ML20154S392

Forwards Supplemental Response to Util 880824 Response to Notice of Violation & Proposed Imposition of Civil Penalty. Corrective actions:real-time Training Package on Reactor Mode Switch Change Event Developed & Training Conducted

ML20154S392
Person / Time
Site:	Brunswick
Issue date:	09/26/1988
From:	Mcduffie M CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE)
References
EA-88-131, NLS-88-238, NUDOCS 8810050060
Download: ML20154S392 (11)

Text

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SEP 26 1988 M. A. McDUFFIE son 6ot Oce Preeksent Nodear Generation SERIAL: NLS 88-238 Director, Office of Enforcement United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSVICK STEAM ELECTRIC PIANT, UNIT NOS.1 AND 2 DOCKET h0S, 50 325 6 50 324/ LICENSE NOS. DPR 71 & DPR-62 SUPP;JMENTAL REPLY TO NOTICE OF VIOLATION EA 88 131 Centlemen:

The NRC issued a nctice of violation and proposed imposition of civil -

, penalty for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2 on ,

July 25, 1988. Pursuant to 10CFR2.201, Carolina Power & Light Company  !

(CP&L) provided a response on August 24,1988 (SERIAL. NLS 88 206) . '

Carolina Power & Light Company hereby submits a supplement to respond to additional concerns identified in conversations between Brunswick Plant i

! management and Region II staff. This response supercedes the Company's submittal dated August 24, 1988.

Carolina Power & Light Company agrees that the violations, when viewod together, identify an issue of critical importance to the safe operation of the Brunswick Plant and meet the criteria for imposition of a civil penalty. Positivo actions have been initiated to provide more dynamic control of operational activities to prevent events, as noted, from occurring in the future. These include: (

The position of Operations Superintendent is being deleted, '

eliminating a level of suparvision between the operating shifts  ;

and management. This streamlining will allow more direct contact .

between the operating shifts and the Manager Operations, enhancing the day to day management. This action will be completed by October 15, 1988.

The position of Manager Operations has been filled by a person with extensive operations experience at Brunswick. This action is complete.

Additional log keeping requirements are being initiated in an effort of ensure the operators are more readily aware of plant conditions. This action will be completed by October 15, 1988.

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Documsnt Control Desk NLS-88 238 / Page 2 The office of the Manager -Operations is being moved to close proximity to the main control room, thus allowing better and nore frequent observation of the conduct of operations. This action will be completed by October 15, 1988.

The Plant General Manager and the Department Manager- Brunswick Nuclear Project are scheduled to meet with each shift to discurs their philosophy on plant operation and its affect on plant safety. These sessions are scheduled to be completed by December 16, 1988. The Company anticipates that these sessions will be conducted on a periodic basis in the future.

Carolina Power & Light Company also appreciates that it needs to assure that the failure to observe trends or conditions that are potentially adverse is not a plant wide attitude. Accordingly, the Plant General Manager has initiated continuing meetings with all levels of plant supervision to assess attitudes and emphasize the need to maintain a constant awareness toward performance.

This action has been implemented.

The Company does not agree that escalation of the civil penalty for an event lacking serious safety significance is justified, simply because the event has been collectively incorporated with two other events. The three events were collectively categorized as Severity Level III in accordance with Supplement I of 10CFR2, Appendix C. It is the prerogative of the NRC to combine events, activities, and/or violations together if circumstances or conditions so warrant. Combination of such events allows the overall safety significance of similar issues to be put into proper perspective. However, once these events have been combined to represent a more significant concern, they lose their unique identity. Thus, considerations for escalation of the penalty must be evaluated against the violation as a whole (i.e., the combination of the three violations) since that is what provides the justification for the bare civil penalty.

As stated in the Notice of Violation, the three violations cited individually do not have serious safety significance and, therefore, if cited individually, would not warrant a civil penalty. Considerations for escalation were based solely on Violation B, not on the violation as a whole. Thus, the Company believes that the escalation of the civil penalty under 10CFR2, Appendix C, item V.B.3 (Past Performance) is inappropriate. A check in the amount of $50,000.00 for payment of the proposed civil penalty was enclosed with our response of August 24, 1988.

Document Control Dask NLS-88 238 / Page 3 Each of the violations is addressed in Enclosures 1, 2, and 3, respectively. Each response includes (1) an admission or denial of the violation, (2) the reason for the violation, (3) corrective actions which have been taken, (4) future corrective actions, and (5) the date by which compliance will be achieved. Please refer any questions regarding this submittal to Mr. Stephen D. Floyd at (919) 836 6901.

Yours very truly,

}l $ D yf' M. A. McDuffic RMP/WRM/wrm(\cor\vresp)

Enclosures cc: Dr. J. Nelson Grace Mr. W. H. Ruland Mr. B. C. Buckley M. A. McDuffie, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power &

Ligt Company.

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ENCLOSURE 1 RESPONSE TO VIOLATION A Descriotion of Violation The NRC's Notice of Violation states the following:

"Technical Specification (TS) 3.0.4 states that entry into an OPERATIONAL CONDITION or other specified applicability state shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements unless otherwise excepted.

"TS 3.5.3.2 requires in OPERATIONAL CONDITIONS 1, 2, and 3 that two independent low pressure coolant injection (LPCI) subsystems of the residual heat removal (RHR) system be OPERABLE with each subsystem comprised of two pumps and an OPERABLE flow path capable of taking suction from the suppression pool and transferring the water to the reactor pressure vessel."

"1S 3.6.1.1 requires in OPERATIONAL CONDITIONS 1, 2, and 3 that primary containment integrity be maintained."

"TS 3.6.1.3 requires in OPERATIONAL CONDITIONS 1, 2, and 3 that the primary containment air lock be OPERABLE with: (1) both doors closed except when the air lock is being used for normal transit entry and exit through the containment, then at least one air lock door shall be closed; and (2) an overall air lock leakage rate of less than or equal to 0.05L3 at P 3, 49 psig."

"Contrary to the above, at 4:35 a.m. on April 26, 1988, Unit 2 entered OPERATIONAL CONDITION 2 when the unit's mode switch was placed in the Startup/ Hot Standby position without RHR Division II being aligned for automatic LPCI initiation, without primary containment integrity being established, and with the primary containment air lock doors open."

Ensoonse to Violation _A I. Admission Or Denial Of The Violation Carolina Power & Light Company acknowledges the requirements of Technical Specifications 3.5.3.2, 3.6.1.1, and 3.6.1.3 were not met on April 26, 1988, when the unit entered OPERATIONAL CONDITION 2 for surveillance testing. This event was previously reported in Licensee Event Report 1 88 015.

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I II. Reason For Violation While preparing to perform a reactor start up on April 26, 1988, the reactor mode switch was placed in the Startup position at 1435 hours0.0166 days <br />0.399 hours <br />0.00237 weeks <br />5.460175e-4 months <br /> to perform the rod worth minimizer (RWM) system surveillance Periodic Test (PT) 01.6.2-2 and the rod sequence control system (RSCS) surveillance test PT 01.6.1. Following completion of these tests, the mode switch remained in the Startup position until the actual reactor start up was begun at  ;

approximately 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />. Section 1.0 of the Technical '

Specifications defines OPERATIONAL CONDITION as "...any one inclusive combination of mode switch position and average reactor '

coolant temperature as indicated in Table 1.2." Technical Specification 3.0.4 states:

"Entry into an OPERATIONAL CONDITION or other specified applicability shall not be made unless the conditions of the limiting condition for operation (LCO) are met without reliance on provisions contained in the action statements unless otherwise excepted. " ,

A mode change is initiated by either placing the mode switch to ,

another position or by changing the reactor coolant temperature.

In addition to this definition, the Technical Specifications provide specific conditions ar situations where the OPERATIONAL CONDITION is not defined by these two parameters exclusively. An example of this is found in Footnotes #, ##, and *** associated with Table 1.2 of the Technical Specifications. These footnotes include provisions allowing the reactor mode switch to be placed i in an otherwise unauthorized position to perform a specified ,

function while not changing operating modes. While one of these '

footnotes is being spplied, the operating mode remains the same as that established prior to movin5 the mode switch to the position allowed by the footnote.

The surveillance testing required by Technical Specifications 3/4.1.4.1 and 3/4.1.4.2 which relate to the RWM and the RSCS each have a Footnote

• associated with them which states:

"Entry into Condition 2 and withdrawal of selected control rods is permitted for the purpose of determining the operability of the RWM (RSCS) prior to withdrawal of control rods for the purpose of bringing the reactor to critically."

The operations staff believed that repositioning the mode switch for the performance of the RWM and RSCS surveillance tests was allowed by Footnote *. The difference in wording between the footnote associated with lechnical Specification Table 1.2,

. . . modo switch may be placed in the STARTUP/ HOT STANDBY (REFUEL) position...." and Techn! a1 Specifications 3/4.1.4.1 and 3/4.1.4.2, "Entry into Condition 2... " was not recognized.

This interpretation was found to be consistent within the El 2

Operation staff and had been in effect as long as anyone could remember. Moreover, even though the requirement to meet OPERATIONAL CONDITION 2 was not met, plant procedures and supervisory controls were in place to prevent control rod withdrawal for the purpose of bringing the reactor to criticality.

The operations staff believed that they were in OPERATIONAL CONDITION 4 and knew that shutdown cooling was in service per Technical Specification 3.5.3.2 and that the drywell was open for maintenance per Technical Specifications 3.6.1.1 and 3.6.1.3.

III. Corrective Actions Which Have Been Taken A Standing Instruction was issued on April 26, 1988 which identified the failure to properly position the mode switch and provided the requirements to ensure proper mode switch operation and OPERATIONAL CONDITION changes. A review was conducted of other Technical Specification notes to determine if similar problems existed. No problems were identified.

A real-time training package on the reactor mode switch change event wri developed and training conducted for operations personnel. In addition, procedure changes have been completed which provide controls of the mode switch /0PERATIONAL CONDITION changes during the reactor start up process.

IV. Corrective Actions To Be Taken No further actions are required as a result of this event.

V. Date When Full Compliance Will Be Achieved Carolina Power & Light Company is now in full compliance with the applicable requirements.

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ENCLOSURE 2 RESPONSE TO VIOLATION B Descriotion of Violation The NRC's Notice of Violation states as follows:

"Technical Specification 6.8.1.a requires that written procedures shall be implemented for applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972. Appendix A requires operating procedures for the RHR system. Operating Procedure, OP 17, RHR System Operating Procedure, Revision 76, implements this requirement and requires that the RHR heat exchanger outlet valve (E11 F003A) be either in the fully open or closed position during the shutdown cooling mode.

"Contrary to the above, OP 17 was not fully implemented on May 11, 1988 in that valve Ell F003A was used in a throttled position during the shutdown cooling mode on Unit 2."

Egiponse to Violation B I. Admire. ion Or Denial Of The Violation Carolina Power & Light Company acknowledges that OP 17 was not fully implemented in that the Ell-F003A valve was not in the open position as required by that procedure. It is noted that this event was identified by the licensee and that there was no safety significance to the event.

II. Reason For The Violation A root causo which led to the event is that operations personnel failed to recognize that throttling of the Ell F003A valve was not an evolution allowed by Operating Instruction (01) 01, paragraph 4.4, "Simple Evolutions."

An additional root causo which led to the event (inadvertent heatup) is believed to be an apparent design inadequacy within the shutdown cooling system. As noted below, during periods of low decay heat generation, the ability to throttle cooling systems (the Ell F003A valve) to match heat load does not exist.

Prior to the event, shutdown cooling had been established using the "A" loop of RHR. Due to the low decay heat load and the inability to throttle the E11 F003A valve by design (the valve logic allows only full open or full closed), coolant temperature was maintained by opening and closing the Ell F003A valve in accordance with OP 17. At approximately 1255 hours0.0145 days <br />0.349 hours <br />0.00208 weeks <br />4.775275e-4 months <br /> on E2 1

Hay 11, 1988, it was determined that the Ell-F0)3A valve could not be opened with the control switch. To allow maintenance personnel to troubleshoot and repair the problem, the valve needed to be de energized; however, this action would remove the ability to control the coolant temperature.

01-01 provides guidance to the operations personnel on evolutions that are considered "simple" and, therefore, do not require specific procedures for implementation. Exemples of such .'

evolutions are the changing of chart paper, venting a heat

' exchanger when the operator opens and closes the valves in a relatively short period, and blowing down an air receiver. The operations staff on duty at the time of this event believed that the manual throttling of the Ell F003A valve with the breaker de energized met "simple evolution" criteria. With the breaker de-energized, the valve would remain in the throttled position (maintaining coolant temperature ) until the repairs were completed, at which time, the breaker would be re energized and coolant temperature would again be controlled by OP 17, by opening and closing the Ell F003A valve.

During the troubleshooting and repair process, the Ell-F003A valve was inadvertently closed and not recognized by the operations staff. The method which should have been used to throttle the Ell-F003A valve was to initiate a temporary change to OP 17. This process would have required a safety analysis and increased the potential for estab'.ishing controls for insuring the position of the Ell F003A valve.

III. Corrective Actions Which Have Been Taken Training has been initiated for the operations staff by the Operations Manager concerning what constitutes a "simple evolution," which is defined as an evolution rot requiring a procedure. In addition, an evaluation has been completed which has determired that the Ell F003 valves should be replaced with valves which allow throttling.

IV. Corrective Actions To Be Completed And Completion Date Project Identification (PID) documentation has been initiated to modify the Ell F003 valves as noted in the evaluation. These valves are scheduled to be replaced in Refuel 8 for Unit 1 (scheduled in 1992) and Refuel 9 for Unit 2 (scheduled in 1991).

In addition, OP 17 will be revised by October 3, 1988, to provide procedural guidance on throttling the Ell F003 valves as required in the future. Any modification implemented in the future will be reflected in OP 17 through the plant modification process.

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i ENCLOSURE 3 RESPONSE TO VIOLATION C ,

1 Descrintion of Violation I The NRC's Notice of Violation states as follows:

"Technical Specification 3.3.1 requires, as a minimum, that the reactor protection system (RPG) instrumentation channels shown in Technical Specifications Table 3.3.1-1 be operable. Accordingly, notation "b" of Technical Specifications Table 3.3.1 1 requires that while in OPERATIONAL CONDITION 5, "shorting links" be removed from the RPS circuitry prior to and during the time any control rod is withdrawn.

"Contrary to the above, from 3:50 a.m. until 7:48 p.m. on March 8, 1988, with the reactor in OPERATIONAL CONDITION 5, Unit 2 control rod 10 39 was in the fully withdrawn position and the shorting links were not removed from the RPS circuitry."

} Resoonse to Violation C ,

I. Admission Or Denial Of Violation ,

I Carolina Power & Light Company acknowledges that control rod 10 39 was fully withdrawn with the shortinh links not removed. This '

event was ide.ntified by the licensee and reported in Licensee >

Evgnt Report 1-88 06. There was no safety significance involved ,

. with this o*ene since the plant is analyzed as safe with the  !

highest worth control rod withdrawn. In addition, the refueling interlocks would prevent withdrawal of additions 1 control rods.  ;

II. Reason For The Violation l The failure to insert control rod 10 39 prior to inserting the '

sharting links was due to personnel error by the licenced operator. Tho fa'.'iure to recognize that control rod 10 39 as boing withdrawn was impeded due to an inoperable position indication switch and a lack of training on a computer software change which displays control rod positions.

At 2025 hours0.0234 days <br />0.563 hours <br />0.00335 weeks <br />7.705125e-4 months <br /> on March 7, 1988, the shorting links were removed to permit performance of Periodic Test (PT) 14.1,"Control Rod Operability Check," and PT-14.1A, "Control Rod Coupling Chack and Control Rod Drive Tewting." These tests were being performed on several control rods following maintenance during the outage. At 0029 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> on March 8, 1988, control rod motion was secured with control rod 10 39 being the last rod tested. Step 7.10 of E3 1

PT-14.1A requires that the control rod being tested be returned to the full-in position; however, this step did not require a sign-off or independent verification. The operator failed to follow this step. At 0350 hours0.00405 days <br />0.0972 hours <br />5.787037e-4 weeks <br />1.33175e-4 months <br />, the shorting links were installed following a verification that control rods were inserted, thus initiating the violation. This condition existed until 2052 hours0.0238 days <br />0.57 hours <br />0.00339 weeks <br />7.80786e-4 months <br />, at which time control rod 10 39 was inserted by its individual scram switch. 1 As noted, a verification that control rods were inserted was performed prior to inserting the shorting links. Control rod 10-39 was not identified as being full out due to two problems: (1) the full out position indication switch was inoperable during this time period; and (2) the computer program for verifying the control rod position was modified during the outage prior to this event.

The position indication switch problem had been identified prior to this event and was scheduled to be repaired prior to unit start-up. Access to the drywell is required as these switches are 4

located within the control rod drive unit. This switch provides a signal which energizes the full out indication (a red light) on the full core display on the control panel.

Prior to the refueling outage during which this event occurred, the computer program used to verify control rod positions was OD-7, option 2. This program would print out "48" for those control rods that were full out. Lato in core life, most, if not all control rods are in the full out position, thereby making t.he OD 7 option 2 printout more difficult to review. To provide better human factored printouts for control rod position indication (to make them 1 css "busy"), another OD 7 option was developed which would not print anything for a control rod at position 48 (full out). By doing this, a full core printout of control rod positions late ir. core life would only print values for those rods not fully withdrawn.

Confusion arose because the new option was defined as OD.7, option 2, while the "old" OD 7, option 2 vas renam?d OD 7, option 3. The operators were not aware of this change at the time the incidout occurred, so that when the printout of control rod position indications was reviewed, the operators would have been looking for a "48." The printout that they saw showed all "0's" except for one small blank (no number), which was not identified.

Training was scheduled to address this program change prior to the completion of the outage.

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III. Corrective Actions Which licua Been Taken The following corrective actions have been completed:

1. Operations personnel involved with this event have been counseled.

2. A Standing Instruction was initiated following identification of this event to inform operations personnel of the computer program change. This instruction has since been deleted as training has been provided.

3. PT 14.lA has been revised to require sign-off and independent verification of control rod position following rod testing.

4. The full out position switch was repaired prior to the unit start up.

IV. Action Which Will Be Taken t No further actions are required as a result of this event.

V. Date Jhen Full Compliance Will Be Achieved Carolina Power & Light Company is now in full compliance with the applicable requirements.

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