ;

resistance readings from bolt to flange.  !

July 10, 1992. The valve was removed and an " opening internal inspection" was perf ormed in accordance with MP-12 step 5.5.3. 2-SW-V23 was lowered to the floor directly below discharge piping to allow access for " custom . fitting" of dielectric insulators. The mylar sleeving material was measured through the pipe flange and beginning threads on the check valve to ensure correct insulator longth. Each bolt's (i.e., 20 bolts) sleeving was then cut to final size using the check valve as a flat curface to ensure a straight cut. This activity was g observed by an NRC resident inspector who noted that protection was not being pitovided to the valve internals, and the valve was being utilized as a cutting

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surface. The NRC inspector contacted maintenance eupervision concerning the evolution. The Maintenance Supervisor investigated the concern, stopped work on the check valve, had the valve cleaned and cleanliness controle restored, and had the general area housekeeping restored.

s July 11, 1992. Maintenance was completed on the valve and a QC inspector wrfornmd thn " closing internal inrpectien" in accordance with MP-12 step p 5.S.3.2. The QC inupector checked "no unusual conditions noted" on the cleanlinema data-sheet. . The valve was re-installed and the resistance test was re-performed with satisfactory results.

Discungign >

The purpose of MP-12 is to "... provido a program for system cleanliness and housekeeaing within the Haintenance Subunit. ... to assure the quality of the Drunuwich Nuclear Project operation."

- MP-12 establichus a "cleanlinesa classification" for nuclear power plant systems and subsystems. There are four cleanliness classifications, "A" through D" with "A" being thn highest level. The service water (SW) system has a "D" cleanliness-classification. MP-12, revision 33, statest CLhSS D cleanlinens is-a nominal level, .... in applications ....

wheru significant amounts of contamination are anticipated to be present in the procase fluid itself.

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The servico water system suction is supplied from the brackish waters of the Cape Fear River. Largo dobris (i.e., logs, marsh grass, etc...) is prevented from

clogging the SW pump suction by a diversion and traveling screens. Chlorine is utilized as a blocide agent. Some amount of contamination from debris which passes through the screens is anticipated.

Section 5.5 of MP-12, Pontoperatinati Repairs and Modifications, is applicable to the referonced maintenance performed on 2-SW-V23. Step G.5.2.2 states that

" Removed equipment, items, components which are to be reinstalled chall be verified / inspected to assure the item, equipment, or component is in a condition equal to or better than "as removed". Stop 5.5.2.3 requires personnel to implement section 5.4,I intenance of Installation Cleanliness, during repairs. j As noted in the violativa, step 5.4.2.3 states that " Openings in hardware and _j piping shall be capped, covered, or plugged when not in use."

During this evolution, the equiprnent was being utilitod to " custom fit" the insulators. Previous attempts to cut the insulators remote from the valve had failed. The Technochock valve plater were in the clor.ed positiori, the sealing members wars no' af f ecta.1 during the cutting evolutior., and the mylar sleeving

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" sawdust" was easily removed. Cleaning and QC inspection were performed prior to re-installation, satisfying MP-12 as stated in step 5.5.2.2 (see above i paragraph). The lead mechanic directing the cutting / measuring of the insulators '

3 was f amiliar with the general cleanliness procedures and the criteria of " class 4

D" cloanliness. Given the above, the quality of the valve and system was maintained; howevot, the work practices utilized did not meet the requirements of MP-12 and are not sanctioned by the management of the Brunswick Nuclear t Project.  ;

Corrective Steno Wttich Have Been Taken and Results Achieved:

The valve was cleaned and protective covers were installed. General housekeeping in the SW building was rostored. The involved craitsmen were counseled in expected houcokeeping and cleanliness standardo.

Corrective Stopp Which Will Be Taken to Avoid Further Violatiortg The houankeeping and cleanlinosa standards will be reviewed with the Maintenance I workforce to delineate and emphapito Hanagement's expectations during maintenance quarterly training. The review will be complete April 3, 1993.

Date When Full Compliance Will tio Achieved:

cp&L ir in cottollance, e

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1 EESPONSE TO VIOLATION A - E7f.MPLE 2

' Admission ;g Denial of Viohj;,Lqnt CP&L admits that the Preventive Maintenance (PM) program is in need of iprovements as indicateci by the stated example.

SJ ,on fer the._ % ]d LQD8 Ori August 13, 1992, due to various adverse condition repor+.s ' ACRs) initiated on the PM program. an overall root cause analysis (RCA) concerning the ndmi.nistration of the PM program was initiated by the corrective Action Program (CAM . The RCA is expeted to be complete by October 12, 1992, at which time the reason for this v!A16 tion will be provided in a supplement to this response.

Preliminaty analysis to date indicatos that Maintenance Management Manual OMMM-004, Prevontive Hun %nancs, revision 5, section L.1.3.14 conflicts with Engineering Procedure, ENP-20, Engineering Work Request (EWR), revision 14c, 6;: tion 10. It is belief that ENP-20, revision 14c, section 10 was tn bu used only for new vt recommendations and not for routiro PM exceptions w. 'h r are addressed in so" n 5.9 of OMMM-004, porrective Steps Which Have Been_Taken and igsq;;P Achievert:

Severr' M e internal to CP&L have identif tad concerno 'rith the PM Srogram and ha're c 0.;. ACRs in accordance with the CAP.

As an interim measure, by management directive, PM exceptions are being reviewed by Technica.1 Support personnel. When a concern exists with the exception an EWR is init - sted in accordanca with appropriato engineering procedures.

parrective Steos Which Will Qp._Jaken to Avoid Further Violationes Proceduren are beiry revised and developed which will better define the administrative, technical and iraplementation requirements of the PM Program.

This is expected tu be in place by November 30, 1992, and will include a ,

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structure that incorporates both Technical Support an? Maintenance functions, i

The basis documentation of the approximately 20,000 PM tasks .w.3180 frequencit.s I will be verified and 2:econstructed where missing. This information will be l captured and maintained in a computer data base that will be i sed for evaluation I

of PM deferrals nd program re'risions.

Date When Full Comp Qqnce Will He Aqh.Lgyg t

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l CP&L vill supplement this violation response ty October 12, 1992 upon completion of the referenced RCA. -The supplement will contain the reason for the violation,

j. additional cr revised corrective actions, if any, and the date when CP&L will be in full complianco.

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I VIOLAIl9M B:

B. Technical Specification 6.8.1.a requires that written procedures shall be established, 1nplemented and maintained covering the activities recommended in Appendix "A" of Regulatory Guide 1.33, November 1972, Aneluding equipment control (e.g. locking and tagging), authorities and reoponsibilities for safe operation and shutdown, and shift and relief turnover.

Local Clearance 1 -W - 14 69, Support to Main Stecm Line Isolation Valve Testing, required that Main Steam Line Drain Isolation Valve 1-B21-F016 be open. Operating Instruction 01-3.4, Daily Check Sheets, Revia'.n 39, requires a weekly tagout audit be conducted on Panel P601, Reactor ".urbine Gauge Board primary eyotems. Operating Instruction OI-2, Sh'

• Turnover Checklist, Revision 45, requires Control Operator and S<. sr Control Operator Control Board walkdowns in conjunction with shift .umovers.

Contrary to the above, these proceduros were t.ot edequately implemented in __

tha us. July 11, A5W, the cloarance established on 1-B21-F016 for the valve to remain open did not prevent its automatic closure on July 16, 1992. A subsequent tagout audit on July 17, 1992, and multiple control board walkdowns during shift turnnvers on July 16 to 20, 1992, did not identify the position of 3-D21-F016 as shut instead of open as required by .

the clearance.

This la a Severity Level IV violation (Supplement I).

EFSPONSE TO VIOLATION B:

Admission or Denial of Violation:

CP&L admits the violation.

)1eason for the Viplation:

Chronology 07-11-92 Main steam line drain valve, 1-B21-F016, is placed under clearance in the "open" position.

07-16-92 OA47 Power to the Reactor P"otection Syt ' im (RPS} bus "A" lost. Loss of RP3 bus "A" caused a half SCRAM, a half isolation of primary containment isolation valve (PCIS) groups 1, 2, 3, 6, and 8, isolation of secondary containment, and an automatic initiation of the Standby Gas Treatment System.

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0458 Commenced restoration of the RPS System por OP-03.

0538 Completed restoration of the RPS System and the Plant. NOTE: 1-B21-F016 was not r=:urned to the position rnquired by the clearance tag that had been placed on the valve's control switch.

07-17-92 Night shift (1900-0700) performed n clearance tag audit on the Unit 1 Control Room panel P601. 3 07-20-92 0700 1-B 1-P016 found in the " closed" position by a NRC Resident Inspector with a required "open" position clearance tag.

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Investigation of this event revealed the following:

1. 1-D21-FOl6 was tagged in the "open" position, with c)earance "

tage placed only on the valve's handwheel and control switch. . vrfve was tagged open to allow installation of a pressure gauge for LLRT related activitios. The LLRT procedure did not require that the automatic close function of the valve be disabled.

2. The clearance, #1-92-01469 Mas hung 1 accepted on 07-11-92. The ISI/LLRT group performed the associated . lve testing and the cla rance was lef t in place while valve refurbishment took place. The clearance tag on 1-B21-F016 could have been removed at this time. Clearance #1-92-0140 was cancelled on 07-28-92.

3. Between the time of the trip of the ' A' RPS HG set (0447/07-16-92) and the time that the Resideat NRC Inspector discovered that valve 1-B21-FOl6 was not in its requireo position (0700/07 20-92) approximately 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> had elapoed. During this period four different operating crews had been involvi.,d with standing watch in the Unit 1 Control Room. During ear:h 12-hour shift, the Reactor Operator is required to walk down the control panels hourly looking for discrepancies and developing trends. The Jenior Reactor Operator in also required to walk down the control panels at least once per shift. Nine shift turnovers occurred during this period, and valve 1-821-F016 was never identified as being out of its required position.

In addition, a weekly audit of the clearance tags hanging in the control room was performed by a licensed plant operator. The purpose of this audit to to verif y that all cagged valves are in the position required by an asscciated red tag. This audit and visual va; rif ication of valve pr-leton vervts tag pocition did not iaentAfy tha; volve 1-B21-F016 was nc in its required position. The Control Oper.ator who performed the audit could not explain why he did not detect Qe discrepancy.

4. The RP! Sy' .cm was restored to operation per OP-03. Step #24 of OP-03 allows for the 1-B21-F016 to be placed in the open position if desired.

This step var "N/A'd" by the first Control Operator and the indepenuent verifier. Clearances are provided to ensure saf e operating condit ions.

Clearance tags denote equipment which cannot be manipulated; therefore, -

neither Operator considered performing the optional step of opening the valve.

The valve is normally closed and wa3 cleared in the "open" position. Years of working with the clearance procedure has in-grained into plant operators, (licensed and non-licensed), that a clearance tag is almost exclusively Mace).e*ed with - closcd valve. In this case the valve was not required to be open to ensure safe operating conditions but to support a LLRT. Automatic closure of the valve was of no safety significance to personnel or the public and the valve would have been more appropriately controlled in accordance with r Administrative Instruction (AI) 58.2, Equipment Testing Procedure. However, at b the time of this test, the LLRT procedure was written such that it required a ,

clearance.

The fact that the clearance was left hanging during valve re-furbishing and the re performance of the LLRT te~t also contributed to this out-of-position condition. When the initial LuR2 testing had been concluded, the tag on the valve could have been removed, to return the plant to a more normal condition, and then re-hung when LLRT re-tectino was to be resumed.

The LLRT test procedures contain a suyrested isolation boundary for specific valve tests. When the LLRT group submits clearance requests, they rely on Operations personnel to add extra protection to the clearance. In this esse, the clearance was prepared exactly as it uma requested. It should be noted that the isolat ion boundary (i.e. , the boundury to ensure safe operating conditions) wa.

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udequate.

The following Root causes have been identified:

Lack of attention to detail in watch standing practices in the Main Control Room.

The use of a clearance to administratively control the position of a valve for test purposes, Corrective actions Taken To Date and Results Ach[2X248 to heighten the level of at.)ntion to detail, the oppos!..e Unit's Reactor operator is currently performing the weakly clearance audit of the control board.

A Management directive has been implemented requiring clearances to be hung on test boundary isolation valves only. Test tags will be ntilized on non-boundary isolation salvo.. This will prevent a valve from being under clearance when in fact it is not required to ensure .afe operating conditions for-the work in progreas.

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The involved LLRT procedure test lineup was revised to include the 1-B21-F016 breaker to prevent automatic closure.

The involved LLRT procedure was revised to allow for the use of Al-58.2.

Cprrective Actions That Will Be Taken To Avoid Further Violatiens The practice of using clearances to support LLRT work is currently being evaluated by the Site Assessmint Team (SAT). The final implementation plan and scaedule for clearance use on site will be complaced by December 1, 1992.

This' event will be reviewed with operations shift personnel during quarterly training by April 3, 1993.

Date of Full Compliance ,

l CP&L is currently in full compliance.

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