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Safety Insp Repts 50-324/88-01 & 50-325/88-01 on 880101-31. Violations Noted.Major Areas Inspected:Areas of Followup on Previous Enforcement Matters,Maint Observation,Surveillance Observation & Operational Safety Verification
	ML20148E859
Person / Time
Site:	Brunswick
Issue date:	03/14/1988
From:	Fredrickson P, Ruland W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20148E842	List: ML20148E838; ML20148E851; ML20148E859;
References
	50-324-88-01, 50-324-88-1, 50-325-88-01, 50-325-88-1, NUDOCS 8803280017
	Download: ML20148E859 (12)
	v • d • e

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gQ Riou UNITED STATES -

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NUCLEAR REGULATORY COMMISSION

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f'oj 101 MARIETTA STREET, N.W.

ATLANTA, G EoRGI A 30323

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Report Nos. 50-325/88-01 and 50-324/88-01

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Licensee: Carolina Power and Light Company

P. O. Box 1551

Raleigh, NC 27602

Docket No. 50-325 and 50-324 License No. OPR-71 and OPR-62

Facility Name: Brunswick 1 and 2

Inspection Conducted: January 1 - 31, 1988

Inspect : bi N

W. H. Ruland Date Signed

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Accompanying Personnel: D. J. Nelson

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S. J. Vias

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Approved By: -l' < \

P. E. Fredrick's'on, Section Chief

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D(te Signed

Division of Reactor Projects

SUMMARY

Scope: This routine safety inspection by the resident inspector involved the

areas of followup on previous enforcement matters, maintenance observation,

surveillance observation, operational safety verification, preparation for

refueling, followup on inspector identified and unresolved items, onsite

followup of events, inadvertent heatup of Unit 1, and plant modifications.

Results: In the reas inspected, one violation was identified - failure to

complete Technic., Specification surveillance within the required time. A

i personnel error which allowed an inadvertent heatup of the reactor coolant

l system and a question concerning the seismic class of the Rad stion Monitoring

l System remained unresolved at the conclusion of the inspection.

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DETAILS

1. Persons Contacted

Licensee Employees

E. Bishop, Manager - Operations

S. Callis, On-Site Licensing Engineer

G. Cheatham, Manager - Environmental & Radiation Control

R. Creech, I&C/ Electrical Maintenance Supervisor (Unit 2)

C. Dietz, General Manager - Brunswick Nuclear Project

R. Eckstein, Manager - Technical Support

K. Enzor, Director - Regulatory Compliance

R. Groover, Manager - Project Construction

W. Hatcher, Supervisor - Security

A. Hegler, Superintendent - Operations

R. Helme, Director - Onsite Nuclear Safety - BSEP

J. Holder, Manager - Outages

P. Howe, Vice President - Brunswick Nuclear Project

L. Jones, Director - Quality Assurance (QA)/ Quality Control (QC)

R. Kitchen, Mechanical Maintenance Supervisor (Unit 2)

J. Moyer, Manager - Training

G. Oliver, Manager - Site Planning and Control

J. O'Sullivan, Manager - Maintenance

B. Parks, Engineering Supervisor

R. Poulk, Senior NRC Regulatory Specialist

J. Smith, Director - Administrative Support

R. Warden, I&C/ Electrical Maintenance Supervisor (Unit 1)

D. Warren, Acting Engineering Supervitor

B. Wilson, Engineering Supervisor

T. Wyllie, Manager - Engineering and Construction

Other licensee employees contacted included construction craftsmen,

engineers, technicians, operators, of fi:e personnel, and security force

members.

Attended the exit interview

2. Exit Interview (30703)

The inspection scope and findings were summarized on February 3, 1988, ,

, with those persons indicated in paragraph 1. The inspector described the

l areas inspected and discussed in detail the inspection findings listed

below. Dissenting comments were not received from the licensee. Proprie-

tary information is not contained in this report.

Item Number Description / Reference Paragrah

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VIOLATION - Failure to Perform DG Surveillance

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325/88-01-01 &

324/88-01-01 Within TS Time Limits (paragraph 4.a).

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325/88-01-02 & URI* - Seismic Requirements for Radiation

324/88-01-02 Monitoring System (paragraph 4.b).

325/88-01-03 URI - Inadvertent Heatup During Cold Shutdown

(paragraph 10.)

325/88-01-04 & -IFI - Review DG Reliability Assessment (paragraph

324/88-01-04 4.a).

Note: Acronyms and abbreviations used in the report are listed in para-

l graph 12.

3. Followup on Previous Enforcement Matter (92702)

(OPEN) Violation 325/87-02-05 and 324/87-02-05, Failure to Follow Mainten-

ance Procedures When Installing Motor-0perated Valve Anti-Rotation

Devices. The licensee found a problem with the anti-rotation device of

valve 1-E51-F022, the RCIC return to the CST. In response to the viola-

tion the licensee had re-inspected the above valve with satisfactory

results. Based on log reviews and interviews, the inspector found that:

on January 8, QA had found that the anti-rotation device for F022 had

fallen down the valve shaft and the valve shaft-to-ARD key had fallen down

to the bonnet area. The licensee re-inspected all accessible Anchor-

Darling valves with anti-rotation devices under WR/JO 88-AARJ1 and

88-AARK1.

The only other problem found was with 2-G31-F042, RWCU Return to Vessel

Isolation Valve, which was found with the set screw and key intact but the

ARD loose on the shaft. The licensee had a vendor representative inspect

the F022 valve. The vendor representative recommended that the licensee

use a tighter fit between valve stem and ARD. The licensee plans to

inspect the ARDs routinely every 9 months until the inspection results

dictate a change.

(CLOSED) Violation 325/87-13-02, Failure to Properly Implement Surveill-

ance Procedure. During ILRT, one channel of high drywell pressure instru-

ment was not de-energized as required due to a fuse labeling problem. A

reactor steam dome pressure instrument was disabled instead. The

inspector reviewed records documenting the licensee's corrective actions,

including a review of procedure changes.

(CLOSED) Violation 325/87-17-01, Plant Incident and Post Trip Investiga-

tion Form Not Completed as Required by 01-22. The inspector reviewed

records, including the revisions to 01-22. The inspector has no further

questions or concerns.

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No significant safety matters, violations, or deviations were identified.

An Unresolved Item is a matter about which more information is required to

determine whether it is acceptable or may involve a violation or oeviati n.

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4. Maintenance Observation (62703)

The inspectors observed maintenance activities, interviewed personnel, and

reviewed records to verify that work was conducted in accordance with

approved procedures, Technical Specifications, and applicable industry

codes and standards. . The inspectors also verified that: redundant

components were operable; administrative controls were followed; tagouts

were adequate; personnel were qualified; correct replacement parts were

used; radiological controls were proper; fire protection was adequate;

quality control hold points were adequate and observed; adequate post-

maintenance testing was performed; and independent verification require-

ments were implemented. The inspectors independently verified that

selected equipment was properly returned to service.

Outstanding work requests were reviewed to ensure that the licensee gave

priority to safety-related maintenance.

The i nspectors observed / reviewed portions of the following maintenance

activities:

88-AABF2 Inspection of Miller Actuator for 2-G16-F020.

88-AAYJ1 Replacement of JWPSCR Allen-Bradley Relay in DG No. 2.

88-FFG021 Megger E-7 Transformer per MI-10-2L1.

88-KAD021 GE 480VAC MCC Checkout per MI-10-2K1 for Switchgear 1PA.

87-BI2U1 Valve 1-SW-V212 CR205 Auxiliary Contact Replacement.

87-BJ1J1 1-CAC-FS-4409-35 Sample Return Flow Switch Replacement.

a. Diesel Generator Items

Several apparently unrelated emergency diesel generator failures

occurred during the month that warrant further licensee and inspector

followup. Problems included failed fuel oil level switches, inter-

mittent annunciator relay contacts, and broken wire lug. The

inspector conducted interviews with plant maintenance personnel,

reviewed logs, examined records and equipment and determined that the

licensee corrected the equipment problem in each case. However, tne

reliability numbers of the emergency diesel generators were lowered

by the DG outages. The Onsite Nuclear :afety group developed a

review plan to examine DG reliability. The plan calls for a review

of recent DG failures using a systematic methodology. Current DG

availability will be compared to PRA model assumptions, station

blackout requirements and industry averages. A separate plan and

schedule for reliability centered maintenance may also be developed.

The inspector concluded that the licensee's response to the issue was

appropriate. The plan, schedule, and results will be reviewed during

future inspections. This is an Inspector Followup Item: Review DG

Reliability Assessment (325/88-01-04 and 324/88-01-04).

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The inspector found, during a log review on January 5, that the TS

surveillance (quick start and load the DGs for 15 minutes) was not

completed within two hours as required with two DGs declared

inoperable. On January 4, at 6:43 p.m. , DG No. 3 was declared

inoperable for a slow start slightly greater than the TS requirement

of 10 seconds. Per TS Action statement 3.8.1.1.b.2, the licensee is

required to demonstrate operability of the remaining diesel genera-

tors by performing TS surveillance requirements 4.8.1.1.2.a.4 and .5.

These surveillance tests require the verification that the diesel

starts, and accelerates to at lesst 514 RPM in less than or equal to

10 seconds, and that the generator is synchronized, loaded to greater

than or equal to 1750 KW, and operates for greater than or equal to

15 minutes. On January 5, at 3:52 p.m. , DG No. I was declared

inoperable for a trip reportedly during paralleling with no alarms,

making two DGs inoperable. Once two DGs are inoperable, TS ACTION

statement 3.8.1.1.e.1 requires the above surveillance requirements to

be completed within cwo hours. Based on a review of PT-12.8, which

implements the above surveillance, the last surveillance was not

completed until 6:00 p.m., eight minute beyond the allowed time. The

8 minute late surveillance by itself has minimal safety significance.

However, the shift foreman had failed to recognize the two hour

requirement for the surveillance test; thus being late only 8 minutes

was fortuitous.

Both DGs 2 and 4 had their surveillance tests completed satisfac-

torily. A lug and a relay were replaced and OG No. I was run

satisfactorily and returned to service on January 5 at 9:15 p.m. DG

No. 3 was returned to service on January 6 at 5: 17 p.m. , after the

I licensee discovered they were misinterpreting the start data.

Failure to perform TS surveillance requirement 4.8.1.1.2.a.5 within 2

hours as called for in TS Action statement 3.8.1.1.e.1, with 2 DGs

declared inoperable is a Violation: Failure to Perform DG Surveill-

ance Within TS Time Limits (325/88-01-01 and 324/88-01-01).

b. On January 6, the inspector found a paper towel wedged between the

stack radiation monitor sample pump motor and a nearby support. The

paper towel kept the motor from vibrating. No trouble ticket had

been issued on the problem at that time. The licensee wrote a

trouble ticket (88-AAMRI) af ter being informed of the problem. The

licensee found that one of the motor mount bolts was missing but that

no operability concern existed. The pump supplies stack ef fluent to

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the accident monitoring instrumentation (TS 3.3.5.3) ventilation high

! range noble gas monitors and the various radioactive gaseous effluent

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monitoring instrumentation (TS 3.3.5.9). FSAR section 3.2.1,2 states

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that part of the Radiation Monitoring System is seismic class I. The

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system engineer reported that the isokinetic probe, which supplies

i the sample to the pump, and stack sample house, which houses the

l pump, had no seismic requirements per plant modification 80-036. The

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licensee agreed in the exit to inform the inspector what portions of

the RMS are seismic class I per the FSAR. This is an Unresolved

Item: Seismic Requirements for Radiation Monitoring System

(325/88-01-02 and 324/88-01-02).

The licensee agreed with the inspector that the "paper towel"

solution vice writing a work request. was inappropriate. They would

take corrective action without waiting for resolution of the. seismic

question.

No significant safety matters, one violation, and no deviations were

identified.

5. Surveillance Observation (61726)

The inspectors observed surveillance testing required by Technical

Specifications. Through observation, interviews, and record review, the

inspectors verified that: tests conformed to Technical Specification

requirements; administrative controls were followed; personnel were

qualified; instrumentation was calibrated; and data was accurate and

complete. The inspectors independently verified selected test results and

proper return to service of equipment.

The inspectors witnessed / reviewed portions of the following test activi-

ties:

IMST-LKDET21R Leak Detection Containment Sump Flow Integrating

System

Channel Calibration.

2MST-DG13R DG 3 Trip Bypass Test.

l 01-3.2 Control Operator Daily Surveillance.

01-3.3 Outside Auxiliary Operator Daily Surveillance Report,

Completed January 29, 1988.

PT-12.6 Breaker Alignment Surveillance.

No significant safety matters, violations, or deviations were identified.

6. Operational Safety Verification (71707)

The inspectors verified that Unit 1 and Unit 2 were operated in compliance

with Technical Specifications and other regulatory requirements by direct

observations of activities, facility tours, discussions with personnel,

! reviewing of records and independent verification of safety system status.

The inspectors verified that control room manning requirements of 10 CFR

50.54 and the Technical Specifications were met. Control operator, shift

supervisor, clearance, STA, daily and standing instructions, and jumper /

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bypass logs were reviewed to obtain information concerning operating

trends and out of service safety systems to ensure that there were no

conflicts with Technical Specifications Limiting Conditions for Opera-

tions. Direct observations were conducted of control room panels, instru-

mentation and recorder traces important to safety to verify operability

and that operating parameters were within Technical Specification limits.

The inspectors observed shift turnovers to ' verify that continuity of

system status was maintained. The inspectors verified the status of

selected control room annunciators.

. Operability of a selected Engineered Safety Feature division was verified

weekly by insuring that: each accessible valve in the flow path was in

its correct position; each power supply and breaker was closed for

components that must activate upon initiation signcl; the RHR subsystem

cross-tie

valve for each unit was closed with the power removed from the valve

operator; there was no leakage of major components; there was proper

lubrication and cooling water available; and a condition did not exist

which might prevent fulfillment of the system's functional requirements.

Instrumentation essential to system actuation or performance was verified

operable by observing on-scale indication and prnper instrument valve

lineup, if accessible.

The inspectors verified that the licensee's health physics policies /

procedures were followed. This included observation of HP practices and a

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review of area surveys, radiation work permits, posting, and instrument

I calibration.

The inspectors verified that: the security organization was properly

manned and security personnel were capable of performing their assigned

, functions; persons and packages were checked prior to entry into the

l protected area; vehicles were properly authorized, searched and escorted

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within the PA; persons within the PA displayed photo identification

badges; personnel in vital areas were authorized; and ef fective compen-

satory measures were employed when required.

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position of certain containment isolation valves, checked a clearance, and

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verified the operability of onsite and offsite emergency power sources.

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No significant safety matters, violations, or deviations were identified.

l 7. Preparation for Refueling on Unit 2 (60705)

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l The inspector reviewed the Fuel Handling Procedure FH-11, concentrating on

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completion of prerequisites required prior to defueling. Two minor

administrative errors were noted:

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o Step 3.3 contained an initial for completion and a comment to refer

to "Note 1" but no Note 1 was recorded. Step 3.3 requires completion

of PT-18.1, Refueling Interlocks check, and PT-18.2, Service Platform

check. PT-18.1 had been completed but PT-18.2 was not required to be

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completed since no usage of the platform is planned this outage.

Af ter the inspector questioned the absence of a "Note 1", it was

added. to the procedure and adequately explained the above circum-

stances,

o Step 3.10 requires completion of Appendix B, System Electrical Lineup

Checklist. This step was initialled as completed on Step 3.10 but

the actual appendix had no approval, signature or time started /

finished recorded. Thia was promptly corrected when pointed out by

the inspector. The inspector verifieo that Appendix B had actually

been completed.

FH-11 also contains a step which requires the operators to ensure only

appropriately qualified personnel operate the refueling bridge. The

inspector questioned a senior control operator in the control room on how

this requirement was satisfied. The operator was not sure how this step -

was completed. The licensee stated and the inspector verified that

qualification cards were completed and maintained on each qualified

operator. A list of these qualified refueling bridge operators was

normally maintained in the SOS office but had not been placed there this

refueling outage. This situation was corrected by obtaining the list.

The qualification cards were filed in the same folder as FM-11 for easy

accessibility to control room operators.

The inspector reviewed GP-07, Preparations for Core Alterations, Revision '

10, and observed defueling operations.

No significant safety matters, violations, or deviations were identified.

8. Fellowup on Inspector Identified and Unresolved Items (92701)

. a. (CLOSED) Unresolved Item (325/87-42-04), Thermometer in Unit 1

Standby Liquid Control Tank.

As described in the subject report, a thermometer was discovered .

inside the SLC tank. Inspection Report 50-325/86-12 and 50-324/86-13

discussed a similar situation in which the resident inspector in May,

1986 f( Jnd a small piece of Opaque plastic wrap floating in the tank.

As a result of that occurrence the licensee revised procedure No.

1130, Monthly Determination of Sodium Pentaborate Solution in the SLC

Tank, to include a step (7.4) which requires a tank inspection after

samples are obtained. The tank hatch has a permanent caution tag

attached to it with directions to contact the shift foreman prior to

opening the hatch. The procedure also requires independent verifi-

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cation of hatch closure. While performing step 7.4 of E&RC No. 1130

on December 23, 1987, the E&RC technician observed the thermometer on

the bottom of the tank. The thermometer was removed from the tank.

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The licensee's investigation of the incident was unable to determine

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how the thermometer got into the tank. No procedures now or recently

in use require such thermometers to be used in the SLC tank. The

licensee concluded the thermometer has -been in the tank for an

extended time and remained undiscovered until now.

The inspector reviewed drawings of the tank to obtain arrangement and

dimensional information on the tanks sparger piping, ' structural

support members, and the location of the outlet (to suction of SLC

pumps) of the tank. The inspector then conducted a visual examina-

tion of the tank. Although the water clarity was good and the bottom

of the tank was visible, the sparger piping and structural supports

inside the tank could cause the thermometer to remain undiscovered

despite monthly inspections of the tank. The inspector did not

observe any foreign objects in the tank and verified the outlet was

free of debris. Based on the location where the thermometer was

found, the arrangement of the sparger piping with respect to the

outlet location, and the low velocities expected in the tank, the

inspector concluded that blockage of the tank outlet by the thermo-

meter was unlikely. The inspector ' did bring to the licensee's

attention that apparently the sparger air supply isolation valve was

leaking, allowing some air flow through the sparger piping into the

tank, reducing visibility. The licensee has lockwired shut the hatch

on the tank. Based on the above information, action to prevent

material entering the tank in the future appears adequate and the

probability that the thermometer could have adversely affected the

operability of the SLC system appears very small.

b. (CLOSED) Inspector Followup Item (325/87-17-02 and 324/87-17-02),

01-41, Operator Aids Discrepancies. ,

The inspector verified, through document review, that the licensee

performed the revised sudit of operator aids and verified that no

"Information Only" copies of procedures were maintained in logbooks.

The inspector also reviewed the latest revision of 01-29, Operations

Internal Audits, Rev. 13, January 27, 1988. The procedure now

contains additional controls to ensure audit completion.

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c. (OPEN) Inspector Followup Item (325/87-42-09 and 324/87-43-09), DG

Building Supply Fan "A" Failure.

The licensee will complete the metallurgical analysis of the fan

blade by February 12, 1988. The liquid penetrant tests on the B&C

, fan blades will be completed by May 10, 1988. The inspector reviewed

the NDE report for a liquid penetrant test conducted on a "D" supply

fan that the system's engineer reported had been in service for about

8 years. No indications of cracks were found. Based on the exam

results, the inspector concluded that the licensee's schedule of

future inspections and evaluations was appropriate. This item

remains open pending the completion of the licensee inspections and

evaluation.

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No significant safety matters, violations, or deviations were identified.

9. Onsite Followup of Events on. Units 2 (93702)

The inspector reported to the site on January 3,1988, to followup on a

manual scram and failures of the drywell equipment and floor drain contain-

ment isolation valves. The inspector conducted the initial event assess-

ment, forwarding the information to regional management. Based on the

information supplied by the inspector, NRC sent an AIT to followup on the

event. The results of the AIT are documented in report nos. 325/88-03 and

324/88-03. Conclusions are contained in the AIT report.

13. Inadvertent Heatup of Unit 1 (93702)

The unit operator inadvertently allowed the reactor coolant system to

heatup to about 210 degrees F. The unit had been in cold shutdown prior

to the event, maintaining RCS temperature at 120 degrees F using the

Division II RHR system in shutdown cooling and running the "D" RHR pump.

The operator had been maintaining temperature by throttling the 18 RHR

heat exchanger outlet valve, 1-E11-F0038. Based on temperature recorder

-traces, the F003B valve was shut about 2:45 a.m., on January 26, 1988. At

4:30 a.m., the operator discovered the F003B valve shut and immediately

cpened the F005B valve and shut the heat exchanger bypass valve,

1-E11-F348B, commencing a cooldown. The operators reported no indications

of boiling in the RCS. This is confirmed by recorder traces observed by

the inspector.

The licensee instituted a review of the event and put short term correc-

tive actions in place shortly af ter the event. The operators are now

required to record RHR heat exchanger temperatures every half hour.

Operators wera instructed on the event prior to assuming the shift. Since

the operator had caught his own error, reported it to management, and

corrective action has been aggressive so far, enforcement action

! consideration will be

deferred until af ter the licensee's review (0ER) has been completed. The

licensee, during the exit, committed to complete the OER by February 29,

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1988. This matter remains Unresolved pending inspector review of the OER:

Inadvertent Heatup During Cold Shutdown (325/88-01-03).

I A significant personnel error occurred which will be reviewed during

future inspections; no violations or deviations were identified.

11. Plant Modifications (37700)

The inspectors reviewed plant modifications to verify compliance with

10CFR50.59, Technical Specifications, and ENP-03, Plant Modification

Procedure, Revision 35. The inspectors verified, through record reviews,

interviews and observation of work and equipment, that the licensee

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performed plant modification work satisfactorily. Specifically, the

. inspector verified chat;

o The modifications were reviewed and approved in accordance with

10CFR50.59.

o QA/QC signoffs were appropriate and completed as necessary.

o Work was contrclied by approved procedures and drawings.

o Appropriate procedure and drawing revisions were identified,

o Procedures were in place to include modification in annual 50.59(b).

The inspector reviewed PM-84-004, Addition of Accumulators for Safety

Relief Valves 2-821-F0138, E & G, using the above criteria. Observation

of work activities was also performed for:

PM-84-084 Provide Alternate Feed for 2-821-F016 and Local Control for

2-B21-F019.

PM-84-042 Enhance Control for 2-E51-F013, 2-E51-F019, and Vacuum and

Condensate Pumps.

No significant safety matters, violations, or deviations were identified.

12. List of Abbreviations for Unit 1 and 2

AI Administrative Instruction

4 AIT Augmented Inspection Team -

A0 Auxiliary Operator

ARD- Anti-Rotation Device

BSEP Brunswick Steam Electric Plant

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CST Condensate Storage Tank

l DG Diesel Generator

l E&RC Environmental & Radiation Control

ENP Engineering Procedure

ERFIS Emergency Response Facility Information System

ESF Engineered Safety Feature

F Degrees Fahrenheit

FSAR Final Safety Analysis Report

GE General Electric

GP General Procedure

HP Health Physics

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HPCI High Pressure Coolant Injection

l HVAC Heating, Ventilating, Air Conditioning System

' HX Heat Exchanger

I&C Instrumentation and Centrol

IE NRC Inspection and Enforcement

IFI Inspector Followup Item

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ILRT Integrated Leak Rate Test

IPBS Integrated Planning Budget System

J0 Job Order

KW Kilowatt

LER Licensee Event Repcrt

MI Maintenance Instruction

MCC Motor Control Center

NDE Non-Destructive Examination

NRC Nuclear Regulatory Commission

OER Operating Experience Report

01 Operating Instruction

OP Operating Procedure

PA Protected Av. -

PM Procedure M 'ication

PRA Probabilist.. Risk Assessment

PT Periodic Test

PNSC Plant Nuclear Safety Comreittee

0A Quality Assurance

QC Quality Control

RHR Residual Heat Pemoval

RCIC Reactor Core Isolation Cooling

RCS Reactor Coolant System

RMS Radiation Monitoring System

RPM Revolutions Per Minute

RWCU Reactor Water Cleanup

SLC Standby Liquid Control-

SOS Shift Operating Supervi:or

SP Special Procedure

SW Service Water

TS Technical Specification

URI Unresolved Item

WR Work Request h

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ML20148E859

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