ML20129H108

Insp Repts 50-324/96-13 & 50-325/96-13 on 960804-0914. Violations Noted.Major Areas Inspected:Aspects of Operations,Engineering,Maint & Plant Support

ML20129H108
Person / Time
Site:	Brunswick
Issue date:	10/11/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20129H081	List: ML20129H077 ML20129H098 ML20129H108
References
50-324-96-13, 50-325-96-13, NUDOCS 9610310052
Download: ML20129H108 (30)

See also: IR 05000324/1996013

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U. S. NUCLEAR REGULATORY COMMISSION

REGION II

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Docket Nos:

50 325, 50-324

License Nos:

DPR 71, DPR 62

Report No:

50 325/96 13, 50-324/96 13

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Licensee:

Carolina Power & Light (CP&L)

Facility:

Brunswick Steam Electric Plant. Units 1 & 2

Location:

8470 River Road SE

Southport, NC 28461

Dates:

August 4 - September 14, 1996

Inspectors:

C. Patterson, Senior Resident Inspector

P. Byron, Resident Inspector (Section P1)

M. Janus, Resident Inspector

E. Brown, Inspector In Training

R. Aiello, Licensing Examiner (Section 05 and 08, 9/9-

13/96)

D. Forbes, Radiation Specialist (Section R1.1 and

R1.2, 9/9 13/96)

Approved by:

M. Shymlock, Chief. Projects Branch 4

Division of Reactor Projects

Enclosure 1

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9610310052 961011

PDR

ADOCK 05000324

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EXECUTIVE SUMMARY

Brunswick Steam Electric Plant Units 1 & 2

NRC Inspection Report 50 325/96 13, 50-324/96-13

This integrated inspection included aspects of licensee operations,

engineering, maintenance, and plant support. The report covers a 6-week

period of resident inspection; in addition, it includes the results of a

training inspection by a regional licensing examiner and a health physics

inspection by a regional inspector.

Operations

A violation was identified for failure to follow the equipment clearance

procedure. (Section 04.1). A Reactor Operator positioned a sample selector

switch while under clearance without a temporary tag lift.

The licensee was effective in conducting written and operating examinations to

ensure operator mastery of the requalification training program content.

(Section 05.1).

A violation was identified for failure to properly implement the Licensed

Operator Requalification (LOR) Program. (Section 05.1). An operator failed to

complete the LSR0 training program as required prior to taking the LSR0 audit

examination.

A non cited violation was identified for failure to provide complete and

accurate information as required by 10 CFR 50.9 Completeness and Accuracy of

Information. Additionally, two program weaknesses, one in operator

remediation and one in emergency plan training were identified. (Section

05.1).

Maintenance

Despite minor problems observed with foreign material exclusion practices

during initial new fuel receipt and inspection, the involved personnel showed

adequate knowledge of performed activities.

(Section M1.2).

A weakness was identified in preparation of the maintenance package for

installation of a fire pump relief valve.

(Section M1.4). The package did

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not discuss valve orientation as specified in the vendor installation

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instructions.

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Followup actions for a feedwater heater water hammer event were not effective

to prevent another event. (Section E2.2).

A violation was identified for not maintaining the Unit 2 criticality monitor

setpoint at greater than SmR\\hr. (Section E7.1).

Failure to properly revise

documents in accordance with an Engineering Evaluation resulted in a

criticality monitor being out of compliance with 10 CFR 70.24 requirements.

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Plant Support

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Two violations or deviations were identified concerning a contamination event.

(Section R1.1). One violation was for failure to follow licensee radiological

control procedures required by Technical SWcification 6.8.1.

The other

violation was for failure to perform radiological surveys required by 10 CFR 20.1501. Three separate NRC inspections since September of 1992 have

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identified survey violations. Corrective actions to these violations do not

appear to have been fully successful over the long term.

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Radiological facility conditions and housekeeping were observed to be good.

(Section R1.2).

The repetitive nature of control room access challenges, as well as a

tolerance of nonconforming access practices by Environmental & Radiation

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Control management was seen as a weakness (Section R1.3).

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The licensee's preparations for Hurricane Fran were prompt and thorough

(Section Pl.1). A good assessment of the site's readiness for restart was

conducted. The licensee temporary suspension of security and fire watch

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rounds were appropriate due to the storm conditions (Section S1.1).

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Report Details

Summary of Plant Status

Unit 1 operated for 50 days until the unit was shutdown on September 5, 1996,

in preparation for Hurricane Fran. On September 5, 1996, the site experienced

hurricane force winds of 115 miles per hour for about ten hours with wind

gusts up to 125 miles per hour.

No significant damage occurred to safety

related structures. Several buildings suffered damage as a result of the

storm. The roofs of the Unit 1 Turbine Building, the Unit 2 Reactor Building

and the Operations and Maintenance (0&M) building developed leaks.

Several

sections of siding were blown off the Technical and Administration Center

(TAC) and O&M buildings, and the Work Control Center (WCC) building. After

the Federal Emergency Management Agency (FEMA) review of the 10 mile emergency

planning zone the unit returned to service on September 10, 1996. At the end

of the report period Unit 1 had operated five days.

Unit 2 operated for 41 days until the unit was shutdown on September 5, 1996,

in pre 3aration for Hurricane Fran. The unit returned to service on

Septem)er 13, 1996. At the end of the report period the unit had operated one

day.

I. Doerations

03

Operations Procedures and Documentation

03.1 Procedures for Averaae Power Rance Monitor (APRM) Gain Ad.iustment

Factor (GAF) ad.iustment (42700)

a.

Inspection Scope (42700)

Review PT 1.11, Revision 35, dated November 6, 1995 Core Performance

Parameter Check, to determine if this procedure could be used after the

turbine was on line. The inspector was concerned that the APRMs could

be reading much higher than alternate indications resulting in non-

conservative scram setpoints,

b.

Observations and Findinas

The inspector identified that PT 1.11. Rev 35, is required to be

performed:

once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when operating greater than or equal to 25%

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thermal power

within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after completion of a thermal power increase of at

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least 15% of rated thermal power

initially and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the reactor is

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operating with a LIMITING CONTROL R0D PATTERN for Average Planar

Linear Heat Generation Rate or Minimum Critical Power Ration

prior to 25% thermal power

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GP 03, Rev 40, Unit Startup and Synchronization, states that APRM

indicated power levels should not be reduced (non conservative) by gain

adjustments below 25% thermal power, otherwise, non-conservative APRM

readings (gain adjustment factor (GAF) greater than 1 may result from

adjustment as power is increased. GP 03, Rev 40. Step 18.b. further

indicates regardless of power level or whether the main turbine is on

line to perform conservative APRM GAF adjustments, as required, in

accordance with OP 09, Neutron Monitoring System Operating Procedure,

Revision 17, dated 12/19/94. OP-09 initial conditions for adjusting the

APRM GAFs are:

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The reactor mode switch is in RUN or START & HOT STBY

The Process Computer is in operation in accordance with 00P-55.

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Revision 19, dated June 5, 1995, Plant Process and ERFIS Computer

Systems Operating Procedure.

00P 55, Rev 19 does not require the main turbine to be online as an

initial condition.

c.

Conclusions

The inspector identified no negative findings.

04

Operator Knowledge and Performance

04.1 Clearance Tao Errors

a.

Inspection Scope (71707)

The inspectors reviewed the events concerning several clearance tag or

equipment control difficulties during August 21 - September 10, 1996.

b.

Observations and Findinas

During this inspection period the inspectors reviewed several clearance

tag or equipment control difficulties.

On August 25, 1996, licensee

personnel entered the Unit 2 B North waterbox for debris filter

cleaning. While attempting to pump down the water level in the box, it

was determined that flow still existed into the waterbox.

Further

investigation revealed that Amertap piping from the B South waterbox was

the source. Boundary clearance 2 96 2341 did not identify the

importance of several valves which provided a cross connection between

the B North and South waterboxes. This clearance was modeled after a

similar clearance previously performed on the A South waterbox. The

cross connection valves were overlooked.

On September 10, 1996, after placing the 2C heater drain pump in

operation the aump packing was found to be hot and smoking. Subsequent

investigation ay the licensee discovered that the pump had been started

without gland seal water flow available. The inspector reviewed the

condition report, equipment control form, and associated drawings.

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On August 21, 1996, after completing maintenance or; the 1 CAC AT 4410

Hydrogen /0xygen Analyzer System, the licensee was preparing to perform

Periodic Test OPT-20.8.2, CAC AT 4410 Leak Test to verify no monitor

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tube leakage. The 1-CAC-AT 4410 was under equipment clearance

1 96 01835 for maintenance activities.

For performance of the test, a

tem >orary tag lift was required to energize the monitor.

In accordance

witi Administrative Instruction 0AI-58. Equipment Clearance Procedure, a

tag lift was requested and approved for the AC circuit power supply

breaker for the monitor only. Additional steps in the procedure called

for operation of the CAC-AT 4410 sample select valve switch located in

the control room. The sample select switch was under clearance and

required to be in the "off" position.

However, the operator

repositioned the switch without the 0AI 58 required temporary tag lift.

The inspector reviewed the associated procedures, clearance order,

discussed switch location and operation with licensee personnel, and

identified the failure to follow OAI 58, Equipment Clearance Procedure

as a violation. This violation was identified as 50 325/96-13-01

Equipment Clearance Error. This violation, despite being identified by

the licensee and timely corrective actions taken, was cited because

previous examples were non cited (NCV 96 08-01 concerning operation of

equipment while under clearance).

c.

Conclusions

Failure to implement adequate boundary clearances and equipment control

forms allowed maintenance activities to be conducted without

establishing adequate system isolation. A failure to obtain a

procedurally required tag lift request before repositioning a switch

under clearance was identified as a violation.

05

Licensed Operator Requalification (LOR) Program Evaluation and Training

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and Qualification Effectiveness

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05.1 Non licensed operator aualification cards. Limited Senior Reactor

Operator (LSRO) trainina and LOR remediation

a.

Insoection Scope (41500. 71001)

The inspector reviewed the licensee's requalification program for

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licensed reactor operators and senior reactor operators to ensure safe

power plant operation and to evaluate how well the individual operators

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and crews had mastered the training objectives. Review portions of the

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non licensed operator training program to ensure that the appropriate

training and qualification programs were developed, implemented,

evaluated, documented, and maintained as required by 10 CFR 50.120 and

allowed by 10 CFR 55.

b.

Observations and Findinas

(1)

The inspector reviewed the four LSR0 qualification cards for the

candidates that took the LSR0 examination in December 1995. The

LSR0 candidates, facility management, and NRC all signed the NRC

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form 398 license applications in November 1995. The facility

signatures verified that all training was complete. However The

qualification cards were not signed and dated by facility

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management until February 6, 1996.

The facility training

department submitted a Condition Report (CR) on February 12, 1996

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concerning this matter. According to the CR, the qualification

records were not signed off as complete because a change had to be

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made to the qualification card which required a management

authorization signature. These qualification cards were

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subsequently set aside. When the license applications were routed

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for signature, the supervisor initial training, signed them

without ensuring that the closure documentation was completed on

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the LSR0 on the job training (0JT) Qualification Card. The

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facility stated in the CR that all of the required training was

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completed prior to submitting the 398 forms to the NRC. The

inspector reviewed documentation and conducted interviews, to

verify that all of the facility 0JT training requirements were

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satisfactorily com)leted as required by TM-4.21. Revision 1, dated

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October 30, 1995,

_SR0 to Refueling Training Program. The

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inspector identified that one LSR0 candidate failed to complete

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all of the required LSR0 training prior to taking the LSR0 audit

examination. TM 4.21 states, in part, that "each candidate will

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satisfactorily complete an LSRO Qual card (TM-4.02.08) prior to

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the LSR0 Audit Examination." The audit examination was

administered on November 17, 1995. The candidate's 0JT was not

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completed until early December 1995.

This is identified as

violation 50-325(324)/96-13 02, failure to complete the LSR0

training

3rogram prior to taking the LSR0 audit examination as

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required )y procedures.

(2)

The inspector identified that the LSR0 applicants and licensee

management signed the NRC form 398 for all four LSR0 applicants

prior to the completion of the facility audit examinations. All

four NRC form 398s were signed before the completion of LSR0

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training.

TM 4.21, paragraph 4.1.3.a. states, in part, "following

the training, an audit examination is given to determine if the

LSR0 trainees are prepared for an NRC license examination."

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Paragraph 19b (disclosure) on NRC form 398 states, in part, that

the subsequent signatures certify that the named individual has

successfully completed the facility licensees requirements to be

licensed as an R0/SR0 pursuant to 10 CFR part 55. The facility

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)rovided inaccurate information when they signed the NRC forms 398

3efore the candidates completed the audit examination and is

identified as a 10 CFR 50.9 violation.

The inspector noted that

the facility has responded promptly to these identified

discrepancies and are pursuing an official root cause

determination. Therefore, this violation is being treated as an

NCV consistent with Section VII.B.1 of the NRC Enforcement Policy.

This is identified as NCV 50 325(324)/96 13 03, for failure to

provide complete and accurate information as required by 10 CFR

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50.9, Completeness and Accuracy of Information.

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(3)

10 CFR 55.59 (c)(5), states, in part, that the facility licensee

shall maintain records of the results of evaluations and

documentation of operating tests and any additional training

administered in areas in which an operator or senior operator has

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exhibited deficiencies. The ins)ector reviewed several reports on

student performance (from 1994 t1 rough 1996) regarding

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remediation. The inspector identified several cases where the

students results were not documented in sufficient detail as

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required by 10 CFR 55.59 (c)(5), Records. The inspector

identified this as a weakness.

(4)

The facility identified in April of 1996 (CP&L Memo dated

April 11, 1996) that reactor operators may not be fully trained on

all auxiliary operator watchstations. The pur>ose of this memo

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was to communicate the compensatory measures t1at needed to be

taken and describe licensee plans for final corrective actions.

The facility implemented a program in May of 1996 (CP&L Memo dated

May 14, 1996) called "A0 Delta." A comparison was made between

the system objectives that the A0s were trained on and the

objectives that the licensed operators were trained on when both

groups received training on the same topic. A qualification card

was developed then implemented on May 17, 1996.

Licensed

operators were not allowed to stand watches in the turbine

building or outside until the qualification card for "A0R Makeup

For Licensed Operators" was completed. Licensed operators were

restricted to reactor building watches until they were "A0 Delta"

qualified since most of the systems were covered in LOR. The

inspector identified on September 12, 1996, that many of the

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licensed operators had started this new qual card but none of them

have completed their qualifications under the new program. This

item is identified as IFI 50 325(324)/96-13 04, AOR Makeup For

Licensed Operators.

(5)

The inspector identified several cases between 1995 and 1996 where

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SR0's were unable to adequately classify events during simulator

exercises. The inspector reviewed the LOR Emergency Plan lesson

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topic and one examination in detail.

Examination scores, from

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five different exams, ranged from 70 to 100%.

Most of the

examination scores were greater than 90%. The operators' poor

performance in the simulator, with respect to Emergency Action

Level (EAL) classifications, does not reflect the stellar

performance that was documented on their written examination

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course roster. The inspector identified this inconsistency as a

training weakness.

c.

Conclusions

The inspector determined that the licensee was effective in conducting

written and operating examinations to ensure operator mastery of the

requalification training program content. However, the inspector

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identified:

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one violation for an LSR0 candidate who failed to complete the

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LSR0 training program as required prior to taking the audit

examination

one non cited violation for failure to provide complete and

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accurate information as required by 10 CFR 50.9, Completeness and

Accuracy of Information

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one weakness in operator remediation

one weakness in emergency plan training

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one IFI regarding AOR Makeup For Licensed Operators

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Miscellaneous Operations Issues (92901)

08.1

(CLOSED) Unresolved item 50-325(324)/96-10 01. Determine if Auxiliary

Operators Have Been Adeauately Trained Der TI 104. Auxiliary Ooerator

OJT Checklist. The inspector reviewed several individual A0

qualification cards. Two of these individuals were licensed operators.

The inspector identified, on one qualification card, where the student

received 14 signatures in one day by the same individual.

Each

signature required an array of duties or applications to be performed.

The inspector questioned whether or not these duties could have all been

physically performed in one day with any degree of proficiency. The

inspector interviewed the trainee and the evaluator. The qualification

card was discussed in detail. The trainee and the evaluator stated that

the checkouts may have been conducted over the course of many shifts.

However, the evaluator did state that if the trainee had previous

experience and was familiar with the systems in question that the

checkout could have been completed over the course of one shift. The

inspector identified that the operator (trainee) was previously

qualified as a radwaste operator. The inspector reviewed the operator's

performance record and identified no significant errors or incidence

that would be indicative of poor or inadequate training. The inspector

had no other concerns and considers this item closed.

II. Maintenance

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Conduct of Maintenance

M1.1 General Comments

a.

Insoection SCoDe (61726)

The inspector observed portions of the following maintenance activities

and surveillance tests:

e 1-MST RHR280, RHR RSDP System Flow Channel Calibration

e 0 PIC PS012 ASCO SC12 SC22, SC32, and SC42 Pressure Switch

Calibration

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e 0 PIC-LS008. Calibration of Magnetrol Model T21 Level Switch

2 MST-APRM210, APRM A and LPRM Group A Channel

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Calibration / Functional Test

1 MST-AMI27M, AMI Suppression Pool Temperature Monitor Channel

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Functional Test

b.

Observations and Findinas

The inspectors verified that work was performed with the procedure

3 resent and properly validated in accordance with licensee arocedures.

_icensee personnel were knowledgeable of their assigned tas(s, observed

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to use good communication and self checking techniques, and approariate

safety equipment was worn when needed. The inspectors verified tlat the

surveillance tests were performed within their required frequencies,

associated documentation was found to be satisfactory, and the observed

tests were completed as discussed in this section.

Specific discussions of other maintenance activities inspected are

included in M1.2 - M1.4 below.

M1.2 New Fuel Receiot

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a.

Inspection ScoDe (62707)

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The inspector observed activities associated with the receipt and

inspection of new fuel bundles for Unit 1.

Discrepancies in the upscale -

setpoint for a new fuel vault criticality monitor were found and are

discussed in Section E7.1.

b.

Observations and Findinos

The inspector observed the receipt and inspection of several loads of

new fuel in preparation for the upcoming Unit 1 outage. The procedures

used were current and had been properly verified as required.

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transport of new fuel into the reactor building and onto the refuel

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floor was observed and conducted in accordance with OSPP FUE501,

Receiving and Handling of New Fuel Bundles.

In accordance with

Administrative Instruction. 0AI-106, Establishing and Controlling a

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Foreign Material Exclusion Area, when the new fuel vault was opened, a

foreign material exclusion (FME) area was established to prevent loose

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materials or equipment from being inadvertently dropped into the vault.

The inspector observed the licensee FME briefing which discussed the

OAI-106 requirements. The insp ctor observed personnel lean over the

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FME area without the required lanyard on their safety glasses. Upon

notification of these actions by the inspector, the work supervisor

notified all personnel present to verify lanyards were used when

accessing the area.

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Good monitoring by the health physics (HP) technician of area dose

limits and of as low as reasonably achievable (ALARA) practices was

observed.

Plant management concerns about dose received on the fuel

inspection platform resulted in additional shielding being added to

reduce area dose. During the inspection of the first load of fuel an

additional training crew was present on the refuel floor. Despite

constant reminders by the health physics technician, several personnel

were not actively seeking low dose areas to watch inspection activities.

Subsequent notification of the HP technician and work supervisor by the

inspector of the infrequent adherence of the training crew to practice

good ALARA techniques resulted in reminding personnel present to move to

a lower dose area whenever possible.

During the observation of the first load of new fuel, inspection

activities were conducted in accordance with the Engineering Procedure

OENP 27. New Fuel. Channel Fasteners Inspection.

Minor problems were

discovered during new fuel transport and inspection.

In several new

fuel containers and channel containers some moisture was noted. The

inspector observed that one out of three tampersafe seals missing from

one of the new fuel inner containers.

Upon notification by the

inspector, the container was promptly inspected by the licensee and

determined to be acceptable.

During a review of subsequent new fuel load inspection activities, an

improved crew awareness of FME and ALARA arocesses was observed by the

inspector. The crews appeared knowledgea)le of the procedural

requirements and compensatory actions if difficulties were discovered.

During subsequent new fuel transport activities CR 96 2546 was

generated. This CR recorded the improper stacking of the new fuel

shipping containers. The licensee promptly identified and corrected the

nonconformance.

No other discrepancies were identified.

c.

Conclusi_o_q

Inspector observation of personnel during initial new fuel transport and

inspection activities showed minor problems with FME and ALARA

practices.

Subsequent management involvement in inspection activities

improved FME and ALARA practices.

Health physics coverage of area dose

and ALARA practices was satisfactory.

M1.3 WR/J096 ACTA 1. Drainina the Unit 1 Eauipment Pool

a.

Inspection Scope (62707)

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The inspectors observed the performance of work activities associated

with WR/JO 96 ACTA 1, which provided instructions for the draining of the

Unit 1 Equipment Pool. The pool was being drained as part of a clean up

effort in preparation for the upcoming Unit I refueling outage.

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b.

Observations

This work involved the removal of the water in the equipment pool and

transferring it to radwaste for

3rocessing.

Following removal of the

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water, the equipment pool would >e washed down and coated with a

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strippable paint to further reduce the contamination levels in the pool.

The water was pum>ed from the equipment pool to the cask washdown area

then drained to t1e waste neutralizer tanks in radwaste. The licensee

established a containment tent around the pool area prior to set-up and

start of this process to minimize the potential spread of contamination

caused by work activities within the pool.

Prior to the start of activities, the inspector attended the final pre-

job briefing.

During the brief, all aspects of the evolution were

discussed and verified ready to support the operation. One topic of

discussion was the expected dose rates in the areas of the transfer and

drain lines. These levels were discussed and plans to monitor and

control these areas were verified to be ready. The work plan and

instructions were discussed in detail, including contingency plans and

expected actions. The inspector noted that the brief provided a clear

outline of the activities, the command and control of the evolution, and

the expected actions of all involved.

The initial transfer of water from the equipment pool started on

August 15, 1996 and continued on a day to day basis as supported

by radwaste until the equipment pool was drained. The inspector

observed the transfer process on several occasions during this

evolution and noted that all work was being aerformed per the

instructions. The inspector verified that t1e dose levels in the

areas of the transfer lines were within the expected levels. The

inspector noted that specific areas near the transfer and drain

lines were roped off to control access and minimize personnel

exposure during the evolution. When questioned, all involved

workers were aware of their responsibilities and required actions,

and had good knowledge of the task at hand. Additionally, the

inspector noted the presence of the project manager and health

physics personnel on the refueling floor monitoring and

controlling the work activities through out the conduct of this

job.

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The licensee completed all equipment pool draining activities on

September 4, 1996, when the job was secured in preparation for Hurricane

Fran. Following the hurricane, all remaining equi > ment in the pool was

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removed.

Less than an inch of water remained in tie pool.

Based on

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excess dose considerations, plans to apply a strippable paint were

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canceled in favor of a thorough hyrolaze and drain down prior to the end

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of the upcoming outage.

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c.

Findinas

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The inspector concluded that the job was thoroughly planned and

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conducted in accordance with that plan. The personnel involved were

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knowledgeable about their tasks and adequately controlled the evolution.

No problems or discrepancies were identified during the conduct of this

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job. This task occurred after additional management attention was

placed on the cleanup following the internal contamination event

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discussed in Section R1.1.

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M1.4 Fire Pumo Maintenance

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a.

Inspection Scope (62703/62707)

On August 21, 1996, the inspector reviewed the maintenance activities

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associated with the motor driven fire pump (MDFP). This system was a

maintenance rule system. The pump had failed a performance test and

would not deliver greater than 2000 gallons per minute. The maintenance

was to replace a leaking relief valve that was the cause of the reduced

flow rate.

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b.

Observations and Findinas

The inspector observed the installation of a new relief valve in the

system. The clearance tag boundaries were reviewed for clearance CL 2-

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96 02318. The inspector noticed that, due to the inability to isolate

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only the MDFP and relief valve, the boundary included the diesel driven

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fire pump. The inspector verified that a temporary diesel driven fire

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pump was connected at the discharge canal as a backup while the other

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fire pumps were out of service. This compensatory measure was required

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by plant procedures. The inspector walked down the temporary

installation at the discharge canal and found no discrepancies.

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While observing the installation of the relief valves, the inspector

reviewed the maintenance package for tb job. The work was being

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performed under work request / job order (WR/J0) 96 AEXG1. The inspector

reviewed the vendor manual, FP 82494, containing information about the

relief valve. The installation instructions on page 4, step 5, stated

that the relief valve must be installed in a vertical position with a

note in parentheses that this was an American Society of Mechanical

Engineers (ASME) Code requirement. The relief valve was being

installed in a horizontal position. This orientation was the original

installation configuration. The inspector discussed this conflict with

the supervisor at the job site and later with an engineering supervisor.

The licensee contacted the vendor and determined that the installation

of the valve was not in accordance with their recommendations. The

licensee initiated CR 96 03556, Fire Protection Relief Valve

Configuration, to address this issue. The horizontal installation could

result in improper seating of the valve. The CR recommended action to

either reconfigure the piping, or implement periodic maintenance to

inspect the valve seats.

Additionally, the licensee concluded that the ASME code was not

applicable to the fire protection system except part B31.1 for pipe

supports. An operability concern did not exist since the relief would

only lift under infrequent deadhead conditions.

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The inspector observed the workers using proper torquing techniques for

bolting the relief valve to the piping flanges.

Later in the day the

pump was tested satisfactorily.

c.

Conclusions

The inspector concluded that the work performed on the MDFP was

performed with adequate clearance boundaries and commnsatory measures.

The licensee addressed the question concerning the p1ysical orientation

of the relief valve by CR 96 02556.

The valve configuration was not

previously addressed during preparation of the repair package. This was

considered a weakness in preparation of the maintenance package.

III. Enaineerina

E2

Engineering Support of Facilities and Equipment

E2.1 Review of Reactor Water Clean Up (RWCU) Hiah Eneray Line Break (HELB)

Analysis

a.

Inspection Scoce (37551)

In response to a problem identified at another Boiling Water Reactor

(BWR), the licensee reviewed the HELB analysis for the RWCU system. The

identified problem involved the isolation signals for RWCU in the event

of a HELB outside of primary containment. At the other BWR, it was

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identified that at lower power levels, automatic RWCU isolation on low

reactor water level was prevented by excess makeup capacity of the

feedwater system. Alternative isolation signals were not available to

provide this automatic isolation on indications of a HELB outside of

primary containment.

The licensee reviewed the issue for applicability, and determined that

they did not have this problem. The RWCU system at Brunswick is provided

with a number of diverse automatic isolation signals for a HELB outside

of containment. The safety related automatic isolation signals are:

Reactor Water Low Level: High Area Temperature: High Area Differential

Temperature: High Differential Flow: Standby Liquid Control initiation:

and an add',tional non safety related isolation signal on Non-

Regenerative Heat Exchanger High Outlet Temperature. The licensee

concluded that based on their design review, that they do not have a

similar pcoblem. The inspector reviewed the licensee's analysis and the

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UFSAR description of the RWCU system, and did not identify any problems

or discrepancies.

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E2.2 Feedwater Heater Water Hammer - Reoeat

a.

Insoection Scooe (37551. 40500)

The inspector reviewed the feedwater hammer event that occurred during

Unit 2 startup after Hurricane Fran. A similar event occurred during

Unit 2 startup after Hurricane Bertha.

b.

Findina and Observations

During shell warming of the Unit 2 main turbine on September 11, 1996, a

water hammer event occurred damaging the 4A feedwater heater drain

valve, 2-HD LV 75. The valve yoke was sheared into two pieces. A

similar problem occurred during a previous startup as discussed in NRC

Inspection Report (IR) 50 325(324)/96-10

The licensee thought they had found the major contributor to

pressurization of the 4A and 5A feedwater heater with the discovery of a

leaking steam extraction isolation valve to the SA feedwater heater.

Repairs were performed to extraction steam isolation valve to the SA

feedwater heater. As a precaution a manual isolation valve between the

4A feedwater heater and the drain valve, 2 HD LV-75, was throttled to

20% open. However, despite the throttling of the manual valve the water

hammer occurred.

The licensee preceded with the unit startup and repaired valve 2 HD LV-

75 later. The licensee used a thermal imager to identify that

extraction steam isolation valve EX-V17 was leaking and pressurizing the

4A feedwater heater.

The inspector reviewed the operator lesson plan ORS-CLS SM 034 A,

Extraction Steam, Feedwater Heaters, Drains and Vents, concerning this

system. Two items were noted in the system design that might have

prevented the second event.

First, this type of feedwater heater has a

subcooler near the drain outlet to prevent flashing of vapor.

The

subcooler was dependent on feedwater flow to be effective. Thus,

sequencing of feedwater flow through the feedwater heater at a time

during which the feedwater heater could be >ressurized would minimize

any potential flashing of vapor.

Second, t1e lesson plan discussed

startup vents from the heater to the condenser. These vents are

supposed to be open during startup to prevent any potential water

hammer.

These issues were discussed with licensee management. The licensee had

independently reviewed the startup vents.

Present plant startup

procedures do not open these vents during startup.

Finally, one of the corrective actions from the first water hammer event

discussed in IR9610 was operational contingencies during startup. This

was to monitor the feedwater heater during startup for any signs of

3ressurization. Due to the leaking valve repair to the SA feedwater

1 eater this was not performed. Additionally, the throttling of the

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manual valve was a precaution taken to 3revent another water hammer

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event.

Neither of these actions were t1orough enough to prevent another

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event.

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c.

Conclusions

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The inspector concluded, as discussed in NRC IR 9610, that engineering

provided good support to the plant in identification of the damaged

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drain valve and cause of the first feedwater hammer event. However,

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engineering followup actions were not effective to prevent another

event. Analysis of the problem did not initially consider startup

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operation of the feedwater heater.

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E7

Quality Assurance in Engineering Activities

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E7.1 Criticality Monitor

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1

a.

Inspection Scope (37551. 40500)

While reviewing the Unit I criticality monitor setpoint, the inspector

noted several procedural discrepancies.

b.

Observations and Findinas

While reviewing the procedures associated with the Unit 1 inspection and

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transfer of new fuel to the nn fuel vault, the inspector discovered

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inacctreacies with the calibration and functional procedures for the new

fuel vault criticality monitor 1(2)D22 RM K6001(2) 26. This area

radiation monitor (ARM) provides indication of an inadvertent

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criticality occurring in the new fuel vault. During a review of

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Annunciator Panel Procedure 1 APP-UA 03, the inspector observed a

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reference to Engineering Evaluation Report (EER) 94168. This EER as

well as adverse condition report (ACR) B93104 documented the licensee

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finding that the upscale tri) setpoint for the criticality monitor was

not set in accordance with t1e 5 mR/hr or greater requirement of 10 CFR

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70.24 (a)(2) as committed to in the Updated Final Safety Analysis Report

(USFAR). The EER corrective actions 3roposed changing the upscale trip

setpoint from 3 i 0.2 mrem / hour (mR/ir) to 6 i ImR/hr using work

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request / job orders (WR/J0s) 94 AHEll cod 94 AHEK1, and revise several

procedures and drawings.

?

The ins)ector reviewed all the documents identified for revision and

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found tlat the lack of proper followup by engineering with other

departments resulted in the closeout of the EER before ensuring several

of the items identified were properly updated. The inspector found that

only the UFSAR and procedures 1(2) UA 03 had been properly corrected for

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the new fuel vault monitor. The environmental & radiation control

(E&RC) procedure 0 E&RC 0358, Area Radiation Monitors Radiation Response

Monthly Test, Rev. 6. System Description SD 11.1 Area and Environs

Radiation Monitoring System, and instrument schedule LL-07000 D22 Sheet

3 were not revised as identified in EER 94-099. The inspector discussed

the incorrect procedures with the licensee.

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Preventive maintenance procedure OPIC ETU003, GE Area Radiation Monitor

Indicators and Trip Unit Model 129B2802 G1 and G11 G17 Calibration,

includes instructions for the calibration of the new fuel vault

criticality monitor. The inspector determined that on August 22, 1994,

revision 14 to 0PIC ETU003 properly changed the criticality monitor

setpoint to 6 i 1mR/hr as required in accordance with EER 94-168.

However, revision 15 on November 17, 1994, erroneously reset the u) scale

setpoint to 3mR/hr. During subsequent preventive maintenance on t1e

Unit I criticality monitor, the setpoint was observed to be incorrect.

A procedure change request was initiated and the monitor was correctly

reset. Additional inspector cuestions led to the discovery that the

Unit 2 criticality monitor hac

been outside of compliance with the 10 CFR 70.24 (a)(2) requirement of at least SmR/hr since December 1994.

This indicated that the criticality monitor was not )roperly set during

new fuel receipt and refueling activities for the Fe)ruary 1996. Unit 2

refueling outage. This failure to maintain a preset alarm point of not

less than 5 mR/hr is identified as violation 50 324/96 13 05 of 10 CFR 70.24(a)(2), Failure to Correctly Update ARM Alarm Setpoint.

Revision 15 to OPIC ETU003 was intended to reset the upscale setpoint

temporary change from 6mR/hr to 3mR/hr for ARM 2 D22 RM K601 2 4,

Condensate Filter Demineralizer Aisle per EER 94 099. The inspector

reviewed EER 94 099 and determined that despite the monitor being reset,

the documents identified for revision had not been corrected.

In

addition on December 1,1994, OPIC ETU003 was identified in WR/JO 94-

ANNR1 as being placed on restricted use hold until a correction to the

upscale'setpoint for ARM 2 D22-RM K601-2 4, Condensate Filter

Demineralizer Aisle was made. The inspector reviewed OPIC ETU003 and

determined that no revision had been made to correct the radwaste ARM

setpoint.

After discussions with the licensee, three condition reports, 96 2373,

96 2379, and 96 2475 were issued to track procedural deficiencies in

E&RC procedure OE&RC 0358, mainter.ance procedure OPIC ETU003, and the

failure to update a related instrument schedule. An UFSAR discrepancy

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was identified by the inspector, this item is discussed in Section E7.2.

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c.

Conclusion

The lack of proper followup by engineering with other departments for

revision resulted in the closecut of EER94168 before ensuring the items

identified were properly updated. The review of the new fuel vault

criticality monitor setpoints in preparation for an NRC observation of

new fuel receipt and inspection revealed procedural change difficulties

for the Maintenance, E&RC, and Document Control organizations. The

failure to maintain a preset alarm point of not less than 5 mR/hr was

identified as a violation.

E7.2 Special UFSAR Review

A recent discovery of a licensee o>erating the facility in a manner

contrary to the UFSAR description lighlighted the need for a srecial

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15

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focused review that compares plant practices, procedures, and/or

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parameters to the UFSAR descriptions. While performing the inspections

discussed in this report, the inspectors reviewed the applicable

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portions of the UFSAR that related to the areas inspected. The

inspectors verified that the UFSAR wording was consistent with the

observed plant practices, procedures, and/or parameters.

The inspector reviewed UFSAR Section 12, as part of the inspection

activities described in E7.1, Criticality Monitor. This review revealed

one inconsistency with UFSAR listed plant parameters.

In UFSAR Table

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12.3.4 3, the setpoint for the Unit 1 and 2 ARM located north of the

fuel storage 'ool with channel nos. 1(2) 27 are not consistent with the

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current OPIC ETU003 identified requirements. The inspector notified the

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licensee of this finding and they were reviewing the issue at the end of

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the report period. This item will be identified as part of URI

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325(324/96 05 02.

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IV. Plant Support

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R1

Radiological Protection and Chemistry Controls

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R1.1 Followuo to Licensee Event (Unit 1)

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a.

Inspection Scope (83725)

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The inspectors reviewed implementation of licensee controls for internal

exposure to determine licensee compliance with regulatory requirements

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and licensee corrective actions to a contamination event that occurred

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in the Unit 1 Reactor Building on July 8,1996.

b.

Observations and Findinas

Description of Event

I

On the morning of July 8,1996, following installation of a ladder in

the Unit 1 equipment pool on the 117 foot elevation, two workers were

found to have facial radioactive contamination.

Subsequent internal

monitoring found measurable internal radioactive contamination of one

worker to be 354 nanocuries (nC1) and 40 nC1 for the other worker. The

workers had been working to install a permanent ladder in the drained

equipment pool to support an equipment pool cleanup. Efforts to

determine the magnitude of the radioactive contamination spread and to

contain the contamination began upon detection that the workers were

contaminated.

Licensee followup surveys determined contamination was

spread by ventilation systems from the 117 foot elevation to the 80-foot

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elevation and down to the 50-foot elevation of the Reactor Building.

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During the inspection, the inspectors indeoendently reviewed licensee

,

procedural requirements, Radiation Work Pe'rmits (RWPs), radiological

surveys, the licensee's investigation /self assessment and immediate

corrective actions to the event, and interviewed selected licensee

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personnel to include technicians, supervisors, and managers. The

following deficiencies were identified by the licensee:

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Inadequate supervisory oversight for the refueling floor work and

poor communications during shift turnover between Health Physics

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(HPs) personnel for the ladder installation work occurred.

e Licensee procedure OE&RC 0230. Issue and Use of Radiation Work

Permit, Revision 33, required workers understand the current

Radiation Work Permit (RWP) revisions. The RWP being used by the

workers only allowed work to be performed with contamination levels

up to 25,000 disintegrations per minute (DPH). Radiological surveys

nMor to modification determined contamination levels of 160,000 DPM

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on the ladder. The workers were allowed by HP to modify the ladder

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on the refueling floor by cutting the ladder su) port legs. Workers

did not understand RWP requirements, in that, tie 25,000 DPM

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contamination limits for the RWP were allowed to be exceeded.

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e Upon determining that the ladder could not be installed without

entering the drained pool to secure the ladder against the wall, a

worker requested aermission from HP covering work on the refueling

floor, to enter tie pool to continue ladder installation. The

worker was instructed by HP to don a set of paper coveralls over his

full set of protective clothing prior to entering the pool. The RWP

requirements addressed only work on the refueling floor. The RWP was

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not intended for pool entry and the requirements were not adequate

a

for entering the equipment pool and an As Low As Reasonably

Achievable (ALARA) plan was not implemented for entering the

equipment pool when the work scope changed.

Licensee procedure

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OE&RC 0230 also required that radiological survey data be used to

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determine applicable dress, dosimetry, respiratory protection and

special survey requirements for RWPs. These actions were not

performed when the work scope changed for the RWP used by the

workers.

e Licensee procedure OE&RC 0045, ALARA/ Radiation Control Pre job

Briefings Revision 4, required a pre job briefing for entering into

a high radiation area or for performing abrasive work on highly

contaminated areas. The event review determined that a pre job

briefing was not aerformed to cover the work scope for entering the

pool which was a ligh radiation area and the performance of abrasive

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work on highly contaminated areas while using the hammer to install

the ladder.

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e Radioactive contamination surveys were not performed to assess the

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radiological hazards present on the side of the equipment pool prior

to allowing the worker to enter the pool and use a hammer (an

abrasive tool) on the side of the pool. Surveys performed after the

event determined contamination levels on the side of the pool to be

as high as 400 millirad / hour / areas of 100 centimeters squared.

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Also, licensee procedure OE&RC 0120 Routine /Special Airborne

Radioactivity Survey, Revision 14, required samples for airborne

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radioactivity to be performed whenever individuals are working in

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airborne or potentially airborne radioactivity and this action was

not accomplished. The inspector informed the licensee that failure

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to perform adequate contamination and airborne surveys to evaluate

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the concentrations or quantities of radioactive materials as

required by 10 CFR 20.1501 resulted in a failure to identify the

,

potential radiological hazards that were present.

Personnel exiting the posted c r aminated area on the refueling

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floor unknowingly bypassed the

est whole body frisker encountered

on the 98-foot elevation of the keactor Building which risked

further potential spread of contamination down to the whoie body

frisker located on the 20 foot elevation.

Licensee procedure OE&RC-

0110 Personnel Contamination and Decontamination, Revision 20,

requires a whole body frisk at the first frisker encountered after

exiting a contaminated area. The workers were unaware the whole

body frisker on the 98 foot elevation had been in service for

approximately 12 days prior to the contamination event.

>

The inspectors verified that immediate corrective actions had been

accomplished to reclaim contaminated areas. The inspectors

independently reviewed radiological survey documentation identifying the

initial spread of c.ontamination and the surveys for reclaiming the areas

after decontamination. Also, the inspectors verified that other

immediate corrective actions were taken to counsel workers and issue a

plant wide memorandum which identified the event and stressed the

importance of pre job briefings and workers understanding of work

assignments.

The licensee investigation and event assessment was reviewed and

i

discussed with supervisory and management personnel. The inspectors

also reviewed licensee self assessments for two months prior to the

event. Based on this review, the inspectors determined the licensee

conducted an aggressive root cause analysis of the event and determined

the licensee had identified items of substance during recent

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assessments.

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c.

Conclusions

After reviewing the sequence of events and the actions taken by the

licensee, the ins metors determined that there were two violations

associated with t1is event. The first violation involved three examples

of a violation of TS 6.8.1 which requires written procedures be

established, implemented, and maintained covering the activities

recommended in Appendix A of Regulatory Guide 1.33, November 1972. On

July 8, 1996, the licensee failed to implement established procedures

by: (1) not conducting pre-job briefings as required by licensee

procedure OE&RC 0045, ALARA/ Radiation Control Pre job Briefings,

Revision 4, (2) not following RWP requirements as required by licensee

procedure OE&RC-0230. Issue and Use of Radiation Work Permit, Revision

33, and (3) not performing a whole body frisk at the first frisker

encountered after exiting a contaminated area as required by licensee

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3rocedure OE&RC-0110. Personnel Monitoring and Decontamination,

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Revision 20. The failure to implement established radiological control

procedures as recuired by TSs is a violation of regulatory requirements

and is identifiec as VIO 50 325(324)/96-13 06.

The second violation involved a violation of 10 CFR 20.1501(a) which

requires a licensee to make surveys that are reasonable under the

,

circumstances to evaluate concentrations or quantities of radioactive

material: and the potential radiological hazards that could be present.

,

On July 8,1996 during performance of work in the Unit 1 refueling floor

1

equipment 3001, the licensee failed to perform adequate surveys to

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evaluate t1e potential radiological hazards that could be present from

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unknown concentrations or quantities of airborne radioactivity that

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existed in areas of the Unit 1 equipment pool. The failure to perform

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adequate surveys to evaluate the potential radiological hazards that

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could be present is a violation of regulatory requirements (VIO 50-

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325(324)/96 13 07).

4

Based on independent review, the inspectors determined that the

licensee's immediate corrective actions to control the contamination and

to inform the plant workers of the event were adequate.

R1.2 Tour of Unit 1 and Other Radioloaically Protected Areas.

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4

a.

Insoection ScoDe (83725)

The inspectors toured work areas to evaluate radiological controls and

conditions of facilities and equipment for controlling internal

exposures.

b.

Observations and Findinas

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The inspectors toured Reactor Building facilities. Turbine Building, and

the Radioactive Waste Facility. At the time of the inspection,

radiological housekeeping was observed to be good. Radiologically

controlled areas observed were appropriately posted and radioactive

material was appropriately labeled. Continuous air monitors observed in

use were functioning properly and were currently calibrated.

c.

Conclusions

Radiological facility conditions and housekeeping were observed to be

good.

R1.3 Control Room Access

a.

Inspection Scope (71750)

During routine inspection activities. the inspector observed personnel

monitoring from the radiation control area (RCA).

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b.

Observations and Findinas

On August 14, 1996, while performing routine inspection activities the

inspector observed a licensee employee escorting three visiting

personnel as they entered the Unit 2 access for the control room at the

49' elevation. Upon entering the personnel monitor (PMW 2), the

licensee employee monitored clean. However the three visitors were

unsuccessful on two attempts to clear the personnel monitor. The

inspector observed the visitors perform a five-point frisk and then

proceed onto the 49' elevation.

The inspector observed the licensee posting on the personnel monitor.

The instructions direct u)on alarming to note the body location,

remonitor at another fris(er, cover hands and feet if found to be

contaminated, report to personnel decontamination and contact health

physics for assistance.

Upon questioning by the inspector, the licensee

employee indicated that the visitors had hand frisked at below 100

counts above background and was therefore permitted to proceed. During

discussion with licensee management, it was rv M that they were

revising the monitoring policy due to turbine building off gas problems.

During the Unit 2 outage, the practice of performing a five-Soint frisk

was instituted for control room access for the duration of t1e outage.

This was a temporary practice and not part of ordinary station

requirements. Management expectation, as communicated during general

employee training and postings in the area would be upon alarming the

second time to note the area contaminated, cover hands and feet if

necessary, and proceed to personnel decontamination for HP assistance.

A similar issue regarding personnel monitoring was addressed previously

by the NRC staff in IR 325(324)/96 04.

c.

Conclusion

The repetitive nature of control room access challenges, as well as

tolerance of nonconforming access practices by E&RC management was seen

as a weakness.

R8

Miscellaneous Radiation Protection and Chemistry Issues

R8.1 Interim Low Level Radwaste Storaae Facility

a.

Inspection Scooe (71750)

The inspector reviewed the licensee's )lans for an interim low-level

radwaste storage facility (ILLRSF). T11s review included observation of

a Plant Nuclear Safety Committee (PNSC) meeting discussing the proposed

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10 CFR 50.59 evaluation, and a tour of the site location,

b.

Observations and Findinas

The licensee has constructed an ILLRSF because the State of South

Carolina has refused to accept waste from North Carolina. The State of

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North Carolina has not built a regional low level waste disposal site.

The inspector toured the location of the facility. The facility was

located on the owner controlled property near the abandoned cooling

tower structure. The location consisted of a concrete pad surrounded by

a chain link fence.

Sixteen empty concrete vaults were on the concrete

pad for future use.

The 10 CFR 50.59 evaluation was presented to PNSC on August 22, 1996.

The evaluation concluded that the storage of solid waste posed no

unnecessary risk to the general public. The material will not be in a

dispersible form and the dose rates will be sufficiently low such that

the dose to members of the public inside the owner controlled area would

be within regulatory limitations.

Section 11 of the FSAR would need to

be revised to include a description of the ILLRSF.

The evaluation was good and included two 33 references. Two references

listed in the 10 CFR 50.59 evaluation discussed NRC guidance concerning

interim storage. These were NRC IN 90 09. Extended Interim Storage of

Low Level Radioactive Waste by Fuel Cycle and Material Licensees and NRC

SECY 94198, Review of Existing Guidance Concerning the Extended Storage

of Low Level Radioactive Waste. Additionally, the inspector noted that

the ILLRSF did not involve land disposal or storage of high-level waste

such as spent fuel,

c.

Conclusions

The inspector concluded that the licensee has constructed an ILLRSF due

to the unavailability of a low level waste storage facility. The

facility was reviewed under 10 CFR 50.59 evaluation considering

applicable NRC guidance concerning the issues and was adequate.

P1

Conduct of EP Activities

Pl.1 Hurricane Fran

a.

Insoection Scope (71750)

The inspectors reviewed the licensee's actions in response to Hurricane

Fran. This included site preparation, emergency response, and recovery.

b.

Observations and Findinas

On September 4,1996, at 5:35 p.m. a Notification of Unusual Event

(N0VE) was declared due to the issuance of a hurricane warning for the

site. Both units were shutdown on September 5, 1996, in preparation for

Hurricane Fran.

Plant 3rocedure OAI-68, Brunswick Nuclear Plant

Response to Severe Weatler Warnings, requires that the units be in cold

shutdown two hours prior to arrival of hurricane force winds on site.

The licensee's emergency response facilities were activated at 1:00 p.m.

on September 5, 1996. The NRC likewise manned each response center with

the resident inspectors and two additional inspectors dispatched to the

site.

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The inspectors toured the protected area prior to the lock down and

observed that the licensee had taken adequate precautions. The

inspectors noted that trailers had been tied down and miscellaneous

equipment had been removed or secured. They identified that the South

Diesel Building flood door had not been latched and the Service Water

Building flood door had not been closed.

In addition, they noted

several maintenance stanchions located by the service water intake

structure.

Prior to the tour the licensee had informed the inspectors

that all the stanchions had been removed. The inspectors informed the

licensee of their observations. The licensee indicated that the

identified deficiencies would be corrected.

Unit I was in cold shutdown at 2:45 p.m. on September 5, 1996. Unit 2

was in cold shutdown at 4:00 p.m. on September 5, 1996. The hurricane

was originally predicted to make landfall at 2:00 a.m. on September 6,

1996, which coincided with high tide. The hurricane increased in speed

from 12 mph to 16 mph. The actual arrival was on September 5, 1996.

Hurricane force winds of 105 mph with wind gusts to 125 mph were

experienced onsite from 4:45 p.m. until 5:15 a.m.

A lull occurred

around 11:30 p.m. as part of the storm's eye passed near the site. As

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soon as the winds subsided the inspectors toured the plant site. The

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0&M, Unit 1 and Unit 2 Reactor buildings sustained roof damage. The

0&M, TAC, and WCC buildings lost pieces of siding. The inspectors noted

that the licensee had not removed the stanchions which the inspectors

had previously identified. Offsite power was maintained throughout the

storm as well as normal communications. After the National Weather

Service rescinded the hurricane watch, the NOUE was terminated at 8:45

a.m. on September 6, 1996.

During the storm the licensee experienced problems with DC grounds on

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the battery bus.

The licensee suspended security and fire watch rounds

due to the severe weather. This was further reviewed in security

section S1.1.

Most of the evacuation sirens in New Hanover and

Brunswick Counties were lost due to loss of power to the siren.

The Technical Support Center (TSC)/ Emergency Operating Facility (E0F)

emergency diesel generator (EDG) was placed in service at 3:00 p.m. on

September 5,1996, when the Southport feeder was taken off the line.

The TSC/E0F EDG tripped at 3:31 p.m. and the licensee was never able to

load this EDG during the event. The licensee was able to reenergize the

Southport feeder which was able to supply reliable power. The licensee

made provisions to )rovide emergency power in the event the Southport

feeder was lost. T1e inspectors reviewed the plans for emergency power.

The TSC/ EOF EDG had been successfully tested and loaded on September 3,

1996. Subsequent troubleshooting revealed that the EDG output circuit

breaker had failed. The licensee had previously made modifications to

the Soui.hport feeder to improve its reliability as a result of lessons

learned from the March 1993. Loss of Offsite Power event.

The data from the meteorological tower became unreliable around 7:00

p.m. on September 5, 1996, and the site had to rely on wind data from

their offsite meteorological consultants. The licensee was unable to

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.

22

obtain current wind information. Their system provided wind speed data

which was averaged over 15 minutes.

Following the hurricane the licensee established a Recovery Team. The

'

Unit I readiness for restart was reviewed by the PNSC that recommended

j

restart on Seatember 9, 1996. The Unit 2 readiness for restart was

,

reviewed by t1e PNSC on September 10, 1996, which recommended restart on

September 11, 1996.

The inspector attended the Unit 2 restart PNSC meeting and reviewed the

items discussed.

Independent walkdowns of the units were also conducted

by the inspectors on September 9, 10, and 11, 1996. Only minor items

were identified and discussed with licensee management. On September 7

,

and 8, 1996, meetings were held between FEMA, the licensee, and

!

Brunswick and New Hanover counties. The licensee management presented

their self-assessment to FEMA focusing on the return to service of all

the sirens.

FEMA completed their review of the emergency planning zone

on September 8, 1996. The units were restarted and synchronized to the

grid on September 10 and 13, 1996, without any adverse impact from the

storm.

c.

Conclusion

The inspectors concluded that the licensee's readiness for the storm's

arrival was prompt and thorough. The licensee executed their emergency

,

plan without any significant problems. The recovery team conducted a

good assessment of the site's readiness to restart.

P4

Staff Knowledge and Performance in EP

P4.1 Operator Offsite Dose Calculation

a.

Insoection Scoce (71750)

As a result of a question with offsite dose calculation arior to

activation of the EOF and the TSC at another facility, t1e inspector

reviewed the licensee's ability to assess offsite dose calculation prior

to EOF and TSC activation.

b.

Observations and Findinas

The inspector discussed calculation of offsite dose with the licensee

and determined that procedures were in place for onshift calculation of

offsite dose. The inspector reviewed senior reactor operator training

documents and an active standing instruction that showed satisfactory

dissemination of requirements to onshift staff. This was demonstrated

upon inspector questioning of licensed operators on different shifts

concerning offsite dose calculation. The inspector found that the

operators were aware of the proper procedures, and the instrumentation

required to obtain needed data to perform the calculation. The

inspector observed a demonstration of the computer program used in the

.

.

-

--

-

_ _ _ - -

-

- .

.

.

23

control room and the E0F to determine offsite dose. No concerns were

identified,

c.

Conclusion

The licensee has the capability to compute offsite dose by the onshift

operators.

The operators questioned were knowledgeaWe about

3rocedures

needed and the related instrumentation required to determine t1e offsite

dose.

S1

Conduct of Security and Safeguards Activities

'

S1.1 Hurricane Fran

,

a.

Insoection Scope (71750)

The inspectors reviewed the licensee's security actions taken in

response to Hurricane Fran. These actions included the suspension of

outside security rounds and firewatches.

b.

Observations and Findinas

On September 4,1996, at 5:35 pm, a hurricane warning was issued for the

area surrounding the Brunswick plant. On September 5,1996, at 1:00 pm,

the licensee activated its emergency response facilities in preparation

for the arrival of hurricane conditions on site. At 5:21 pm, on

September 5,1996, the licensee made a one hour non emergency

notification to the NRC in accordance 10 CFR 50.72(b)(1), that due to

,

the severe weather conditions the site has suspended periodic 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

security rounds of the protected area fence line and external vital

areas. Additionally in the notification, the licensee also suspended

roving fire watches until the severe weather subsides. The notification

stated that these actions were taken in accordance with the provisions

of 10 CFR 50.54(x) and (y).

At 8:20 )m, the licensee made a 10 CFR 50.72(a)(1)(i) notification to

report tlat an Unusual Event had been declared based on security

degradations caused by Hurricane Fran. Security camera deficiencies

were encountered as a result of Hurricane Fran. Appropriate

compensatory actions were taken and full security measures were re-

established by 4:51 am, on September 6,1996.

During the time of the suspended tours, no challenges to vital areas

occurred, and security cameras were in operation. Additionally, both

fire detection and automatic suppression systems were operable during

this time period in all areas of the buildings.

c.

Conclusions

The inspectors reviewed the licensee's actions taken in accordance with

10 CFR 50.54(x) and (y) to ensure the safety of the members of the

security force during Hurricane Fran. The inspector concludes that the

---

- -

.

..

. - - -

-

.

-

..

d

-

.

.

24

actions taken were prudent and reasonable given the hurricane conditions

with winds in excess of 115 mph present on site during the storm. The

,

inspectors concluded that the deviation from the TS requirement was

reviewed, discussed and properly dispositioned in accordance with the

!

requirements of 10 CFR 50.54(x) and (y). The inspectors observed that

as soon as weather conditions permitted the licensee quickly resumed the

suspended activities and verified that no problems occurred during the

time of the suspended tours. The inspectors concluded that the licensee

adequately implemented the requirements of the security plan and took

,

a)propriate actions given the conditions on site to ensure the safety of

>

t1e security force members.

V.

Manaoement Meetinas

,

XI

Exit Meeting Summary

,

The inspector presented the inspection results to members of licensee

management at the conclusion of the inspection on September 20, 1996.

Post inspection briefings were conducted on September 13, 1996 and

-

September 13, 1996. The licensee acknowledged the findings presented.

i

The licensee did not identify any materials used during the inspection

j

as proprietary information.

I

f

,

.

.

25

PARTIAL LIST OF PERSONS CONTACTED

Licensee

G. Barnes, Manager Training

A. Brittain, Manager Security

W. Campbell, Vice President Brunswick Steam Electric Plant

R. Foy, Superintendent, Radiation Protection

N. Gannon, Manager Maintenance

J. Gawron, Manager Nuclear Assessment

D. Hicks, Manager Regulatory Affairs

W. Levis, Director Site Operations

R. Lopriore, General Plant Manager

J. Lyash, Brunswick Engineering Support Section

K. McCall, Supervisor, Operator Initial Training

C. Pardee, Manager Operations

R. Schlichter, Manager Environmental and Radiation Control

M. Turkal, Supervisor Licensing and Regulatory Programs

H. Wall, Training Supervisor

Other licensee employees or contractors included office, operation,

maintenance, chemistry, radiation, and corporate personnel.

R. Aiello

E. Brown

P. Byron

D. Forbes

M. Janus

C. Patterson

_ _ _

_

_ -_.

,

e

26

INSPECTION PROCEDURES USED

IP 37551:

Onsite Engineering

IP 40500:

Effectiveness of Licensee Controls in Identifying, Resolving, and

Preventing Problems

IP 41500:

Training and Qualification Effectiveness

IP 42700:

Plant Procedures

IP 61726:

Surveillance Observations

!

IP 62707:

Maintenance Observations

IP 71001:

Licensed Operator Requalification Program Evaluation

IP 71707:

Plant Operations

IP 71750:

Plant Support Activities

IP 83725:

Occupational Exposure During Extended Outages

IP 84750:

Radioactive Waste Treatment and Effluent and Environmental

IP 92901:

Followup - Operations

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

50 325(324)/96 13 01

VIO

Equipment Clearance Error (paragraph 04.1)

50 325(324)/96 13 02

VIO

Failure to Complete the LSR0 Training Program

Prior to Taking the LSR0 Audit Examination

(paragraph 05.1)

50 325(324)/96 13-03

NCV

Failure to Provide Complete and Accurate

Information as Required by 10 CFR 50.9,

Completeness and Accuracy of Information

'

(paragraph 05.1)

50 325(324)/96 13 04

IFI

A0R Makeup For Licensed Operators (paragraph

05.1)

50 324/96 13 05

VIO

Failure to Correctly Update ARM Alarm Setpoint

(paragraph E7.1)

50 325(324)/96 13 06

VIO

Failure to Follow Licensee Radiological Control

Procedures Required by TS 6.8.1 (paragraph R1.1)

50 325(324)/96 13 07

VIO

Failure to Perform Surveys Commensurate with the

Hazards Present (paragraph R1.1)

Closed

50 325(324)/96-10-01

URI

Determine if Auxiliary Operators Have Been

Adequately Trained per TI-104, Auxiliary

Operator OJT Checklist (paragraph 08.1)

_ _ . .

o

e

27

Discussed

50 325(324)/96-08-01

NCV

Failure to Properly Implement Drywell Venting

Procedure (paragraph 04.2)

50 325(324)/96 05 02

URI

FSAR Discrepancies (paragraph E7.2)

"

1

4

j