View source for BSEP-96-0477, Responds to NRC Re Violations Noted in Insp Repts 50-324/96-15 & 50-325/96-15.Corrective Action:Review of OAP-010, Procedure Use & Adherence Will Be Performed

{{Adams
| number = ML20133A641
| issue date = 12/20/1996
| title = Responds to NRC Re Violations Noted in Insp Repts 50-324/96-15 & 50-325/96-15.Corrective Action:Review of OAP-010, Procedure Use & Adherence Will Be Performed
| author name = Levis W
| author affiliation = CAROLINA POWER &amp; LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000324, 05000325
| license number = 
| contact person = 
| document report number = BSEP-96-0477, BSEP-96-477, NUDOCS 9701020008
| title reference date = 11-22-1996
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 8
}}

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CP&L SERIAL: BSEP 96-0477 10 CFR 2.201 DEC 2 01996 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REPLY TO NOTICE OF VIOLATION                                                                                 ,
Gentlemen:
On November 22,1996, the Nuclear Regulatory Commission (NRC) issued a Notice of Violation for the Brunswick Steam Electric Plant, Units 1 and 2. The basis for the violation is provided in            l NRC Inspection Report 50-325/96-15 and 50-324/96-15.
i Carolins Power & Light Company admits violation A occurred as described in NRC                               1 Inspection Report 50-325/96-15 and 50-324/96-15. The reason for the violation, the corrective                j actions taken, and those further corrective actions necessary to prevent recurrence have been provided in Licensee Event Report (LER) 1-96-012 and submitted in a {{letter dated|date=October 18, 1996|text=letter dated October 18, 1996}}. Carolina Power & Light Company believes the company is in compliance with NRC regulations related to violation A and that no further actions are necessary.
Enclosure 1 provides Carolina Power & Light Company's response to the remaining violations in accordance with the provisions of 10 CFR 2.201.
Carolina Power & Light Company finds the inspection does not contaln information of a proprietary nature. Please refer any questions regarding this submittal to Mr. M. A. Turkal at (910) 457-3066.
Sincerely, W. Levis 9701020008 961220                                       Director - Site Operations PDR      ADOCK 05000324 0                       PDR                                                                           g i
SFT/s" Enclosures 300050                                                              $6U        I     1
: 1. Reply to Notice of Violations
: 2. List of Commitments

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..                   Document Control Desk                                                                                          i h                  ' BSEP 96-0477 / Page 2                                                                                          :
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I cc:      Mr. S. D. Ebneter, Regional Administrator, Region ll                                                  i
(                            - Mr. D. C. Trimble, Jr., NRR Project Manager- Brunswick Units 1 and 2 Mr. C. A. Patterson, Brunswick NRC Senior Resident inspector                                          i The Honorable H. Wells, Chairman - North Carolina Utilities Commission 1                                                                                                                                   i l
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4                                                            ENCLOSURE 1
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BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 and 2                                      .,
;                                        NRC DOCKET NOS. 50-325 & 50-324                                           I OPERATING LICENSE NOS. DPR-71 & DPR-62 REPLY TO NOTICE OF VIOLATIONS VIOLATIONS:
During an NRC inspection conducted from September 15 through October 26,1999, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
VIOLATION A:                                                                                              .
l 10 CFR 50 Appendix B, Criteria XVI, Corrective Action, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions,                j deficiencies, deviations, defective material, and equipment nonconformances are promptly                  ;
identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, the licensee failed to correct an adverse condition which resulted in a history of chlorine detector failures. On September 19,1996, during performance of OMST-                )
CLDET21A, Chlorination Detection System Channel Calibration, four of four chlorine detectors at          i the control building intake plenum and one of four detectors at the service water building failed        ]
the acceptance testing. Previous corrective actions from similar failures in March 1995 and April        j 1996 to prevent recurrence were established per Licensee Event Reports 1-95-02 and 1-96-05.
These actions failed to correct the detector failures. In inspection Report 325(324)/96-05 the            l NRC issued violation 96-05-01 to address the failure of the licensee to implement actions to             '
promptly identify and correct the nonconformances; the September 19,1996, detector failures are seen as a repeat of this violation.
This is a Severity Level IV violation (Supplement I). This is applicable to both Units.
RESPONSE TO VIOLATION A:
Admission or Denial of Violation:
Carolina Power & Light admits this violation.
Reason for Violation:
Reference LER 1-96-012 1 of 5

1 Corrective Actions Which Have Been Taken and Results Achieved:                                     l Reference LER 1-96-012 Corrective Steos Which Will Be Taken to Avoid Further Violations:
Reference LER 1-96-012 Dpte When Full Comoliance Will Be Achieved:
Carolina Power and Light believes that it is in full compliance with the requirements of 10 CFR 50 Appendix B, Criteria XVI.
VIOLATION B:                                                                                       l l
1 Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the applicable activities recommended in Appendix A of Regulatory Guide 1.33, November 1972. Regulatory Guide 1.33 recommends procedure for the control of alarm devices to assure that the device is properly controlled, calibrated, and adjusted at        j specified periods to maintain accuracy.
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Environmental & Radiation Control Procedure 0-E&RC-0358, Area Radiation Monitors (ARM)             l Radiation Response Monthly Test, Revision 6, requires a determination if the as found ARM          I readings accurately indicate area radiation levels. if found outside of the expected range, a      l judgment would be made to determine if actual area readings had changed or if the monitor          i required maintenance.
Contrary to the above, during the July 25 and August 14,1996, performances of 0-E&RC-0358           ,
the licensee failed to implement the requirements to properly determine the status of the ARMa. l In numerous instances upon finding monitors outside of the expected range the technicians failed to make the determination if actual radiation levels had changed or if the monitors required maintenance.
This is a Severity Level IV violation (Supplement I). This is applicable to both Units.            l RESPONSE TO VIOLATION B:                                 .
j Admission or Denial of Violation:
Carolina Power & Light admits this violation.
Reason for Violation:
Technicians responsible for performing 0-E&RC-0358 did not comply with the procedural requirements regarding action to be taken when ARM as found readings were discovered outside the expected range. In addition, supervisors responsible for the review and approval of completed ARM tests did not perform effective reviews of the completed ARM test procedures to ensure actions to resolve identified discrepancies were initiated.
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t Corrective Actions Which Have Been Taken and Results Achieved
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l           Specific instruction regarding the conduct of 0-E&RC-0358 and expectations for procedural j           compliance has been provided to the Radiation Protection Superintendent and the Radiation
!           Protection Instrumentation Supervisor.
l 0-E&RC-0358 was satisfactorily performed.
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l           Corrective Stecs Which Will Be Taken to Avoid Further Violations:
A review of OAP-010, Procedure Use and Adherence, will be performed during first quarter 1997 i
cycle training for Health Physics technicians.
l Date When Full Comoliance Will Be Achieved:
i Carolina Power and Light believes that it is in full compliance with the requirements of Technical Specification 6.8.1.
l VIOLATION C:
10 CFR 50, Appendix B, Criteria V requires that activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.
Contrary to these requirements, as of October 25,1996, instructions or procedures and drawings were either not followed or were not appropriate (adequate) for the modifications of the electrical j           cabinets as described below.
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: 1.      Section 9.14.6 of Procedure OMMP-04, Installation of Piping, HVAC, and l&C Tubing Supports, Revision 2, dated December 12,1994, requires that bolts shall have full thread engagement.
The bolts installed on electrical cabinets 21 A-1,21 A-2,22B-1, and 22B-2 did not have full thread engagement.
i           2.      The drawing shown on Page 23 of Engineering Service Request 9600407, Revisions 0 through 6 requires repair of loose hardware for the instrument rack for electrical cabinet
,                    P615.
The loose hardware was not repaired because of a drawing error, which did not clearly show the correct location of the repair, and the misinterpretation of the repair requirements by licensee personnel.
: 3.       Section 9.7 of Procedure EGR-NGGC-0005, Engineering Service Request (ESR),
Revision 1, dated August 2,1996, requires revisions to ESR documents to be documented and approved. The drawing shown on Page 16 of Calculation No. ESR 4
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9600407, Revisions 0 through 6, requires plate sizes to be 3/8" X 2" X 4-3/4" or 3/8" X 2" x 5" which are to connect electrical cabinets XU63 and XU64.                                       ,
The installed plate sizes connecting cabinets XU63 and XU64 were measured to be 3/8" X 2-5/8" X 5-5/8" which exceeded the 1/4" installation tolerance and required a revision to       (
the drawing (ESR document). The drawing was- not revised in accordance with Section               i 9.7 of EGR-NGGC-0005.
l This is a Severity Level IV violation (Supplement 1). This is applicable to Unit 1 only.                   !
RESP' V TO VIOLATION C:                                                                                    ]
Admission or Denial of Violation:                                                                          q Carolina Power & Light admits this violation.
Reason for Violation:                                                                                      I The examples identified in this violation were caused by the failure of modification                        j implementation personnel to comply with procedural requirements and to perform an adequate                 ;
verification for the work activities,                               ,                                      i Example 1 of the violation occurred when the personnel responsible for verifying thread engagement made an error in assessing the extent of thread engagement. Since visual inspection of the competed botting installation was difficult, craft personnel verified thread engagement by touching the bottom of the bolt / nut connection and then verifying that the bolt end was flush with the bottom of the attached nut. Subsequent inspection indicated that this bolting did not exhibit full thread engagement as required by site procedures. The end of bolt
      - lacked approximately 1/8" from extending to the face of_the nut.
Example 2 of this violation occurred when craft personnel made an erroneous interpretation of the scope of the work activity due % a modification drawing error. Upon identifying the error, craft personnel failed to consult with engineering personnel to resolve the error. In addition, craft
      - personnel allowed the work activity to continue without ensuring a revision to the sketch had been completed in accordance with procedural requirements.
With regard to example 3 of this violation, craft personnel determined that, due to some minor differences in the physical separation of the electrical c'abinets affected by the modification, several of the cabinet connecting plates needed to be slightly larger than specified on original design drawings. Craft personnel requested design engineering review and acceptance of the plate enlargements prior to piate fabrication. The responsible design engineer concurred with the change to the plate dimensions and intended on submitting the necessary design drawing change to reflect the enlarged plates prior to modification closure; however, these revisions had not been processed prior to installation of the plates. The enlarged plates were fabricated and installed with craft assuming that the required changes to design drawings would be initiated by engineering. However, prior to plate installation, craft personnel did not verify that the design drawings reflected the revised plate dimensions.
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Corrective Actions Which Have Been Taken and Results Achievd Engineering walkdowns were conducted subsequent to the identification of the conditions identified in this violation. The scope of these walkdowns included inspection of those accessible components affected by the modification. These walkdown inspections provide reasonable assurance that the remainder of the work associated with the modification is acceptable.
The craft personnel associated with implementation of ESR 96-00407 were counseled on the importance of cbtaining engineering direction for resolving discrepancies encountered durino implementation of field activities and ensuring installed conditions are consistent with design drawings.
Appropriate engineering personnel were counseled on the importance of ensuring that necessary revisions to design documents are processed in a timely manner.
Engineering personnel were trained on the modification drawing revision process during fourth quarter continuing training.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
Implementation Coordinators and Project Managers will be trained on their role associated with oversight of contract personnelimplementing field work.
The lessons learned from this event will be incorporated into the Seismic Qualification Utilities Group (SQUG) project implementstion plan.
Date When Full Comoliance Will Be Achieved:
Carolina Power & Light believes that it is in full compliance with the requirements of 10 CFR 50 Appendix B, Criteria V.                                                                 l l
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d                                                                                                                                            .h Enclosure 2                                                              }
.                                                        List of Regulatory Commitments
!              - The following tab'le identifies those a'c tions committed to by Carolina Power & Light Company in                             :
this document. Any other actions discussed in the submittal represent intended or planned                                    t j                 actions by Carolina Power & Light Company. They are described to the NRC for the NRC's j                 information and are not regulatory commitments. Please notify the Manager-Regulatory Affairs                                 l i                 at the Brunswick Nuclear Plant of any questions regarding this document or any associated                                    ;
i                 regulatory commitments.-
t Commitment da e r utage t
: 1.           A review of OAP-010, Procedure Use and Adherence will be .                                04/15/97 performed during first quarter 1997 cycle training for Health Physics technicians.
: 2.           The lessons learned from th'is event will be incorporated into the                        01/31/97 Seismic Qualification Utilities Group (SQUG) project implementation plan.
: 3.           Implementation Coordinators and Project Managers will be trained                           6/30/97 on their role associated with oversight of contract personnel implementing field work.
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