ML20125E545

Notice of Violation from Insp on 921002-30.Violation Noted: Procedures Were Not Adequately Implemented in That Unit 1 RO Did Not Obtain SRO Approval Prior to Initiation of Evolution Affecting CR Indication

ML20125E545
Person / Time
Site:	Brunswick
Issue date:	11/25/1992
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20125E541	List: IR 05000325/1992035 ML20125E545
References
50-325-92-35, EA-92-208, NUDOCS 9212170109
Download: ML20125E545 (19)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION Carolina Power and Light Company Docket No.: 50-325 Brunswick Steam Electric Plant License No.: DPR-71 Unit 1 EA 92-208 During an NRC inspection conducted on October 2 - 30, 1992, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations ve listed below:

A. Technical Specification 6.8.1.a requires that written arocedures shall be established, implemented, and maintained covering tie activities recommended in Appendix "A" of Regulatory Guide 1.33, November 1972 including administrative procedures for authorities and responsibilities for safe operation and shutdown.

Plant Operating Manual Volume I, Book 1, Administrative Procedure, Revision 145, requires Shift Supervisors, Senior Reactor Operators, and Reactor Operators to collectively perform operations to maintain the plant in a safe condition at all tines in accordance with procedures contained within the Plant Operating Manual and Technical Specifica-tions.

Operating instruction 01-1, Conduct of Operations, Revision 47, requires .

the Plant Monitor Reactor Operator to inform the Unit Senior Reactor Operator / Shift 'apervisor of any significant changes in plant parameters

i. and to refrain from becoming involved in evolutions that are not l

directly related to the frequent monitoring of plant parameters.

Brunswick Site Procedure BSP-50, Site Procedure for Command, Control, and Communication, Revision 1, requires that an evolution affecting or i potentially affecting Control Room indication requires Unit Senior l

Reactor Operater approval prior to initiation.

i Contrary to the above, on October 2, 1992, these procedures were not l

adequately implemented in that the Unit 1 Reactor Operator did not obtain Senior Reactor Operator approval prior to initiation of an evolution affecting Control Room indication, did not inform the Unit i

Senior Reactor Operator / Shift Supervisor of a significant= change in a i

plant parameter, and did not refrain from becoming involved in an l

evolution not directly related to the frequent monitoring of plant parameters. This resulted in reactor vessel water level being allowed to decrease to the Low Level 1 Engineered Safety Features actuation set point resulting in an automatic Reactor Protection System and Primary Containment Isolation System actuation to prevent further decrease in reactor vessel water level.

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

t 9212170109 921125 gDR ADOCK 05000325 PDR

Carolina Power and Light Company 2 Docket No.: 50-325 Brunswick Steam Electric Plant License No.: DPR-71 Unit 1 EA 92-208 B. Technical Specification 6.8.1.a requires that written procedures shall be established, implemented, and maintained covering the activities recommended in Appendix "A" of Regulatory Guide 1.33, November 1972, including administrative procedures for equipment control (e.g., locking and tagging).

Administrative Instruction Al-58, Equipment Clearance Procedure, Revision 38, provides the requirements for administering equipment clearances.

Contrary to the above, Al-58 was not properly established in that requirements for communicating to Licensed Operators the disablement of equipment and instrumentation caused by clearances were not included.

This resulted in the disablement of the Unit I lleactor Vessel High/ Low Level Alarm,1-A-7, Window 2-2, by Local Clearanco 1-92-2158, Dioital Feedwater Control System Modification, on September 15, 1992 without informing control room personnel. At the time, reactor vessel level control was Operator controlled and was dependent upon the low levcl alarm to lessen the potential for inadvertent draining.

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

Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.

20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the. violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the i date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for i Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

l Dated at Atlanta, Georgia this 25th day of November 1992 i

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ENCLOSURE 2 LIST OF ATTENDEES A1 THE NOVEMBER 23, 1992 ENFORCEMENT CONFERENCE Carolina Power and Liaht R. A. Watson, Senior Vice President, Nuclear Operations R. E. Morgan, Interim Manager, Brunswick Nuclear Project J. P. Cowan, Manager, Technical and Regulatory Support D. B. Waters, Manager, Brunswick Licensing 4 K. J. Ahern, Manager, Operations - Unit 2 S. D. Floyd, Manager, Regulatory Compliance R. A. Niec, Control Room Operator B. S. Strickland, Shift Supervisor M. S. Calvert, Manager, Associate General Counsel - Brunswick Nuclear Reaulatory Commission S. D. Ebneter, Regional Administrator, Region II (RII) 4 J. R. Johnson, Deputy Director, Division of Reactor Projects (DRP), RII A. F. Gibson, Director, Division of Reactor Safety, (DRS), RII E. G. Adensam, Director, Project Directorate 11-1, Office of Nuclear Reactor

Regulation (NRR)

G. P. Jenkins, Director, Enforcement and Investigation Coordination Staff (EICS), RII D. M. Verre111, Chief, Reactor Projects Branch 1, DRP, RII H. O. Christensen, Chief, Reactor Projects Section lA, DRP, RII D. J. Nelson, Resident Inspector - Brunswick, DRP, RII R. Lo, Project Manager, NRR M. E. Ernstes, Chief, Operating Licensing Section 2, DRS, RII B. Uryc, Senior Enforcement Specialist, EICS, RIl j R. E. Carroll, Project Engineer, Section IA, DRP, RII

C. F. Evans, Regional Counsel, RII e

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ENCLOSURE 3

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J CAROLINA POWER & LIGHT COMPANY

! BRUNSWICK NUCLEAR PROJECT i

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AND I

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l NUCLEAR REGULATORY COMMISSION l

ENFORCEMENT CONFERENCE NOVEMBER 23,1992

AGENDA latroduction R. A. Watson l

Overview R. E. Morgan Initial Conditions K. J. Ahern Sequence Of Fsvents K. J. Ahern /

R. A. Niec Safety Significance K. J. Ahern Direct Cause / K. J. Ahern Immediate Corrective Actions Root Cause / R. E. Morgan Long-Term Corrective Actions Conclusions R. E. Morgan Closing Comments R. A. Watson 1

OVERVIEW EVENT DIRECT CAUSE ROOT CAUSE 1

MANAGEhENT ASSESSAENT 2

l INITIAL CONDITIONS Unit 1 Status Cold Shutdown Decay Heat Removal System RHR Loop B (Primary)

Decay Heat Removal System RHR Loop A (Back Up)

Level Monitoring Instrumentation ERFIS l

l Established Level Band 200" - 240" 1

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i INITIAL CONDITIONS (cont.)

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l SYSTEMS OUT OF SERVICE i

i Condensate And Feedwater

Reactor Water Cleanup i

l Feedwater Level Control (For Installation Of Digital Feedwater) l i

High Pressure Coolant Injection l (Steam Supply Valve Disassembled For i

Maintenance)

Main Steam Line Drains

( (Drain Valve Disassembled For Maintenance) 4 l

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. SEQUENCE OF EVENTS s

. 8/15/92 RHR Lcop B Placed In Shatdown Cooling

>!15/92

'Searances Needed To Install Digital Feedwater

. Control Hung

.. p RPV Level HI/LO Annunciator Removed ham Service Without CompennA.n

• 1/19/92 RWCU Removed From Service For Leal Leak Rate Testing Of Isolation Valves Level Control Using Batch Transfer Of. Water To Radwaste Begins Processing Of Vessel Level Necessary ~ Eicry 3.5 Hrs.

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SEQUENCE OF EVENTS (cont.)

10/1/92 Operator Commences Level Reduction Operator Becomes Distracted By Telephone <

Level Decrease Terminated At 204" Event Discussed With Other RO And SRO t

10/2/92

= 1200 Shift Meeting Held To Discuss Upcoming Plant Visit .

Crew Told Plant Visit Report Required

~ 1300 Example Plant Visit Report Distributed C

1312 Operator Commences Level Reduction Initial RPV Tennperature = 92 F.

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SFAIIENCE OF EVENTS (cont.)

10/2/92 1312- Operator Begins To Read Example Plant Visit 1317 Raport 1317 RPV Water Level Decreases Below 200".

1321 RPS Trip Occurs On Low Level (=166" Above Top Of Active Fuel)

Isolation Of Shutdown Cooling Occurs 1327 Group Isolation Signal Reset - RPV Water Level >166" l

l 1345 RPS Trip Reset - RPV Water Level >200".

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SEO_UENCE OF EVENTS (cont.) _

i i 10/2/92 l = 1430 Loop B RHR Outboard Injection Valve Fails

! To Reopen Fully During Recovery From Isolation Of Shutdown Cooling-a i

1455 Shutdown Cooling Reestablished Using RHR Loop A Peak RPV Temperature = 97.2 F.

! Maximum Temperature Increase Over Duration Of Event = 5.2 F.

1525 Operator Interviewed By Site Incident Investigation Team 8

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SAFETY SIGNIFICANCE 4

Initial RPV Temperature Low (92 F.)

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1 Decay Heat Load Minimal ECCS Available i

All Protective Features Operated As Designed

! Loss Of Shutdmyn Cooling Not Significant For l = 12 Hours

! RIIR Loop B Outboard Injection Valve Available

! For Manual Operation f

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9 DIRECT CAUSE Operator Did Not Properly Perform License Duties l

Oversight Of Operator Not Properly Performed Proper Communication Not Utilized l

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IMMEDIATE CORRECTIVE ACTIONS Site Incident Investigation Team Promptly Convened Temporary Audible Level Alarm Installed 1

t Procedure Revised To Require A Second Operator Training Performed l

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IMMEDIATE CORRECTIVE ACTIONS (cont.)

Emphasized Expectations For Operators:

Standing Instruction For Essential Operator Activities Issued Reading Material Policy Clarified RO Responsibilities Reemphasized Shift Supervisor To Relieve Senior Control Operator Of Selected Work Control Responsibilities Upgrade Of Control Room Appearance And Condnct Initiated Shift Turnover Discipline Development Project Initiated l

l Continuing Assessment By Operations Management Established l

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! ROOT CAUSE i

ADEQUACY OF MANAGEMENT CONTROL OF

LICENSE ACTIVITIES i

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i Removed Audible RPV Level Alarm With No Compensating Instrumentation d

Removed RWCU From Service Requiring Batch Processing Of Level i

Shift Briefing On Non-Operational Matters Conducted In The Control Room l

Command And Control Not Fully Utilized In The Control Room l

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l LONG TERM

CORRECTIVE ACTIONS Site Incident Investigation Team Performed Thorough Root Cause Analysis And Provided Corrective Actions Obtained INPO Assistance For Root Cause Determination Revamp Modification Process l

Integrated Schedule Developed Perform Risk Assessments Perform Control Room Work Study l

Enhance Training 14

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CONCLUSIONS Prompt, Thorough Investigation Prompt Corrective Action i Broad, Long Terni Approach 1

Management Standards And Expectatioits i

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