ML20128L808

Insp Repts 50-324/84-39 & 50-325/84-39 on 841210-14. Violation Noted:Failure to Follow Procedure Re Obtaining Water Sample from RHR Sys to Verify Conductivity

ML20128L808
Person / Time
Site:	Brunswick
Issue date:	02/14/1985
From:	Caldwell J, Julian C, Poertner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128L790	List: ML20128L787 ML20128L798 ML20128L808
References
50-324-84-39, 50-325-84-39, NUDOCS 8507250120
Download: ML20128L808 (6)

See also: IR 05000324/1984039

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                                p Kirog                                            UNITED STATES
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                              h         'o                          NUCLEAR REGULATORY COMMISSION -
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                          ,y                n                                        REGION 18
                            g               j                             101 MARIETTA STREET,N.W.
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                                            2'                              ATLANTA, GEORGI A 30323
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                          Report Nos.i 50-325/84-39 and 50-324/84-39
                          Licemee: Carolina Power and Light Company
                                         411 Fayetteville Street
                                        -Raleigh, NC 27602-
                          Docket Nos.: 50-325 and 50-324                                        License Nos.: DPR-71 and DPR-62
                        -Facility Name: ' Brunswick.1 and 2
                        -Inspection Conducted:- December 10 - 14, 1984
                          Inspectors:            b~                               M                                                      2/[M/d'S-
                                         W. K. Po #tner,                         //                                                           Date Signed
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                                         J. L. CaldWell                          /                                                            Date Signed
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                        . Approved by:            b
                                            C. A. JuliW , Section Chief
                                                                                                                                          1//F/8S
                                                                                                                                            'Date Signed
                                            Operations Branch
                                   - -      Division of Reactor Safety
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>                                                                                  SUMMARY
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                          Scope: -This routine, unannounced inspection entailed 68 inspector-hours on site                                                    I
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                          in ,the areas of-Unit 2 RHR water hammer event and vessel drain to the torus.
                          Results: Within the areas inspected, one violation was identified (Failure to-
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                        ' follow procedure; see paragraph 5.b).
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                                  8507250120 850221
                                  PDR      ADOCK 05000324
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                                       REPORT DETAILS
     1.  Persons Contacted
         Licensee Employees Contacted
        *C. Allen, Regulatory Compliance
        *S. Dimmette, Assistant to Vice President
        *W.   Leonard, Operations Engineer
        *C. Blackmon, Operations Superintendent
        *M.   Hill, Technical Support
        *J. Chase, Operations Manager
        *E. Scarff, Operations Engineer
        *J. O. Sullivan, Maintenance Manager
        *L. Boyer, Director-Adminsitrative Support
        *J. McKee QC Supervisor
        *L. Jones Director QA/0C
        *A. Cheatham, Manager EGRC
        *W.   Hatcher, Security Specialist
        *D. Novotny, Regulatory Compliance                                            I
        *B. Hinkley, Technical Support
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        *A. Hegler, Radwaste Supervisor
         Other licensee employees contacted included operations, maintenance and
         engineering personnel.
         NRC Resident Inspectors
         D. Myers
         L. Garner
        *T. Hicks
        * Attended exit interview
     2.  Exit Interview
         The inspection scope and findings were summarized on December 14, 1984, with
         those persons indicated in paragraph 1 above.
         In a telephone conversation on February 1,1985, the inspector informed the
         plant manager that as a result of Region II's review of the report details
         presented in pararaph 5, one issue concerning failure to implement proper
         controls had been determined not to be a violation and will be identified as
         an inspector followup item. The issue should be addressed by the licensee
          in its response to this inspection report.
     3.  Licensee Action on Previous Enforcement Matters
         This subject was not addressed in the inspection.

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     4. Unresolved Items
        Unresolved items were not identified during this inspection.
     5. Unit 2 RHR Water Hammer Event and Vessel Drain to the Torus
        On November 28, 1984, an event was reported at Brunswick Unit 2 under
        10 CFR 50.72. The event included a water hammer event on the RHR steam
        condensing line and a vessel drain to the torus while attempting to place
        the unit into the shutdown cooling mode of operation. On December 10-14,
        1984, an inspection team composed of two individuals from Region II visited
        the Brunswick Nuclear Plant in order to evaluate this event.
        a.    Background
              On November 27, 1984, with Unit 2 at approximately 90 psi, operations
              commenced section 5 of OP-17 (Residual Heat Removal System Operating
             -Procedure) to place the unit into the shutdown cooling mode of opera-
              tion. RHR loop "A" was selected as the loop of RHR to be put in the       ,
              shutdown cooling mode due to the fact that the "B" loop of RHR was        I
              technically inoperable because the injection valve had been leaking
              and ' both the inboard and outboard injection valves had been
              electrically de-energized.
              The "B" loop of RHR is normally used when placing the RHR system in the
              shutdown cooling mode of operation. Using the "B" loop of RHR allows
              the flushing of the RHR system to be directed to the Radwaste system in
              lieu of the torus as required when using the "A" loop of RHR for
              shutdown cooling.
              OP-17 required that system flushes be conducted prior to entering the
              shutdown cooling mode of operation. The purpose of these flushes is to
              warm-up the RHR system piping and to ensure that the conductivity of
              the RHR system is less than 10 umho/cm. The first flush consists of
              bypassing the LPCI iniection check valve, opening the LPCI inMard
              injection valve E11-F015A and RHR HX 2A drain to the suppression pool
              E11-F011A.    The RHR HX 2A Level controller is then used to throttle
              open E11-LV-F053A to commence flushing the RHR HX discharge piping to
              the suppression pool. This evolution commenced at approximately
              2000 hours at which time a water hammer event was observed by a health-
              physics technician and reported to the control room. Water hammer is
              not considered an unusual event at Brunswick when placing the RHR
              system into shutdown cooling and cursory inspection by an r.xiliary     -
              operator did not detect damage to any piping or supports. !T. flush of
              the RHR HX discharge piping continued until the following shift at
              which time the discharge line flush was secured and a flush of the RHR
              pump suction lines was commenced.     The flush of the suction lines
              consists of opening shutdown cooling isolation valve E11-F009,
              throttling open shutdown cooling isolation valve E11-F008 and then
              throttling open E11-F053 to commence the flush to the suppression pool.
              This evolution commenced at approximately 0130 hours November 28, 1984.

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            However, when E11-F008 was throttled open, reactor vessel water level
            decreased rapidly which resulted in a reactor scram and a group 2, 6
            and 8 isolation. Reactor vessel level was restored, the RHR system was
            filled and .another attempt was made to flush the suction lines.     As
            E11-F008 was throttled open a vessel level decrease was noted and F008
            was shut. Level was restored and a third attempt was made to flush the
            lines. This attempt also resulted in a rapid vessel decrease and F008
           .was shut. A trouble ticket was processed on E11-F053 and the shift
            continued in OP-17 to place RHR loop "A" in the shutdown cooling mode
            of operation without further flushing.    The "A" loop of RHR was placed
            into shutdown cooling at approximately 0530 November-28, 1984. Further
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            investigation into the event revealed E11-F053 - had been full open
            during the flushes rather than closed as thought and that 15 of 19 pipe
            supports on the steam condensing line between E11-F052 and the RHR HX
            had been damaged due to water hammer.
            E11-F053 is an air operated valve and has a complicated control system.
            The - valve can be controlled by either RHR heat exchanger level
            (controller E11-LIC-R604A) or RCIC suction pressure (controller
            E11-LIC-R606A). The signal used to control the position of E11-F053A
            is determined by controller E11-SS-F605A. E11-SS-F605A normally
            receives both the level controller signal and the pressure controller
            signal and then outputs the lower of the two signals. This signal then
            controls the position of E11-F053. While troubleshooting the operation
            of E11-F053, it was determined that E11-SS-F605A was taking the two
            input signals (E11-LIC-R604A and R606A) and outputting the higher of
            the two signals. Further troubleshooting revealed that the output jack
            of controller E11-SS-F605A was plugged into the HI value position as
            opposed to the L0 value position as required. With E11-SS-F605A
            passing the high value, F053A received an open signal when air was
            supplied to the valve due to the fact that the RCIC suction pressure
            controller E11-LIC-R604A had been placed in automatic with the setpoint
            tape set at a value greater than RCIC suction pressure to allow the
            operator to use the RHR HX level controller to control the position of
            E11-F053A. E11-F053A has no position indication in the control room;
            therefore the operator had no means of determining the position of the
            valve other than the demand signals from the controllers. The only
            indication in the control room that could have alerted the operator of
            a problem was heat exchanger level. This indicator was later deter-
            mined to have been out of commission and pegged high during the event.
        b.  Failure to Follow Written Approved Procedures
            Section 5 of OP-17 requires that the RHR HX outlet temperature be
            within 110 F of reactor vessel water temperature and that conductivity
            of the RHR system be less than 10 umho/cm prior to securing the RHR HX
            downstream piping flush and continuing in OP-17 with the RHR pump
            upstream piping flush. The RHR HX outlet conductivity cell was out of
            commission and chemistry was unable to obtain a water sample from the
            sample line. When the sample valves were opened, air appeared to be
            drawn into the RHR system and no flow was observed. Due to the fact

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          that a water sample could not be obtained from the sample line the
          shift foreman marked the step "NA" and continued with the procedure.
          These same requirements are required prior to securing the RHR pump
          upstream piping flusn and continuing into the shutdown cooling mode of
          operation.
          Technical Specification 6.8.1.a requires written procedures be imple-
          mented covering procedures recommended in Appendix A of Regulatory
          Guide 1.33, November 1972. Item A.4 of Appendix A requires procedures
          be established for procedure adherence and temporary change method.
          Section 4.1 of 01-01, Operating Principles and Philosophy, states:
          " Procedure compliance is mandatory".
          Section 4.3.1.3 of 01-01 states: "An Operator may omit a step only if
          the step is applicable under a given condition as described in the step
          and is determined to be inapplicable by the operator, or if only a        '
          given portion of a procedure is required to be completed (i.e., per-
          formance of only a portion of a periodic test is required to satisfy a
          given PMTR)."
          Contrary to the above, the licensee failed to implement procedure
          01-01, in that while performing section 5 of OP-17 on November 27-28,
          1984, a water sample was not obtained from the RHR system to verify
          that the conductivity of the RHR system was less than 10 umho/cm
          as required by 0P-17 section 5 steps 17 and 41. The steps were
          marked "NA" and the evolution continued. This is a violation
          (50-324/84-39-01).
       c. Controller E11-SS-F605A Output Plug in Wrong Position
          The root cause of the water hammer and vessel draining event was
          determined to be that the output signal of controller E11-SS-F605A was
          selected to the HI jack as opposed to the L0 jack as required for the
          procedure to perform its intended function. Controller E11-SS-F605A
          was last calibrated on May 5, 1984, at which time records show that the
          output signal followed the lower of the two input signals as required.
          For the output of the controller to be switched from the L0 position to
          the HI position, the controller had to be opened up and the output plug
          unplugged from the L0 position and then plugged into the HI position.
          Investigation by the licensee to determine how the output plug could
          have been moved provided no explanation.      No documentation could be
          found that performed additional work on the controller.
          The inspectors expressed a concern about the apparent lack of adequate
          controls established concerning manipulations of the output jack of
          controller E11-SS-F605A.    No maintenance or operational procedure could
          be identified that manipulated the output plug and whatever caused the
          movement of the plug from the L0 position to the HI position did not
          ensure return of the plug to its proper position.       In a telephone
          conversation February 1, 1985, the inspector informed the plant manager
          that this issue should be addressed by the plant in its response to

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         this inspection report.  Th;s item will be identified as an Inspector
         Followup Item (50-324,325/64-39-02).

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