View source for BSEP-83-1417, Responds to NRC Re Violations Noted in IE Insp Repts 50-324/83-05 & 50-325/83-05.Corrective Actions: Operating Procedures Revised to Accurately Reflect Desired Position of Fuel Oil Manual Fill Valves

{{Adams
| number = ML20076G468
| issue date = 05/20/1983
| title = Responds to NRC Re Violations Noted in IE Insp Repts 50-324/83-05 & 50-325/83-05.Corrective Actions: Operating Procedures Revised to Accurately Reflect Desired Position of Fuel Oil Manual Fill Valves
| author name = Dietz C
| author affiliation = CAROLINA POWER &amp; LIGHT CO.
| addressee name = Oreilly J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION II)
| docket = 05000324, 05000325
| license number = 
| contact person = 
| document report number = BSEP-83-1417, NUDOCS 8306140682
| title reference date = 04-07-1983
| package number = ML20076G462
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 2
}}

=Text=
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FILE: B09-13510E SERIAL: BSEP/83-1417 Mr. James P. O'Reilly, Administrator U. S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street NW Atlanta, GA     30303 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1&2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS

==Dear Mr. O'Reilly:==

The Brunswick Steam Electric Plant (BSEP) has received IE Inspection Report 50-324/83-05 and 50-325/83-05 and finds that it does not contain any information of a proprietary nature. As reported in BSEP's {{letter dated|date=May 5, 1983|text=May 5, 1983, letter}}, this response is being submitted late.
The report identified one item that appears to be in noncompliance with NRC requirements. This item and Carolina Power & Light Company's responsa are addressed in the following text:
Violation (Severity Level V)
Technical Specification 6.8.1.a requires written procedures to be established and maintained for recommended activities in Appendix A of Regulatory Guide 1.33, November 1972.       Items D.24.b and H.2 of Appendix A recommend procedures for operation of emergency power sources and for each surveillance test listed in the Technical Specifications.
Contrary to the above, on February 24, 1983, operating procedure OP-38, which is utilized for filling the emergency power diesel generator fuel oil tanks, was not adequately maintained, in that valves 2-FP-V20, -V21, -V22, and -V23 were specified as open instead of locked closed.
Contrary to the above, on February 20, 1983, surveillance procedure PT-08.2.4 was not adequately established, in that service water valves SW-V100 and SW-V104 were not listed as requiring verification of correct position.
8306140602 830607 PDR ADOCK 05000324 PDR G                                                                         OFFTCIAL -COPY

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Mr. O'Reilly                                          Carolina Power & Light Company's Response Carolina Power & Light Company acknowledges that plant operating procedures were not adequately maintained or established to assure compliance with NRC requirements as identified in this violation. The four valves associated with the diesel generator fuel oil system had been locked closed due to excessive leakage of the four-day tank automatic fill valves, which caused the four-day tanks to overflow into the saddle tanks and subsequently onto the floor around the diesels. When these valves were shut, an adequate review of the operating procedure (OP-38) was not performed to assure that the valve lineup list was appropriately revised.
A review of historical data concerning service water valves SW-V100 and SW-V104 has determined that these valves were not being checked as required by plant procedure (PT-08.2.4). The valve lineup for the service water system (OP-43) had indicated that the position for these valves was open, while the piping and instrument drawings (P&ID) for that system indicated that the valves were locked open. An adequate review of both documents was not performed while preparing PT-08.2.4 to notice the conflict and, therefore, resolve the discrepancy.
To correct the problems, OP-38 was revised (revision 7, March 18, 1983) to accurately reflect the desired position of the fuel oil manual fill valves.
OP-43 was revised (revision 31, March 29, 1983) to require that SW-V100 and SW-V104 be locked open. In association with this change, PT-46.1, a quarterly locked valve verification procedure, was revised (revision 21, April 13, 1983) to include these valves. No change was required to PT-08.2.4 due to the revision to PT-46.1.
A review is being conducted by Operations personnel to determine if similar procedural problems exist with other safety systems. This review is expected to be completed by June 15, 1983. Any other discrepancies identified will be corrected in an expeditious manner.        In addition, training is being planned for Operations personnel to address this violation, its cause (inadequate reviews), and the importanca of performing adequate reviews of procedures when system changes are being made. This training should be completed by July 15, 1983.
The plant operating procedures are currently undergoing a major upgrade by an outside contract group being assisted by two BSEP licensed personnel. This upgrade, including piping walkdowns to assure procedural adequacy for valve positions, should identify and correct other similar deficiencies. This procedure upgrade should be completed by December 31, 1983.
Very truly yours, C. R. Dietz, General Manager Brunswick Steam Electric Plant RMP/shb/LETSBl cc:   Mr. R. C. DeYoung NRC Document Control Desk t                                                          - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - - _ _ _ _ _ _ _ _                                                _ _ - - . _ _ _ . - _ ____m}}