ML20151T879
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| ML20151T879 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/30/1986 |
| From: | Fredrickson P, Garner L, Ruland W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20151T840 | List: |
| References | |
| 50-324-85-40, 50-325-85-40, IEB-80-11, NUDOCS 8602100382 | |
| Download: ML20151T879 (8) | |
See also: IR 05000324/1985040
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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Report Nos.: 501325/85-40 and 50-324/85-40
Licensee: . Carolina Power and Light Company
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.P. O. Box 1551
Raleigh, NC 27602
L Docket'Nos.: 50-325 and 50-324 License'Nos.: DPR-71 and DPR-62
Facility Name: _ Brunswick-1 and 2
Inspection Conducted: December 1-31, 1985
Inspectors:I,I. %b[cw / SOk6
Date Signed
35ct f. H. Ruland
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Date Signed
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Fred *fcison, Section Chief f) ate 'S'i gned
Division of. Reactor Projects
i' SUMMARY
: Scope: This routine, safety inspection involved 107 inspector-hours on site .in
the areas of maintenance _ observation, surveillance observation, operational
safety verification, Engineered Safeguard Feature (ESF) System walkdown, onsite
. Licensee Event ' Reports (LERs)' review, cold weather preparations, plant
modifications, and followup on IEB 80-11 (Masonry Wall Design).
Results: .Two viol'ations were' / identified: Two examples of Failure to Take
A'dequate . Corrective Action, paragraphs 6 and 9; two examples of Failure to
ConductJActivities According ol Approved Procedures and Drawings, paragraph 9.
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REPORT DETAILS
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1. Persons Contacted
Licensee Employees
P. Howe, Vice President - Brunswick Nuclear Project
C. Dietz, General Manager - Brunswick Nuclear Project.
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-T. Wyllie, Manager --Engineering and Construction
E. Bishop, Manager - Operations
L. Jones, Director - QA/QC-
J. Moyer, Director - Training
M. Jones, Acting Director - Onsite Nuclear Safety - BSEP
'J. Chase, Assistant to. General Manager
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J. O'Sullivan, Manager - Maintenance
G. Cheatham, Manager - Environmental & Radiation Control
K. Enzor, Director - Regulatory Compliance
B. Hinkley, Manager - Technical Support
C. Blackmon, Superintendent - Operations
J. Wilcox, Principal Engineer - Operations
W. Hogle, Engineering Supervisor
W. Tucker, Engineering Supervisor
B. Wilson, Engineering Supervisor
R. Creech, I&C/ Electrical Maintenance Supervisor (Unit 2)
R. Warden, I&C/ Electrical Maintenance Supervisor (Unit 1)
,W. Hatcher, Supervisor - Security
R. -Kitchen, Mechanical Maintenance Supervisor (Unit 2)
R. Poulk, Senior NRC . Regulatory Specialist .
D. Novotny, Senior Regulatory Specialist
W. Murray, Senior Engineer - Nuclear Licensing Unit
Other licensee employees contacted included construction craftsmen,
engineers, technicians, operators, office personnel, and security force
members.
2. Exit Interview (30703)
The inspection scope and findings were summarized on January 6,1986,' with
the assistant to the general manager and the vice president. The following
-issues were discussed in detail: failure to correct a ground on Unit 1
250 V DC Battery. Bus A (paragraph 6); removal of heat tracing for Unit 1
Condensate Storage' Tank (CST) level switches (paragraph 9); use of an
uncontrolled procedure to check certain freeze protection circuits (para-
graph 9); and insufficient thread engagement for mounting fasteners 'for a
. CST level switch (paragraph 9).
The licensee acknowledged the inspection findings and took no exceptions.
Regarding the use of'an uncontrolled procedure, the licensee stated that the
operations group would review Administrative Operating Instructions (AOIs)
t to insure- that no safety-related activities were being controlled by the
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AOI. The licensee did not' identify during the inspection any materials
-provided or reviewed by the inspector as proprietary.
3. Followup on Previous Enforcement Matters (92702)
Not inspected.
4. Maintenance Observation (62703)
The inspectors observed maintenance activities 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 (QC) hold points were
adequate and observed; adequate post-maintenance testing was performed; and
independent verification requirements were implemented. The inspectors
independently verified that ' selected equipment was properly returned to
service.
Outstanding work requests and authorizations (WR&A) were reviewed to ensure
that the licensee gave priority to safety-related maintenance.
The inspectors observed / reviewed . portions of the following maintenance
activities:
-' Diesel Generator lube oil pressure switch problems.
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MI-10-2AB, Electrical Equipment Cabin'ets, Inspection and Cleaning,
Rev. 5.
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SP-85-112, Installation and Operation of a' Jet Pump Nozzle Plug Vent
System, Rev. 1.
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Scram solenoid pilot valve Environmental Qualification (EQ) upgrade per
.WR&A 85-AHQR1,85-AHQS1 and MI-10-4C, Control Rod Drive (CRD) Solenoid
Operated Scram Pilot Valve, Core, Diaphragm, and Gasket Replacement,
Rev. 10.
No violations or deviations were identified.
5. Surveillance Observation (61726)
The inspectors observed surveillance testing required by Technical Specifi-
cations. Through observation and record review, the inspectors verified
that: tests conformed to Technical Specification requirements;
administrative controls were followed; personnel were qualified; instru-
mentation was calibrated; and data was accurate and complete. The
inspectors independently verified selected test results and proper return to
service of equipment.
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The inspectors-witnessed / reviewed portions of the following test activities:
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PT-17-3P, Plant Batteries, Rev. 17.
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-PT-12.2A, Diesel _ Generator 1 Monthly Load Test, Rev. 22.
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Units 1 and 2 Daily Surveillance Record.
During a review .of .the daily surveillance record on December 19, 1985, the
inspector noticed that the steps requiring a channel check referenced steps
that did not have four channels of the same parameter. Two items related to
the Automatic Depressurization System (ADS) had been added, but the channel
check. steps had not been changed. All channel checks had been recorded such
that it appeared that the checks were done correctly. The licensee plans to
re-number the channel check steps to correct the problem.
No violations or deviations'were identified.
6'. Operational Safety Verification (71707)
The inspectors verified conformance with 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 room, shift
supervisor, clearance and jumper / bypass logs were reviewed to obtain
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information concerning operating trends and out of service safety systems to
ensure that there were no conflicts with Technical Specifications' Limiting
Conditions for Operations. Direct observations were conducted of control
room panels, instrumentation and recorder traces important . to safety to
verify operability and that 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 ESF train was verified by insuring that: each
accessible ' valve in the flew path was in its correct position; each power
supply .and breaker, including control room fuses, were aligned for
-components that must activate upon initiation signal; removal of power from
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those ESF motor-operated valves, so identified by Technical Specifications,-
was completed;' there was no leakage of major components; there was proper
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. 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 proper instrument valve
lineup, if accessible.
The . inspectors verified that the licensee's health physics policies /
procedures were followed. This included a review of area surveys, radiation
work permits, posting, and instrument calibration.
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- The inspectors verified that: the secur.ity organization was pr aerly manned
and that. ' security personnel were capable of performing the', assigned
functions; persons and packages were checked prior. to entry into -the
, protected area (PA); vehicles were properly ' authorized, searched and-
escorted within the PA; personnel in vital areas were authorized; effective
compensatory measures were employed when required.
. The inspectors observed that during the start of cold weather, an occasional
licensee employee, mostly craft, were wearing coats that covered their photo
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badges. ' The inspector notified plant security. Since then, improvement in
proper wearing of the photo badges has.been noticed.
The inspectors also observed plant housekeeping controls, verified position
of certain containment isolation valves, checked a clearance, and verified
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the operability.of onsite and offsite emergency power sources.
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The inspectors found.that a "250 V Battery Bus A Ground" Unit I annunciator
had been disabled for almost a year without a ground identified. The
inspectors reviewed the licensee's computer generated disabled annunciator
list. 'The licensee listed each disabled annunciator with certain supporting
data. Annunciator 1-UA-23 3-7, 250 V Battery Bus A Ground, was disabled on
January 1, 1985. The pulled annunciator card was documented pulled in the
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jumper log as Jumper 1-85-0001. A WR&A, 1-E-84-6349, had been issued to
- work the problem but was voided. No new WR&A had been issued at the time of
the inspection. Unit 1 Annunciator' Panel Procedure (APP) UA-23, Rev. 3, pg.
46, required the licensee to determine the location of the ground (Bus P, N
or NP) and perform the DC ground isolation procedure per OP-51, DC
Electrical System. The procedure contained a caution that the shift foreman
should determine if the plant is in a condition to allow opening of each
4 individual feeder breaker for DC ground isolation. Unit 1 performed an
extensive outage after the alarm was disabled. The licensee could not
provide to the inspector any record of performance of OP-51 to identify the
ground. Not correcting the ground problem on a safety-related DC bus is a
i failure to take prompt corrective action to correct a condition adverse to
quality as per the licensee's-accepted QA program (FSAR chapter 17.2.16)
and, collectively, with another example in paragraph 9, is identified as a
violation (325/85-40-01).
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One violation was identified.
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7 '. 'ESF System Walkdown (71710)
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The inspectors completed a comparison of the High Pressure Coolant Injection
(HPCI) System piping and instrumentation diagrams, D-25023 and D-2523 with
the system operating procedure, OP-19. The inspector noted that Unit 1
OP-19, Revision 5, page 35 of attachment 1, required that valve E41-V99,
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HPCI keepfill station inlet isolation valve, was required to be locked open.
Drawing D-25023 showed V99 as a locked closed valve. The licensee plans to
submit a drawing ' change to show V99 as a locked open valve. The drawing .
discrepancy also existed:in Unit 2.
No violations or deviations were identified.
8. 'Onsite Review of Licensee Event Reports (92700)
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The listed LERs were reviewed to verify that the information provided met
NRC reporting requirements. The verification included adequacy of event
description and corrective action taken o_r planned, existence of potential
generic problems and the relative safety significance of the event. Onsite
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inspections were performed and concluded that necessary corrective actions
have- been taken in accordance with existing requirements, licensee
conditions and commitments. The following reports are considered closed:
Unit I
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!- 82-74, High Battery Electrolyte Level.
83-21,. Reactor-Turbine Gauge Board Rod Position Indication Problems.
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' 85-62, Auto Start of Control Building Emergency Air Filtration (CBEAF)
System Train 2A.
85-64, Automatic Isolation of CBEAF System from C1 Alarm.
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No violations'or deviations were identifie'd.
9. . Cold Weather Preparations (71714)
The inspectors reviewed procedures, examined hardware, and reviewed the
licensee's response to IE Bulletin 79-24 to determine if the licensee has
maintained an effective program to protect safety-related equipment from
extreme cold weather.
The inspectors found certain conditions that violated NRC requirements.
Heat. tracing installed around the Unit 1 CST low level switches for the HPCI
suction transfer had been removed, eliminating corrective action for a
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freezing problem with the switches identified in January 1985. An
uncontrolled, unreviewed procedure was used by the- operations group as a
cold weather bill to check freeze protection cir.uits. Also, during the
equipment .walkdown, the inspectors found that the fasteners attaching a
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seismic category 1 level switch to its support had inadequate ' thread
engagement.
The inspectors found disconnected heat tracing wire wrapped around the
- Unit- 1. level switches 1-E41-LSL-N002 and N003. The wire around N002 was
installed :on January 23, 1985 under WR&A 1-E-85-579. Level switch N002,
4 along with Reactor Core Isolation Cooling level switches 1-E51-LSL-4463 and
4464, failed. to actuate during cold weather while . performing routine
Technical Specification surveillance (PT-3.1.2PC). The heat tracing was
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disconnected. on October 28, 1985, (WR&A 1-E-85-4980), because the heat
tracing was not in accordance with drawings. The heat tracing was found on
the level switches by maintenance personnel during performance 'of a pre-cold
weather (WR&A 1-E-85-4478) inspection of heat tracing. The permanent fix
for the freezing problem was to be implemented under WR&A 1-E-85-607, and-
Engineering Work Request (EWR) 2240. WR&A 607 recognized that the hea+
tracing on N002, N003, 4463, and 4464 was temporary and referenced final
solution to EWR 2248. The EWR was not approved for work at the time of the
inspection.
10 CFR 50, Appendix' B, Criterion XVI, Corrective Action, as implemented by
the licensee's accepted QA program (FSAR chapter 17.2.16), requires that
conditions adverse to quality be corrected. A condition adverse to quality
was not corrected in that a freeze protection solution to a previous adverse
condition, potential freezing of saftey-related level switches
1-E41-LSL-N002 and N003, was removed and no deliberate corrective action was
substituted. This failure to take corrective action, collectively with
another example in paragraph 6, is identified as a violation (325/85-40-01).
The inspectors found that' an uncontrolled, unreviewed procedure, AOI-28,
Cold Weatner Bill Action Items, was used by the licensee to check all freeze
protection circuits. Step B.1 of AOI-28, required the licensee to " check
all freeze protection circuits energized and operating as per OP-53." OP-53
was .a deleted procedure at the time of the inspection. Also, FP-26 was
referenced in A01-28; however, it had been deleted and was replaced by
FPP-024. The freeze protection circuits that protect the CST level switches
and associated piping prevent a condition adverse.to quality, freezing, from
affecting the safety-related function of the switches, and as such fall
under Appendix B of 10 CFR 50.
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings,
as implemented by the licensee's accepted QA program (FSAR chapter 17.2.5),
requires that activities affecting quality be conducted according to
procedures that have the following elements: prerequisites, precautions,
acceptance criteria, and check lists. Inspection was performed on the
freeze protection equipment associated with the CST level switches using
A0I-28, which did not contain the required elements. This is one of two
examples of a procedural violation (325,324/85-40-02).
During the cold weather protection walkdown .the inspectors found that three
of four bolts that attached level switch 2-E41-LSL-N003 to its support were
not engaged properly. Drawing 9527-L-2260, Unit 2, sheet 2 of 2, from Plant
Modification PM-83-190, revision 5, required, in note 1, the licensee
furnish new and longer bolts and/or studs if required. Specification.No.
248-107, Section XXIV, Thread Engagement, states that full thread engagement
is defined as being flush with the face of the nut.
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings,
as implemented by Brunswick FSAR Section 17.2.5, requires that activities
affecting quality be accomplished in accordance with instructions and
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i !' I drawings. Activities were not conducted in accordance with drawings in
that,- although drawing 9527-L-2260, sheet 2 of 2, required that new and
longer bolts be used as necessary to fasten the N003 switch to its support,
bol.ts of sufficient length were not used. This is the second example of a
' procedural violation (325,324/85-40-02).
One violation and a second. example of the violation in paragraph 6 was
identified.
'10 . Plant Modifications (37700)
- The inspectors observed work activities and reviewed documentation
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associated with one plant modification. The inspectors verified that the
modification was reviewed and approved as required and that installation was
in accordance with approved procedures and drawings. The plant modification
reviewed was PM 82-288I, RIP Valve Modification Relay Replacement.
No violations or deviations were identified.
11. Followup IE Bulletin 80-11, Masonry Wall Design (92703)
The inspector reviewed the licensee's method for ensuring that recent
modifications .or future modifications would not result in placing
safety-related equipment near an unanalyzed masonry wall. The method
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- utilized involved noting a the structural drawings which walls were
( non-safety related and a caWon note about re evaluation if safety-related
equipment -is to be installd near a masonry wall. However, since some-
activities such as routing of conduit does not usually involve use of the~
structural wall drawings, a problem could develop. The licensee has revised
structural design gt.ide SDG-2, Design of Pipe Supports, and SDG-5, Design of
Seismic Class 1 Safety-Related Conduit Supports, to assign the support
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engineer the responsibility to check the structural general arrangement
drawings and to notify the proper personnel when items to be supported have
been located within the area of influence of non safety-related walls.
Furthermore, engineering personnel also performed field walkdowns of non
safety-related masonry walls to verify that no adverse condition had been
- created since the original reviews and walkdown. No problems were
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L The inspector. believes that the licensee's actions are sufficient to prevent i a problem in this area and exceeded the requirements of the bulletin. This ! bulletin was last inspected during report 81-22 and remains open for both
units (325,324/80-BU-11).
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No violations or deviations were identified. L _ _ -
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