ML20133G932
| ML20133G932 | |
| Person / Time | |
|---|---|
| Issue date: | 01/14/1997 |
| From: | Racquel Powell NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Hulman L AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20133G934 | List: |
| References | |
| FOIA-96-534 NUDOCS 9701160229 | |
| Download: ML20133G932 (3) | |
Text
U.S. NUCLEA.R REGULATORY COMMISSION ~
NRC F OIA REQUEST f4UMBERtSI gM-h}
FOIA s34 daA RESPONSE TYPE
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RESPONSE TO FREEDOM OF xX I FINAL l l PARTIAL INFORMATION ACT (FOIA) REQUEST s
DATE
%e...o rJAN 14 w DOCAE T NUMBER (Si f/f spoteable)
REQUESTE R Lewis G. Hulman PART l.-AGENCY RECORDS RELEASED OR NOT LOCA) 30 fSee checkedboaes/
No agency records subject to the request have been located.
No additional agency records subject to the request have been located.
RNuested records are available through another public distribution program. See Comments section.
Agency records subject to the request that are identified in Append.x(es) are already available for public inspection and copying at the NRC Public Document Room,2120 L Street, N.W., Washington, DC.
O Agency records subject to the request that are identified in Appendix (es) are being made available for public inspection and copying X
ct the NRC Public Document Room,2120 L Street, N.W., Washington, DC,in a folder under this FOI A number.
Th3 nonproprietary version of the proposal (s) that you agreed to accept in a telephone conversation with a member of my staff is now being made available for public inspection and copying at the N RC Public Document Room,2120 L Street, N.W., Washington, DC, in a folder under this FOI A number.
Agency records subject to the request that are identified in Appendix (es) may be inspected and copied at the NRC Local Public Document Rcom identified in the Comments section.
Enclosed is information on how you may obtain access to and the chtrWs for copying records located at the NRC Public Document Room,2120 L Street, N.W., Washington, DC.
X Agency records subject to the request are enclosed. Appendi x A, and rel easabl e portions of Appendix B documents Records subject to the request have been referred to another Federal agency (ies) for review and direct response to you,a re enc l 0500.
Fees NONE You will be billed by the NRC for fees totaling $
You will receive a refund from the NRC in the amount of $
in view of N RC's response to this request, no further action is being taken on appeal letter dated
, No.
FART 11. A-INFORMATION WITHHELD FROM PUBLIC DISCLOSURE Certain information in the requested records is being withheld from public disclosure pursuant to the exemptions described in and for the reasons stated XX in Pzrt II, B, C, and D. A. -
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sr NRC FZM 464 (Part I) (191)
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FOlA NUM8 ems)
DATE RESPONSE TO FREEDOM OF INFORMATION ACT (FOlA) REQUEST FOlA 534
'N 14 WW (CONTINUATION) l PART 18.8-APPLICABLE EXEMPTIONS Records subject to the request that are described in the enclosed Appendix (es) are being withheld in their entirety or in part under the Exemption No.(s) and for the reason (s) given below pursuant to 5 U.S.C. 552(b) and 10 CF R 9.17(a) of N RC regulations.
- 1. The withheld anformation is properfy classified pursuant to Emocutive Order (Exemption 1)
- 2. The withheld enformation relates solely to the antemal persormM rules and procedures of NRC. (Exemption 2) l l 3. The withheld information is specifically exempted from public disclosure by statute indicated. (Exemption 3)
Sections 141 145 of the Atomn: Energy Act, which prohibits the disclosure of Restricted Date or Formerly Restncted Data (42 U.S.C. 21612165L Section 147 of the Atomic Energy Act,which prohibits the disclosure of Unclassified Safeguards information (42 U.S.C. 2167).
- 4. The withheld information as a trade secret or commercial or financial mformatsor, that is being withheld for the reason (s) indicated. (Exemption 4)
The enformation es considered to be confidential busmess (propnetaryl mforrnation The mfremation se considered to be proprietary mformation pursuant to 10 CFR 2.790(dHIL i
The mformation was submitted and received m confidence pursuant to 10 CFR 2_790 ldh 2)
- 6. The withheld mformation consists of mteragency or mtraagency records that are not avadable through discovery dunng titigation (Exemption 5). Apphcable Privilege:
Deliberative Process: Disclosure of peeoecesional mformation would tend to inhettat the open and franti enchange of ideas essential to the dehberative process Where records are withheld in their entirety, the f acts are mentncably entertwaned with the predecis onal mformation There also are no reasonably segregable f actual portions because the release of the f acts would permit an indirect snquiry mto the predecisional process of the agency.
Attomey work product privilege IDocuments prepared by an attorney in contemplation of litigation I Attorney client privilege (Confidential commumcations between an attomey and his/her chent.)
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- 6. The withheid mformat on is esempted from public disclosure because its disclosure would result m a clearly unwarranted mvasion of peisonal pnvacy. (Exemption 6)
- 7. The withheld anformation consists of records compiled for law enforcement purposes and is being withheld for the reason (sl mdicated (Exemption 7)
Disclosure could reasonably be espected to mterfere with an enforcement proceedmg because it could revea' the scope. direction, and' focus of l
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enforcement efforts, and thus could possibly allow recipients to take action to shield potential wrongdomg or a violation of NRC requirements from investigators. IE semption 7 (A))
Disclosure would constitute an unwarranted invasion of personal privacy. (Ememption 7(C))
The mformation consists of names of individuals and other mformation the disclosure of which could reasonably t'.f emoected to reveal identities of confidential sources. (Enemption 7 (D))
OTHEH l
PART ll. C-DENYING OFFICIALS Pursuant to 10 CF R 9.25(b) and'or 9 25(c) of the U S. Nuclear Regulatory Commission regulations, it has been determined that the information withheld is exempt from pro.
duct 6on or disclosure, and that its production or desclosure is contrary to the pubhc mterest. The persons responsible for the denial are those of f,cials identified below as denymg officials and the Director, Division of Freedom of Information and Publicat ons Services. Office of Administration, for any denials that may be appeated to the Executive Director for Operations (EDO) l DENYING OFFICI AL TITLE, OFFICE RECORDS DENIED APPELLATE OFFICIAL Em SECRETARY 10 IRobertA.Watkins Acting Assistant Inspector General for Invash.gatinns Appench. y R YY l
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l I
l PART 11. D-APPEAL RIGHTS The d: mal by each denymg official identified in Part il.C may be appealed to the Appellate Official identified there. Any such appeal must be made in writing withm 30 days of receipt of this responsa. Appeals must be addressed, as appropnate, to the Executive Director for Operations. to the Secretary of the Commission. or to the inspector General, U.S. Nuclear Rrgulttory Commission, Washington, DC 20555 and should clearly state on the envelope and m the letter that it is an " Appeal from an initial FOI A Decision."
N7,C FORM 464 (Part 2) (191)
U.S. NUCLEAR REGULATORY COMMISSION
4 r
1 Re FOIA-96-534 APPENDIX A RECORDS BEING RELEASED IN THEIR ENTIRETY (If copyrighted identify with *)
NO.
DATE DESCRIPTION /(PAGE COUNT) 1.
3/5/96 Office of Inspector General Event Inquiry, Case No. 96-01S:
Implementation of Recommendations to Improve NRC's Program for Protecting Allegers Against Retaliation.
(21 pages) 2.
5/8/96 Office of Inspector General Event Inquiry, Case No. 96-04S:
HRC Staff's Actions Related to Regulation at Maine Yankee.
(30 pages) i e
S 2
b.
Observations and Findinas The inspector observed por' ions of the Organizational Readiness Affirmation conducted on November 2,1996. The meeting was conducted in accordance with Plant Programs PLP 29, Self Assessment for Readiness to Startup. The plant manager had each organization manager individually discuss readiness to support startup activities. Areas addressed during this meeting included staffing needs, outstanding regulatory commitments, completion of applicable training, and management housekeeping responsibilities as delineated in Administrative Instruction 0AI-114 Management Responsibilities for Housekeeping. The inspector found the meetings adequate to assess organizational readiness to support startup activities. Assessments were found to be thorough and several items were identified for the startup plant nuclear safety committee (PNSC) review.
The ins actor attended a portion of the PNSC meeting on November 4, 1996.
Emphasis was placed on the power uprate activities. The five license conditions associated with power uprate were reviewed. A very thorough discussion of work on the turbine electro hydraulic control (EHC) system was conducted. The meeting was comprehensive and reviews for readiness to support startup activities were acceptable.
c.
Conclusion The inspector found the organizational readiness assessment meeting to be adequate. The assessments were appropriate to evaluate organizational readiness to support startup activities. The PNSC meetings were comprehensive and provided a thorough evaluation for startup activities.
02 Operational Status of Facilities and Equipment 02.1 Loss of Shutdown Coolina a.
Inspection Scope (71707)
The inspectors reviewed licensee activities connected with the loss of shutdown cooling event on October 11, 1996, previously discussed in NRC Inspection Report 50-325/96 15.
b.
Observations and Findinas On October 11, 1996, while Unit 1 was in mode 5 with 205 fuel assemblies transferred to the spent fuel pool, an individual working on instrument rack 1-H21 P022 jarred reactor pressure switch 1 832 PS N018B which caused a Group 8 primary containment isolation signal. The isolation signal closed the 1 E11 F008 Shutdown Cooling (SDC) suction valve resulting in a trip of the 1A residual heat removal (RHR) pump which was being used for SDC. The control room operator recognized that the 1A pump had tripped and promptly restored SDC within 8 minutes. Coolant
5 was protected from freezing. The inspector noted that the Control Building Heating. Ventilation and Air-Conditioning (CBHVAC) room located outside on the 70' elevation and the Main Stack Buildings were not included in the cold weather bill.
In the CBHVAC room the inspector identified the absence of cold weather precautions for the Ambient Chlorine Analyzers. After review of the Chlorine Analyzer Technical Manual, the inspector informed the licensee of the vendor's recommendation that the ambient temperature be maintained above 32 F for the analyzers. Based on this information the licensee submitted procedure change requests to revise the CBHVAC System operating procedure, an annunciator response procedure for a low temperature annunciator for the CBHVAC room, and the cold weather bill to include a once per shift-verification that the temperature in the CBHVAC room did not drop to 32 F.
The inspector reviewed NRC Information Notice 94-19. Emergency Diesel Generator Vulnerability to Failure From Cold Fuel Oil and verified that the licensee had precautions in the cold weather bill to ensure the operability of the diesel fuel oil transfer system. The inspector identified that no measures were in place for the protection of the fuel oil supply for the backup diesel generator used to supply )ower to the Emergency Operations Facility / Technical Support Center (E0F/TSC). The licensee Nued a WR/JO to insulate the fuel line to prevent the fuel from sludging due to low temperature. The licensee is addressing these concerns.
C.
Conclusion The cold weather program and procedures were found satisfactory to provide guidance for implementation of cold weather protective measures.
Continued inspection of the cold weather program implementation will be corducted.
05 Operator Training and Qualification 05.1 Operator Trainino for Power Vorate Modification a.
Insoection Scope (71707)
The inspector reviewed the Licensed Operator Requalification (LOR) training package provided for implementation of Power Uprate on Unit 1.
b.
Observations and Findinas In preparation for the implementation of Power Uprate on Unit 1, the inspector reviewed the Licensed Operator treining Jackage arovided during Cycle 6 of LOR. The classroom lesson plan
_01-CLS _P 500 96 6 Power Uprate Modification, covered all of the changes and impacts associated with the implementation of Power Uprate on Unit 1.
The Power Uprate modification would raise the core thermal power of the reactor core from 2436 Megawatts thermal to 2558 Megawatts thermal or an additional 5% power.
?
4 Discussions with members of the risk assessment team who performed the shutdown risk assessment for the Unit 1 outage indicated that the potential implications of working this activity during refueling were recognized. Despite this review, the inspector could find no condition report indicating the failure of ESR 94 406 to adequately assess the possible impact of the structural modification on the pressure sensor.
The failure of the risk assessment team to initiate a condition report to record the deficiency once recognized was identified as a weakness and discussed with licensee management.
The ins pctor reviewed the corrective actions associated with LER 1 96-14 and other actions initiated to prevent recurrence.
Identified multiple barriers failed to prevent the loss of shutdown cooling event, including the ESR design review, scheduling 3rocedural requirements, as well as WR/JO implementation instructions.
Jpon review of the corrective actions and discussions with licensee management, the inspector determined that the actions established were not prescriptive i
enough to prevent recurrence, due to the similarities of the corrective actions for this event and the actions associated with previous loss of SDC events described in LERs 1 95 04 and 1 94 01. This was the third loss of shutdown cooling event that has occurred in three years.
c.
Conclusions The failure to properly preplan and perform the structural modification to instrument rack 1 H21-P022 to 3revent affecting decay heat removal was identified as a violation wit 1 three examples. The failure of the risk assessment team to initiate a condition report once recognized was identified as a weakness. The inspector determined that the corrective i
actions established were not prescriptive enough to prevent recurrence.
j 02.2 Cold Weather Preparations a.
Inspection ScoDe (71714)
The inspector reviewed the program and procedures governing the implementation of the freeze protection program.
b.
Observations and Findinos The licensee began preparations for cold weather by performance of Preventive Maintenance (PM) Procedure OPM HT001, Preventive Maintenance on Plant Freeze Protection and Heat Tracing Systems. The inspector reviewed the work request / job order (WR/J0) for the PM. This PM provided an operability check of the freeze protection and heat tracing system.
l The inspector reviewed the Freeze Protection and Cold Weather Bill l
contained in Operating Instruction 00I 01.02, Shift Routines and l
Ope"ating Practices and Fire Protection Procedure 0FFP 24, Freeze Protection of Fire Suppression Systems. The inspector reviewed precautions for ensuring that equipment located in the outside buildings
3 heatup was minimal, less than 1 F, with a calculated heatup rate of 4.83 F/hr and a calculated time to boil of 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />.
In licensee event re> ort (LER) 1-96-14, Loss of Shutdown Cooling During Instrument Repair, t1e licensee attributed the loss of shutdown cooling event to improperly scheduled work activities.
Initially, the modification to the instrument rack was appropriately scheduled and the overall outage schedule was frozen. One week before the outage, concerns with workload leveling by maintenance personnel led to a scheduler rescheduling the activity during core offload.
This schedule change was not in accordance with Brunswick Site Procedure BSP 35, Outage Planning. BSP 35, required final approval of scope changes after the outage schedule was frozen to be made by the Superintendent Outage Management. This change did not receive the required BSP 35 final approval.
Technical Specification (TS) 6.8.1 recuires that written procedures shall be established, implemented, anc maintained as recommended in Regulatory Guide 1.33 covering maintenance activities which can affect the performance of safety related equipment. These activities should be properly preplanned and performed in accordance with written procedures, documented instructions or drawings appropriate to the circumstances.
The failure to pro >erly preplan the structural modification to instrument rack 1 121-P022 to prevent the loss of decay heat removal was identified as the first example of VIO 50 325/96 16 01, Improper Work 1
Planning Resulted in a Loss of Shutdown Cooling.
The inspectors reviewed the affected instrument rack and associated instrumentation, the engineering service request (ESR), work request / job order (WR/J0), associated outage prncedures, and other documentation.
ESR 94-406 contained the system impact evaluation. This evaluation was to determine whether the instrument rack structural modifications should be performed online or during unit shutdown. The inspector's review i
found that the aossibility of a loss of SDC signal as a result of vibration of 1-121 P022. B Instrument Rack was not evaluated. The failure in ESR 94-406 to identi; the potential impact this work would have on the RHR system was identified as the second example of VIO 50-325/96-16 01, Improper Work Planning Resulted in a Loss of Shutdown
- Cooling, i
Precautions contained in the WR/JO included the performance of a pre job briefing with operations. This briefing would have aided in a clearer understanding of the listed precautions and limiting actions prior to WR/JO implementation. The licensee determined that no pre job briefing with operations was conducted.
Modification Administrative Procedure OMAP 005, Implemenation of Major Modificiions, requires that prerequisites are verified 3rior to start of work and that work shall be performed in accordance wit 1 the instructions drawings, sketches, design documents, and procedures as specified in the WR/J0. The failure to follow the instructions to perform a pre job briefing with operations was identified as the third example of VIO 50 325/96-16 01. Improper Work Planning Resulted in a Loss of Shutdown Cooling.
6 The lesson plan covered in detail the specific impact that the implementation of Power Uprate would have on each of the following areas: setpoint changes; operating parameters; system specific im changes to Emergency Operating Procedures; changes to procedures: pacts:
Emergency Response Facility Information System and Process computer changes; modification and changes to the EHC system; and the procedures i
for the start up testing program.
l In detailing the specific changes to setpoints, the lesson plan provided a table of new and old values for comparison and TS references. Similar tables were provided detailing system impacts and procedure changes.
c.
Conclusions The inspector reviewed the Power Uprate lesson plan and concluded that it clearly communicated the changes and impacts associated with the implementation of Power Uprate on Unit 1.
The lesson plan provided a detailed review of the changes and impact that the modification would have on all aspects of alant operation. Additionally, the inspector reviewed and verified t1at all licensed operators, except for two, received the training prior to unit start up. The two o question would receive training prior to standing watch.perators in 06 Operations and Administration 06.1 0utaae Controls a.
Inspection Scope (71707)
The inspector reviewed the refueling outage that was accomplished in 33 days.
b.
Observations and Findinas The Unit 1,1996 refueling outage was accomplished in 33 days: the shortest ever at Brunswick. Effective planning and controls during the outage lead to this timely accomplishment. The licensce continues to demonstrate a strength for control of outage activities. This was accomplished in part by using shift outage meetings, unified outage logs, and remote monitoring cameras of key work areas such as the refueling floor. Noteworthy, this outage, was the emphasis placed on reducing or eliminating operator workarounds, annunciator problems, and gauge board deficiencies.
c.
Conclusions The licensee continued to demonstrate a strength in control of outages.
Emphasis place on reducing control room board deficiencies was noteworthy.
l 08 Miscellaneous Operations Issues (92701) l
1 7
08.1 (Closed) Unresolved Item 50 325/96 15 02 Loss of Shutdown Cooling This item was closed based on changing the unresolved -tem to violation 325/96 16 01 issued in this report.
II. Maintenance-M1 Conduct of Maintenance M1.1 General Comments a.
Inspection Scope (61726)
The inspector observed the performance of the surveillance test to verify secondary containment integrity.
b.
Observations and Findinas On November 1, 1996, the inspector observed the performance of surveillance test 1 PT-15.4, Secondary Containment Integrity. This test was performed to verify conformance with the requirements of TS 4.6.5.1.6.
This test confirmed that 0.25 inch of water vacuum could be i
maintained in secondary containment with Standby Gas Treatment System j
(SBGT) in operation.
Prior to the start of core reload on October 23, 1996, the inspector asked licensee management if secondary containment integrity could be maintained due to reports of roof water leaks in the reactor building.
This concern was reviewed by the licensee and they concluded that secondary containment was adequate since there were no visual openings after Hurricane Bertha or Fran. The secondary containment integrity test had not been performed after either hurricane and was scheduled for November 1, 1996. This test was last performed nearly 18 months ago as required by TS.
The inspector observed preaarations for the test in Unit 1 control room.
The inspt.ctor noted that tie SBGT section of the main control room panel was covered with green plastic covering to allow touch up painting of the panel. A supervisor directed that the plastic covering be cut to allow operation of the SBGT system switches and directed that only clear plastic covering be used in the future.
The inspector observed collection of test data on the refuel floor.
Manometer readings were taken at each of the four walls on the refuel floor and the data averaged to 0.275 inch of water. This however i
provided little margin above the required 0.250 inch of water.
The licensee tested the reactor building for leaks using infrared thermography and found leaks on the 80 foot elevation, 117 foot elevation, and in the reactor building roof. These were sealed and 1 PT-15.4 was performed again on November 4, 1996, with a reading of 0.35 inch of water.
8 c.
Conclusion The test met the TS required value for vacuum. However, the as found condition of secondary containment integrity only provided 0.025 inch of water vacuum margin. The licensee repaired various leaks and was able to increase the margin to 0.100 inch of water vacuum.
M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Tornado Check Valve Damoer Failure a.
Inspection Scope (62707) l The inspector reviewed the failure of the control building ventilation system tornado check valve dampers, located in the control building ventilation intake structure, that occurred on November 12, 1996. This caused both units to be in a 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to hot shutdown limiting condition for operation (LCO).
b.
Observations and Findinas l
The inspector learned that at 5:00 p.m. on November 12, 1996, the licensee had entered a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> LC0 for both units. This was because the control building ventilation check valve dampers would not shut due to corrosion buildup on the seating surfaces. This was found during a licensee's visual inspection. The failure of these dampers caused the control building ventilation to be inoperable. The licensee entered LC0
- A2 96 1117 to track the problem. The licensee performed PM instruction AHVV003, tornado damper visual inspection, and found that inlet tornado damper,1-VA 1A-CV-CB, would not close completely. The piping around the damper had rusted and blistered to the point that the damaer would not close. A similar condition was found on 2A damaer.
Bot 1 dampers were repaired and OPT 12.1.2 Tornado-Pressure Chec( Damper Test, was performed to demonstrate operullity of the dampers. The LC0 was exited at 6:30 p.m. on November 12, 1996. The licensee initiated CR 96 03765 to document the problem.
The inspector has observed that the material condition of this ventilation Jiping was aoor. When initially assigned to the site in July 1994, t1e control auilding ventilation room was pointed out by the previous NRC senior resident inspector as the area with the worst material condition in the plant.
Furthermore, in NRC Ins)ection Report 50-325(324)/96 04, the degraded condition of the air inta(e plenum was noted.
Other than painting and insulating in the area, the licensee has done little to correct the degraded material condition. Although the licensee routinely performs surveillances on this equipment to determine operability, the poor material condition has not been corrected.
.