ML20062G394

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Insp Repts 50-324/90-41 & 50-325/90-41 on 901002-1104. Noncited Violation Noted.Areas Inspected:Surveillance Observation,Operational Safety Verification,Initial Response to Onsite Events,Onsite Review & Followup
ML20062G394
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 11/19/1990
From: Carroll R, Prevatte R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20062G388 List:
References
50-324-90-41, 50-325-90-41, NUDOCS 9011290162
Download: ML20062G394 (17)


See also: IR 05000324/1990041

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                                                         UNITED STATES
                                               NUCLEAR nEGULATORY COMMISslON
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                                                            REGION 11
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                                                    101 MARIETTA STREET, N.W.
       *                'r                           ATLANT A, GEORGI A 30323
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           Report Nos.:         50-325/90-41 and 50-324/90-41
           Licensee:         Carolina Power and Light Company
                             P. O. Box 1551
                             Raleigh, NC 27602
           Docket Nos.:         50-325 and 50-324                       License Nos. DPR-71 and DPR-62
           Facility Name:          Brunswick 1 and 2
            Inspection Conducted:           October 2 - November 4, 1990
           Lead Inspector:            .     IdxM[M                            I        ///O/fC
                                 R. L. Prevat C ~                g        g           Date Signed
           Other Inspectors:            W. Levis
                                        D. J. Nelson
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           Approved Bh: . E. C/orroll, Acting Section Chief                           Date 5figned
                              Reactor Projects Branch 1
                              Division of Reactor Projects
                                                            SUMMARY
           Scope:
           This routine safety inspection by the resident inspectors involved the areas of
           maintenance observation, surveillance observation, operational safety verifica -
           tion,-initial response to onsite events, onsite review committee, onsite

, , followup of. licensee event reports, review of 10 CFR Part 21 items, and action

           on previous inspection findings.
           Results:-
           In the areas inspected, no programmatic weaknesses or significant safety
           matters were identified.
         -A non-cited violation for the failure to place a channel of the reactor
           protection' system scram discharge volume water level high trip system in the
           trip condition after exceeding the Technical Specification two hour time limit'
           for having this equipment in test was identified, paragraph 7.a.
           Two minor deficiencies involving the lack of attention to detail by the contrml
           room operators were noted.during routine plant tours, paragraph 4.
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                :A-review of the unit trip-and degraded voltage event that occurred on
                 September- 27,1990,' identified four items where the inspector did not have
                 sufficient information and/or. the necessary resources to fully evaluate. These                        "
                                                                                                                          .
                - items will be referred to NRR for further review, paragraph 7.c.
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                 Unit 1 was in a refueling outage during the reporting period. Unit 2 experi-                            '
                 encedian automatic trip on October 12 as the result of a blown fuse in-the
 '-              feedwater level' control' system, paragraph 5. The unit was restarted on
                 0ctober- 18,:1990. The~ licensee appeared very conservative-in their approach to
                 unit restart and reduced- power twice during equipment malfunctions _ that may
                 have placed the unit at risk.
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                                                                  REPORT DETAILS
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                    1.             Persons Contacted
                                  Licensee Employees
                                *K. Altman, Manager - Regulatory Compliance
                                   F. Blackmon, Manager - Radwaste/ Fire Protection
                                   S. Callis, On-Site Licensing Engineer
                                  T. Cantebury, Manager -- Unit 1 Mechanical Maintenance
                                *G. Cheatham, Manager - Environmental-& Radiation Control
                                  M. Ciemnicki, Security
                                   R. Creech, Manager - Unit 2 I&C Maintenance-
                                   J. Cribb, Manager - Quality Control (QC)
                                *W.       Dorman, Manager - Quality Assurance (QA)/(QC)
                                *M.-Foss, Supervisor - Regulatory-Compliance
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                                   V. Grouse, Employee Relations
                                  'J. Harness, General' Manager - Brunswick Steam Electric Plant
                                   W ' Hatcher, Supervisor - Security
                                   R. Helme, Manager - Technical Support
                                   J.-Holder, Manager-OutageManagement& Modifications:(OM&M)
              '
                               '*M. Jones,. Manager - On-Site Nuclear Safety - BSEP
                                   R. Kitchen, Manager:- Unit 2 Mechanical' Maintenance
                               t*B. Leonard, Manager - Training
                                *J. Leviner, Manager - Engineering Projects
                                   J.E McKee, Manager' -QA
      ',                      (*J. Moyer, Technical. Assistant to Plant. General' Manager                      ,
                                *P. Musser, Manager - Maintenance Staff
                                        .
 n                                 B.'Poteat,? Administrative: Assistant to Plant General Manager
                                   R.-Poulk,-Manager -. License Training-
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                              ' *J. Simon, Manager L- Operations Unit 1             .
                                   W. Simpson,-Manager - Site Planning and Control-
                                   S. Smith; Manager -Unit 1 1&C Maintenance.
                                                                      -
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                                 ' R.L Starkey, Vice President -' Brunswick Nuclear Project
                                   R. Tart,-Manager ,0perations; Unit-2       .
                                   J.'Titrington,. Manager ,0perations, Staff
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                                *R. Warden, Manager         Maintenance
                                   B. Wilson,: Manager - Nuclear Systems Engineering                         -l
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                                L0ther licensee employees contacted included construction craftsmen,
h                                : engineers, . technicians, operators,toffice personnel, and security force
+                                  members.-
                                * Attended:the' exit interview'                                              g
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                                   Acronyms:and initialisms used in the report are listed in the last:
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                                   paragraph.
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          2.  Maintenance Observation (62703)
              The inspectors observed maintenance activities, interviewed personnel,
              and reviewed records to verify that work was conducted in accordance with
              approved procedures, Technical Specifications, and applicable industry
              codes and standards. The inspectors also verified that: redundant
              components were operable; administrative controls were followed; tagouts
              were adequate; personnel were qualified; correct replacement parts were
              used; radiological controls were proper; fire protection was adequate;
              quality control hold points were adequate and observed; adequate
              post-maintenance testing was performed; and independent verification
              requirements were implemented. The inspectors independently verified that
              selected equipment was properly returned to service.                       ,
              Outstanding work requests were reviewed to ensure that the licensee gave
              priority to safety-related maintenance. The inspectors observed / reviewed
              portions of the following maintenance activities:
                    90-ALUC1        2C RBCCW Pump Rebuild
                    90-ASYH1        MSL Rad Monitor B Power Supply Changeout
                    90-PME411       Route on 2-CAC-1262
                    90-PZI395-      Sample Pump Replacement for 2-CAC-4409
                    90-WFI414       Rosemount ATTU Output Voltage Check
              Violations and deviations were not identified.
          3.  SurveillanceObservation(61726)
              The inspectors observed surveillance testing required by Technical Speci-
              fications. .Through observation, interviews, and record review, the
             .. inspectors verified that: tests conformed to Technical Specification
              requirements; administrative controls were followed; personnel were
              qualified; instrumentation was-calibrated; and data was accurate and
              complete. The inspectors independently verified selected test results and
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              proper return to service of equipment.
              The inspectors witnessed / reviewed portions of-the following test
              activities:
                    1-MST-IRM12W     IRM Channels B, D, F, H Functional Test
                    1-MST-SRM22R     SRM Channels A and C Channel Calibration
                    PT-7.1.1.a       Core Spray Injection Check Valve Operability Test
                    PT-20.7.2        1-E11-F050B LLRT
              Violations and deviations were not identified.

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          4.  Operational Safety Verification (71707)
             -The inspectors verified that Unit 1 and Unit 2 were operated in compliance
              with Technical Specifications and other regulatory requirements by direct
              observations of activities, facility tours, discussions with personnel,
              reviewing of records and independent verification of safety system status.
              The inspectors verified that control room manning requirements of 10 CFR
              50.54 and the Technical Specifications were met. Control operator, shift
              sup?rvisor, clearance, STA, daily and standing instructions, and
              jumper / bypass logs were reviewed to obtain information concerni .g operating
              trends and out of service safety systems to ensure that there were no
              conflicts with Technical Specification Limiting Conditions for Operations.
              Direct observations of control room panels and instrumentation and recorder
              traces important to safety were conducted to verify operability and that       -
              operating parameters were within Technical Specification limits. The
              inspectors observed shif t turnovers to verify that system status continuity
              was maintained. The inspectors verified the status of selected control-
              room annunciators.
              Operability of a selected Engineered Safety Feature division was verified
              weekly by ensuring that: each accessible valve in the flow path was in
              its correct position; each power supply and breaker was closed for
              components that must activate upon initiation signal; the RHR subsystem
              cross-tie valve for each unit was closed with the power removed from the
              valve operator; there was no leakage of major components; there was proper
               lubrication and cooling-water.available; and conditions did not exist
              which could prevent fulfillment of the. system's functional requirements.
               Instrumentation essential to system actuation or performance was verified
              operable by observing on-scale indication and proper instrument valve
              lineup, if accessible.
              The inspectors verified that the licensee's health physics

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              policies / procedures were'followed. This included observation of HP
              practices and a review of area. surveys, radiation work permits, postings,
              and instrument calibration.
              The inspectors verified by general observations that:      the secarity

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              organization was. properly manned and security personnel were capable of
              performing- their assigned functions; persons and packages were checked
               prior to entry into the PA; vehicles were properly authorized, searched
              and escorted within the PA; persons within the PA displand photo identi-
               fication badges; personnel in vital areas were authorized; effective
              compensatory measures were employed when required; and security's response
               to threats or alarms was adequate..

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              Ine inspectors also observed plant housekeering controls, verified
               position of certain containment isolation ' alves, checked clearances, ard    ,
               verified the operability of onsite and of' site emergency power sources.

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            An inspector found two minor control room deficiencies on Unit 2 not
            discovered by operators. On October 19, 1990, at approximately 7:30 a.m.,
            the control switch key was found inserted in the control switch for Core
            Spray Valve F001A, Su)pression Pool Suction Valve.      Important component
            control switches on tie control board are equipped with locks that require
            keys for operation to preeent inadvertent manipulation. Dummy keys are
            normally inserted with the color coded real keys attached. The valve was
            in its correct position, but had been manipulated for the performance of a
            surveillance test on the previous shift. Following the test, the key was
            not switched back. Prior to the inspector's discovery, three control
            operators and one trainee had performed their board walkdown without
            detecting the error. The inspector informed the operators of the problem
            and the key was promptly switched.
            On October 24, 1990, the inspector observed that one of six APRM GAFs
            indicated 0.00 on the 7:00 a.m. process computer P-1 printout. Normal GAF
            values are 0.98 to 1.00. The printout also flagged APRM B as a failed
            sensor. The process computer calculates the GAF from a ratio of calculated
            power and APRM indicated power.      The 0.00 value observed by the inspector
            indicates that a meaningful GAF could not be calculated due to a problem
            with calculated or indicated power. The inspector reviewed previous
            hourly P-1s, which also indicated GAFs of 0.00 back to 3:00 a.m., which
            had a 4.17 value. When questioned, the on-duty-operators were unaware of
            and could not explain the discrepancy. Et 'ntually the operators determined
            that a surveillance test prior to 3:00 a.m. for APRM Channel B caused the
            computer to cease its " scan" of APRM B due to inconsistent values calcu-
            lated when the APRM output was manipulated during the test. The APRM-was
            placed back in service following the surveillance test, but the computer
            " scan" was not reset. This did not affect the operability of the APRM,
            and no other indications in the control room were affected.
            GAF values are the most consistent indication of APRM reliability.
            Although the APRM trend chart recorders would also indicate an actual APRM
            problem, the recorders cannot trend all six APRM channels simultaneously.
            Therefore, it is important for operators to monitor the GAFs.
            These two examples, while not safety significant, indicate that continued
            diligence by operators-is needed in monitoring control room indications.
            Violations and deviations were not identified.
         5. Initial Response to Onsite Events (93702)
            Unit 2-Scram
            Unit 2 was operating at 100 percent power on October 12, 1990, when a fuse
            blew in the FWLCS resulting in a loss of power to a . number of components
            in the control circuit. The loss of power gave the appearance of low
            reactor water level which caused an increased demand signal to the RFPs
            and a trip' signal to the reactor recirculation pump runback circuits.      The

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          "A" RFP also locked up due to the loss of power resulting in the "B"   RFP
          responding to the master controller demand for increased feed flow.
          Twenty-six seconds after the fuse blew an actual high water level
          condition was reached which caused a turbine trip and reactor scram.
          The lowest reactor water level reached was approximately 117 inches.
          Group 2, partial Group 3 and Group 6 isolations were received. Reactor
          recirculation pumps tripped due to the low level condition. RCIC auto
          started and injected and HPCI auto started but did not inject due to the
          short duration of the level transient. HPCI was subsequently used to
          raise water level to the normal band.
          During post trip recovery, the operators had difficulty in placing a RFP
          in service. Because of the loss of power to the FWLC circuit, the master
          controller was still demanding 100 percent output. When 2B RFP was placed
          back in service, in automatic, the pump increased speed to 5700 RPM and
          discharge pressure increased to 1700 psig. With the flowpath isolated due
          to feed pump trip recovery actions, the 4 and 5 feedwater heater relief
          valves lifted and began releasing steam into the feedwater heater room.
          When steam was reported as being released in these rooms, the feedwater
          heater inlet valves were shut securing the leak. The FWLC system was also
          placed in single element and selected to channel B, which then restored
          level feedback to the controller.
        :The fuse that blew in the' FWLC circuit was a Gould Shawmut A25Z? fuse and
          was similar to the fuse which blew in this circuit on August 16, 1990,
          that also resulted in a reactor scram. The licensee has subsequently
          replaced the Gould Shawmut fuses in the FWLC circuitry with Bussman MIN
          fuses which are the type installed in Unit 1.    The Gould Shawmut fuses
          were installed as an Appendix R modification to provide separation between
          safe shutdown circuits and other associated circuits of concern.
          Subsequent review by the licensee documented in EER 90-0262, October 14,
         -1990, determined that separation of this circuit was not required.
                                                                                      .
          The inspector will review the licensee's corrective actions taken with
          respect to.the feed pump operation and the fuse failure when the LER is
        . issued.
    6.    Onsite Review Committee-(40700)
          The inspectors attended selected Plant Nuclear Safety Conrittee meetings
          conducted during the period. The inspectors verified that the meetings
          were conducted in accordance with Technical Specification requirements
          regarding quorum membership, review process, frequency, and personnel
          qualifications. Meeting minutes-were reviewed to confirm that
          decisions /recomendations were reflected in the minutes and followup of-
          corrective actions was completed.
          Violations and deviations were not identified.
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                        7.    Onsite Followup of Licensee Eveat Reports (92700)
                              The below listed LERs were reviewed to verify that the information
                              provided met NRC reporting requirements. The verification included
                              adequacy of event description and corrective action taken or planned,
                              existence of potential generic problems, and the relative safety
                              significance of the event. Onsite inspections were performed and
                              concluded that necessary corrective actions have been taken in accordance
                              with existing requirements, license conditions, and commitments, unless
                               otherwise stated,
                               a.   (Closed) LER 1-90-16, Operation Prohibited by Plant Technical
                                    Specifications During SDV Maintenance and Surveillance Activities.
                                    On September 17, 1990, the Unit 1 SF authorized the performance of
                                    IMST-RPS27R, RPS Scram Discharge Volume High Water level Channel
                                    Functional Test and Channel Calibration. In conjunction with the
                                    test, the SF also authorized work to be performed in accordance with
                                    the instructions of WR/JO 90-AMCT1, which replaced the electronic
                                    printed circuit board for level switch 1-C11-LSH-4516C. The SF
                                    entered a tracking LC0 for this work believing that only one input to
                                     channel A2 would be disabled.
                                     Subsequent review of this work on September 20, 1990, by a different
                                      shift foreman, revealed that the MST disables the trip function of
                                      channel A2 during a portion of the test. A two hour time limit is
                                      allowed by Technical Specification 3.3.1 for a channel to be disabled
                                      during surveillance testing provided that the other channel in the
                                       same trip system is operable. After the two hour period, the channel
                                      must be returned to operable status or placed in the tripped
                                       condition. Because of the maintenance actions performed on
                                        1-C11-LSH-4516C, the two hour time limit was exceeded during
                                        performance of the MST on September 17, 1990. .The SF did not place
                                        the channel in the tripped condition, as required by Technical
                                        Specification 3.3.1, because he did not realize that the A2 channel
                                        was disabled during the testing. The channel was inope aole for 2
                                         hours and 20 minutes,
                                          in their investigation..the licensee noted several contributing
                                          conditions. First, it is not appropriate to perform corrective
                                         maintenance while performing surveillance tests. The two hour time
                                          period allowed by Technical Specifications for ' inoperable channels
                                          applies. to surveillance testing and not corrective maintenance. A
                                           Standing Instruction was put in place until permanent procedure
                                           revisions are made that prohibit corrective maintenance to be
                                           performed during surveillance testing under the two hour time
                                           constraint. In addition, the MSTs will be revised to enhance the
                                            specific instruments that will be made inoperable by jumper, and
                                             training for the appropriate people will be performed.
                                            The failure to place channel A2 of the RPS SDV water level high trip
                                             scram signal in the tripped condition is a violation of TS 3.3.1:-
                                              Failure to Place Channel- A2 In the Tripped Condition, (325/90-41-01).
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                                  This licensee identified violation is not being cited because
                                  criteria specified in Section V.G.1 of the NRC Enforcement Policy
                                  were satisfied.
                             b.   (Closed)LER 1-90-017, Unit 1 High Pressure Scram During Performance
                                  of Turbine Control /Stop Valve Tightness Test. A unit 1 scram, from
                                  high pressure, during the ierformance of Turbine Control /Stop Valve
  m                               Tightness Test, occurred oi September 27, 1990, and was discussed in
                                  inspection report 90-37. At the time of that report, the licensee
                                  was still investigating tne event and preparing a LER. The investi-
                                  gation was subsequently completed and LFR 90-017 was issued on
                                  October 26, 1990. The LER provided a description ci the events
                                  surrounding this-occurrence and contained recommendations to prevent
                                  recurrence. This event occurred with the unit at approximately c2
                                  percent po;:er while in the process of shutting down for a refueling
                                  outage. The licensee had started the planned Periodic Test (PT)
                                  40-2-10, Turbine Control /Stop Valves (TCV/TSV) Leak Tightness Testing.
                                  The event occurred due to erroneous procedural guidance provided by
                                   the vendor, General Electric, in GEK-25406A and defective switches on
                                   the TSVs, which allowed the TCVs to open when the TSVs were closing.
                                   The turbine BPV's open demand signal was limited by the maximum
                                   combined flow circuitry of the turbine control system. The closure
                                   of the TSVs without the BPVs being able to open caused reactor
                                   pressure to increase to the SCRAM setpoint. A detailed licensee
                                   review of this event has determined that this proceaure contained
                                   weaknesses which are applicable to both nuclear and fossil plants
                                   which have used this procedure / guideline to develop their plant
                                    tests. The licensee had made this information available to other
                                   utilities through " Network" and have indicated that GE may issue an
                                    information letter on this item,
                               c.   (Closed) LER 2-90-15, Unit 2 Reactor Scram-Due to Loss of Excitation
                                    on Main Generator. A' scram occurred on Unit 2 on September 27, as a
                                  . result of the loss of excitation on the main generator. This item
                                    was also discussed in inspection report 90-37, and the licensee was
                                    investigating this event at the close.of the previous inspection
                                    period. The licensee subsequently completed their investigation into
                                    the event and provided the details in LER 90-015, dated October 26,
                                     1990. The inspectors have reviewed the LER and other licensee docu-
                                    mentation associated with the event and discussed this matter.with
                                     NRR. Based on this review and discussion with the licensee and NRR,
                                     the inspectors are unable to determine the following: -(1) was the
                                     capacity and. stability of the offsite power system prior to and
                                     immediately after the Unit 2 trip adequate to provide acceptable
                                     voltages to handle a design basis event in Unit' 2 and a safe shutdown
                                     on Unit 1; (2) does the licensee's loss of voltage protection system
                                     (relays). which only sheds the safety-related equipment off the "E"
                                     buses, provide- adequate protection for system voltages less1 than the
                                     setpoint of the degraded voltage relays; (3) if the offsite power
                                     voltage drops to a level that is inadequate to start safety-related
                                      loads, will the 10.5 second degraded voltage relay time delay result
                                      in a delaying safety bus transfer to the diesel generator such that
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                       the plant may be outside the boundary of this safety analysis; and
                       (4) does CP&L provide adequate direction and guidance to system load
                       dispatchers to ensure that adequate voltage is maintained at all
                       nuclear units? These items will be referred to NRR for review.
                       Pending the outcome of the above, these items will be tracked as an
                       inspector followup item: Adequacy of Offsite Power, (325,324/90-41-02).
               One e-cited violation was identified.
          8.   10CFRPart21 Items (36100)
                (OPEN) 325,324/P2188-01 - Worn Shaft Gear Failures in Size 2 Limitorque
               Actuators and Also in Fisher Supplied H3BC Actuators. The inspector
                discussed this item with the licensee. A review of licensee records could
                not determine that this report had ever been received. They contacted
                Limitorque who verified that the information had been provided, so it was
                apparently lost. The licensee has entered this item into FACTS and has
                assigned responsibility for investigation and resolution. This item will
                be reviewed further as information becomes available.
                 (CLOSED) 325,324/P2188-04 - Reinstalling Foxboro Controller Circuit Cards
                May Cause 100 Percent Output and Subsequent Transient to Occur. This
                 controller has been identified in BWR Recirculation Flow Control System
               -DCS-88080301. This Part 21 was sent by the Foxboro Company to the Perry
                 Nuclear Power Plant,      it related to SPEC 200, Model 2AC-D+44 controller
                  card with its associated 2AX+RM removable manual card. This notice was
                  not sent to Brunswick since they do not use these units in their
                  recirculation flow control system. A review of parts and installation by
                  the licensee has verified that these units are not installed or used in
                  spare parts at Brunswick.
                  (CLOSED) 325,324/P2189-01 - Brown Boveri K-Line, K-225 Through K-2000
                  Circuit Breakers Delivered Prior to 1974 Had Rebound Spring Added to Slow
                  Close In. This item identified that testing had discovered that the above
                  breakers may fail to function properly in that persistent sine dwell
                  vibration could occasionally cause the sicw close bar-to move into-a
                   position such that the breaker, when called on to close, could slow close
                   rather than closing normally. Adding a rebound spring to the slow close
                  ' lever will prevent the slow close bar from vibrating to the undesired
                   position. Brunswick was identified as a plant that had received shipment
                   of these breakers. A survey by the licensee found that 10 electrically
                   operated breakers of this type were installed in the plant. Substations
                   3L and 4L located in the hot machine shop have K-1600 incoming main
                   breakers. These units were manufactured in 1972 and do not contain
                   rebound springs but are used in non-safety applications to provide power
                 .to the warehouse, maintenance shops and office buildings. Emergency
                    substations ES, E6, E7, and E8 were found to have K-3000 breakers and the
                    Part 21 does not apply to the breakers. The four remaining breakers are
                    installed as crosstie breakers on substations ES, E6, E7, and E8. These
                  .are K-1600 breakers manufactured before 1972 and do not contain rebound
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            spri ngs ~. However, these breakers are administratively controlled in the
            racked out position and verified racked out as part of normal system
            surveillance testing. The breakers may be closed at the discretion of
            the shift supervisors when both units are in mode 4 or 5 and other TS
            requirements are met. No credit is taken in the accident analysis for use
            of these tie breakers. Based upon the above, the licensee discovered that
            the use of these components at Brunswick does not pose a substantial
            safety hazard and, therefore, is not reportable under 10 CFR Part 21.
            Since this defect would only occur under seismic event conditions and the
            components are not used for safety applications, the licensee does not
            have any current plans to install recommended springs in the substations
            used for the warehouse, maintenance shop, and office buildings. The
             licensee plans to purchase and install the springs in the crosstie
             breakers for substations ES, E6, E7, and E8 at the next scheduled
            maintenance period after receipt of the springs.
              (CLOSED) 325,324/P2189-05 - PT-21/ Germane to Safety from GE:
              Susceptibility of Weld Between Core Spray Line and Thermal Sleeve to
              IGSCC. GE recommends that welds be included in IE Bulletin 80-13
              surveillance. This item was evaluated by GE and the licensee and
              determined to be germane to safety, but not reportable. The licensee has
              implemented the vendor recommendations and included this item in their
              surveillance program to be tested each refueling outage under Periodic
              Test, Core Spray /Feedwater Visual Examination, PT-90.1, and reported under
               IEB 80-13. The iaspector verified that these reports had been submitted
              as required.
               (CLOSED) 325,324/P2189-06 - PT-21/ Germane to Safety from GE:                        Concerns
              with Core Neutron Flux Monitoring and Reactor Protection During Refueling.
              This item was the result of NRC questioning the conservatism cf
               center-spiral reloading because the SRMs were not on scale and, therefore,
               not monitoring neutron flux changes during a refueling at the Brown's
               Ferry Plant. GE performed an evaluation of this event and concluded that
               this event did not-constitute a substantial safety hazard and was not
               reportable under the context of 10 CFR Part 21. However, they oid conclude
               that this issue was germane to safety. Based on the above, RICSIL No. 039
               was issued by_GE on February 10,-1989, to alert BWR owners that interim
                recommendations would be provided. These-interim recommendations were:
                (1) that during refueling, the neutron monitoring system should be capable
                of continuously monitoring changes in neutron flux in the region of the
                core'where fuel is being loaded or control rods are being removed to
                provide operators with indications of an approach to criticality; (2)'that
                the
                scramRPS   should
                         based  on be inputs     capable at all
                                                    from the    times of
                                                             neutron  flux    reliably. initiating)a
                                                                                detectors;           reactor
                                                                                             and (3 that the
                recommendations of SIL 372 and SIL 68 should be followed when refueling
                 interlocks are bypassed. The inspector reviewed the licensee's Engineering
                Evaluation Report (EER) 89-0022, dated January 16, 1989, that evaluated
                 this event and the vendor recommendations, the licensee's Refueling Fuel
                 Handling Procedure FH-11, Volume IX, Revision 41, and Engineering Procedure
                 Guidelines for Prepara+1on of Core Component Sequence Sheets, ENP-24.12,
                                                                                                                .
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                                                 10
            Volume XX, Revision 8, to verify that the vendor recommendations had been
            implemented. This review indicates that Procedure FH-11 provides
            Administrative Control and direction over core reloads, that all control
            rods will be fully inserted during fuel movement, that the source range
            monitors will be operable and providing on scale indications, that
            refueling interlocks will .be operable and not bypassed or jumpered out,
            and that the core loading will progress in a sequence which ensures that
            the SRMs have accurate indication of changes in neutron levels. These
            procedures, therefore, implement the vendor recommendations and appear to
            be satisfactory. EPRI is currently conducting a study on this issue.     It
            is anticipated that this study will be completed in late 1990. The
            licensee has indicated that they will review and implement the
            recommendations of that study as appropriate to the Brunswick Plant.
            (CLOSED) 325,324/P2189-18 - SMB Actuators Found to Have Melamine Torque
            Switches That Undergo Post Mold Shrinkage and Cause Cam Binding. Melamine
            Torque Switches Found to be Not Qualified. The licensee reviewed this
            item and determined it to be applicable to BSEP. A decision was made to
            replace the applicable torque switches on PCIS valves during the 1989-90
            refueling outage for Unit 2 and on Unit I during its refueling outage in
            1990-91.- The remaining torque switches were scheduled for replacement
            when routine maintenance is performed on the remaining valve actuators
            with all replacement work completed by July 3,1992. The inspector
            reviewed the completed work request for PCIS replacement accomplished on
            Unit 2 during the past outage, and the work scheduled for Unit 1 during
            the current outage. The listing of work scheduled under the routine
            maintenance program for the remaining torque switches was also reviewed.
            It appears that the licensee has determined which torque switches require
            replacement and have the program needed to complete these activities
            underway with an established completion date.
             (CLOSED) 325,324/P2189-12 - PRE-1981 SMB-000 and PRE-1976 SMB-00 Cam Type
            Torque Switches Can Fail as a Result of Stationary Contact Screws
            Loosening on Side of Torque Switches That Had Fiber Spacers. Two failure
            modes were reported. The first type failure resulted when one of the
            screws in the contact bridge came loose resulting in premature tripping of
            the torque switch. The second failure resulted when both stationary
            contact screws loosened and the contact bridge raised with the contact
            fingers maintaining continuity on the torque switch. The licensee's
            evaluation concluded that no events of this nature have occurred at BSEP
            and, due to the low number of failures reported, concluded that the_ safety
             significance was low. A licensee's review of safety-related SMB-00 and
            SMB-000 valves at BSEP determined that these switches, which were made of
            melamine or ahenolic materials, had been or were:in the process of being
            replaced wit 1 new fiberite torque switches as a result of 10 CFR 21.89-18.
            The remaining SMB-000 and SMB-00 torque switches-that were made of
            fiberite, were: verified as having been replaced since 1985; with the
            exception of one switch,1-E21-F001A-M0, that is planned to be worked
            under Work Request 89-AZIA1.     The new torque switches and any SMB-000
             purchased since 1980 and SMB-00 switches purchased since 1976, do not
             include fiber spacers and do not have this problem. Based on the above,
       - - .                              _ _ _ . _ . . . . _ . .          ..
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                                                                          11
                               it appears that the licensee has identified all equipment affected by this

L item and has either completed or established documentation to inspect and

                               replace the remaining items.
                               (CLOSED)            325,324/P-2190-04 - Rosemount Resistance Bridges Can Exhibit

-

                               Premature Long Term Degradation Under Certain Combinations of Humidity.

- Power and Temperature. Two of the units referenced in the above, serial

                               numbers 0067897 and 0067898, were provided to BSEP. Neither of these
                               units have been installed. They have been placed under administrative
                                hold in stock under CP&L Part Number 731-758-12. They will be returned to

"

                                the vendor for replacemen+ when the new units on order are received. This
                                item is closed.
                                Violations and deviations were not identified,
 f                          9.  Action on Previous Inspection Findings (92701) (92702)

-- (CLOSED) Violation 325,324/88-18 05, HPCI/RCIC High Steam Line Flow

                                 Instruments Inoperable. The inspector reviewed the licensee's response to
                                 the Notice of Violation and Civil Penalty dated January 27, 1989. The
                                 specific corrective actions taken to resolve the instrument's setpoints

g

                                was detailed in LER'l-88-14, which was inspected and closed in Report No.
                                 90-37. The violation was issued because of the inadequate corrective
                                 actions taken to resolve the issue when it was first identified. In           their
                                 response, the licensee coninitted to revising their corrective action
                                 program along with establishing a program to effectively implement the
                                 BSEP system engineering concept.
                                 Weaknesses in the licensee's corrective action and system engineering
                                  programs were also noted in the Diagnostic Evaluation Team report. As a
                                  result, the licensee included.these specific areas into their IAP program
                                 which resulted in further NRC inspections to followup on the program's
                                  implementation. The licensee's new corrective action program was
                                  inspected in Report No. 90-31. The report stated that the actions
                                  committed to in the IAP were completed. The effectiveness of the new

7

                                  program was not assessed and will be evaluated in future inspections.

1 System engineering program improvements were inspected in Report No.

                                  90-16. The report stated that the appropriate procedures and programs
                                  were in place to correct deficiencies in this area. Based on the
                                   inspections. completed to date, which address the required corrective
                                  actions of the violations and the additional inspections planned to assess

_

                                   the effectiveness of the licensee's corrective action, this item is
                                   closed.
                                   (CLOSED) Violation 325,324/88-24-03, Silicon Bronze Bolts Corrective
 .                                 Actions. .The inspector reviewed the licensee's response to the Notice of
                                   Violation and Civil Penalty dated January 27, 1989. This violation, along
                                   with 325,324/88-18-05, were included in EA-149 and constituted the 2
 _
                                   examples of inadequate corrective action. The specific actions taken with
                                    regard to the silicon bronze bolt issue is detailed in LER 1-88-06, which
 _
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                                                   12
               was inspected and closed out in Report No. 90-37.    As discussed in the
               closcout of Violation 88-15-05, the licensee's actions to resolve
               corrective action program deficiencies have been and are continuing to be
               inspected as part of the followup to the licensee's IAP. Based on these
               inspections, this item is closed.
               (CLOSED) Violation 325,324/88-34-01, Inadequate Design Control Related to
               RCIC Steam Exhaust Check Valve. This violation concerned the Unit 1 and 2
               RCIC Steam Exhaust Check Valve, E51-F040. Plant Modifications 81-274 and
               81-275, replaced the Unit 1 and 2 valves which included discs with design
               pressures of 25 psig. Based on the calculated peak containment pressure
   -
               during a DBA of 49 psig, and containment design pressure of 62 psig, the
    -
               discs were under rated. The inspector reviewed the licensee's response to
               the violation and supporting documentation.. tER-88-0461 was written to
               evaluate the design pressure discrensocy and concluded that the discs were
               sufficient. This was based on successful local leak rate testing at 49
               psid and documentation from the valve manufacturer stating that the discs
               would " withstand a pressure of 62 psig at 248 degrees F for a sustained
               period of time". The EER concluded that these values are greater than the
               containment system requirements for the DBA and higher than credible
               turbine exhaust operating pressures. The cause of the design error was
               that the containment accident pressure and LLRT pressure were not
               evaluated; only operational exhaust pressures were considered during the
               design process. Revisions to applicable administrative and engineering
               procedures have added formalized checklists and training requirements for
               safety reviewers.
               (CLOSED) Violation 325,324/88-38-01, Failure to Control Combustibles in
               Restricted Plant Areas. The inspector reviewed the licensee's response to
               the Notice of Violation and supporting dxumentation. The licensee stated
               that the reason for the violation was t' n personnel not f amiliar with
               fire-retardant wood requirements obtaired wood from outside the protected
               area for use as forms to install a plant modification. A contributing
               factor was that the modification instructions did not specify the type of
               material to be used for the forms. The-licensee enhanced the existing
               controls to allow only fireproof material and/or fire retardant wood to be
               used within the plant protected area. An improvement in identification
               markings for fire retardant wood to ensure this type of wood, including
               cut up pieces, is readily identifiable for use in the protected area. The
               training lesson plan for the plant construction support group annual

,

               training was revised to address this topic.
               (CLOSED) Unresolved Item 325,324/88-05-01, Service Water System Operating
               Mode Concerns. Other inspections of this issue are documented in Inspec-
               tion Reports 89-09, 89-12 and 89-14. -As a result of these inspections and

I

               others perfonned on the service water system, a Notice of Violation and.
               Imposition of Civil Penalty was issued on January 26, 1990, for failure to
               take adequate corrective actions for identified service water deficiencies.
               Example A of- the violation describes the inadequate evaluation performed
               when determining system operability with the single failure concerns
   . . ..
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                                                 13
            associated with the SW-V106 valve.      Further inspection of this issue will
            be performed in the closeout of Violation 325,324/89-34-47.
            (CLOSED) Unresolved item 325/88-34-02, Reactor Vessel Water Level Wide
 o          Range Indication Anomolies. This item was also discussed in inspection
            report 325,324/90-02. Currently the licensee is replacing Rosemount
            transmitters in Unit 1 and is delaying any further action on the wide
            range indicators pending completion of the replacements. The licensee
            expects some indication difference with the new transmitters. The
            inspector determined that no regulatory issues existed. Therefore, this
            item is closed.
            (CLOSED) Unresolved item 325,324/88-38-02, Failure to include All LPCI
            and Suppression Pool Cooling Flow Path Boundary Valves in Surveillance
            Program. This item was also discussed in inspection report 89-05 and was
            expanded to include core spray system valves. This item concerned the pts
            that meet the monthly TS surveillance requirements of ECCS systems for
            verification that each valve.in the flow path that is not locked, sealed,
            or otherwise secured in position is in its correct position. The licensee
            originally disagreed with the inspector on what was a " flow path" valve. -
            Specifically, minimum flow valves, vent isolation valves, valves normally
            outofpositioninstandbylineup(i.e.,E11-F027A(B),RHRSuppression
            Pool Spray Isolation), or flow path boundary valves were not included in
            the surveill'ances. The licensee has subsequently revised the pts to
            include these valves. No occurrences are known where these valves have        '
            been found out of position due to their omission in the pts. This item is
          -closed.
            (CLOSED). Unresolved item 325,324/90-17-02, Potential Inoperability of
            CBEAF System.    Based on inspector's quertions regarding the differential
            pressure measurement technique used to determine the CBEAF system
            operability, the licensee changed the test procedure to more accurately
            measure the differential pressure (see inspection report 90-02).
            Subsequent tests verified that previous test results may have been            s
            inaccurate in cietermining that a positive pressure existed in the control
           . building relative to the outside atmosphere. Based on the licensee's
            previous analysis and documentation from 1985,.the erroneous differential
            pressure measurement technique has minimum safety significance, therefore,
            this item is closed.
            (CLOSED)    IFI 324/88-15-05, Normal Position for SW-V117, Nuclear Header to
            Vital Header Isolation Valve. As a result of extensive review and
            analysis of the service water system design, the normal position of the
            SW-V117 was changed from closed to open. The valve position was changed
            to allow a.RHR room cooler to be placed in service affording the service
            water pumps minimum flow protection under worst case single failure           ,
            scenarios.    The Service Water System Operating Procedures, 1-0P-43,
          ' Revision 31, and 2-0P-43, Revision 68, require that the valve be open.
            The licensee plans to keep the valves open until the service water pump

l thrust bearing modifications are completed. This work is currently

            scheduled to begin in 1992.                                                   ,
                                                                 . . . - . _ _ - . . . .                                                       _,

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              (CLOSED)    IFl 325,324/88-38-05, Licensee Activities Related to Correcting
              Keepfill System Discrepancies. The licensee has determined that the
              primary cause of keepfill system problems are bent stems on pressure
              control valves due to over-pressurization downstream. Several causes of
              over-pressurization have been identified. Currently three of twelve
              keepfill systems are inoperable. Modifications are scheduled for the
              current Unit 1 outage and the next Unit 2 outage to replace pressure
              control valves. This item is closed based on the licensee's
               identification of the causes of the keepfill system discrepancies and
              planned corrective actions.
              Violations and deviations were not identified.
          10. ExitInterview(30703)
               The inspection scope and findings were summarized on November 5, 1990,
               with those persons indicated in paragraph 1. The inspectors described the
               areas inspected and discussed in detail the inspection findings listed
                below. Dissenting comments were not received from the licensee.
                Proprietary information is not contained in this report.
                Item Number                Description / Reference Paragraph
                325/90-41-01               h0N-CITED VIOLATION - Failure to Place Channel A2
                                           in the Tripped Position (paragraph 7.a).
                325,324/90-41-02-          IFl - Adequacy of Offcite Power (paragraph 7.c).
          11. Acronyms and Initialisms
                A0- .      Auxiliary Operator
                 APRM      Average' Power Range Monitor
                 ATTU      Analog Transmitter Trip Unit
                 BPV       Bypass Valve
                 BSEP      Brunswick Steam Electric Plant
               -BWR         Boiling Water Reactor
                 CBEAF      Control Building Emergency Air Filtration
                 CP&L       Carolina Power & Light Company
                 DBA        Design Basis Accident
                 ECCS       Emergency Core Cooling System
                 EER        Engineering Evaluation Report
                 ENP        Engineering Procedure
                  EPRI      Electric Power Research Institute-
                  ESF       Engineered Safety Feature
                  F         Decrees Fahrenheit
                  FACT"     Facili y Automated Conmitment Tracking System
                  FWLCS     Feedwater Level Control System
                  GAF       Gain Adjustment Factor
                  GE        General Electric
                  HP        Health Physics
                                                                                         .
                                                                                           . . . . . , . . . . . . . . . . . . . . . . . . . , . . . . . . = _
                                                             _,____
                                                                      . _ _ _ _ _ _ _ _ _ _ _ _ _                 __ - _ _ __ - _ _ _ __ ______ __-__                           __ _ _ .
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                                                                                                                                                                                             i
 3
                             HPCI      High; Pressure Coolant Injection
                             IAP-      Integrated Action Plan
                             I&C-      Instrumentation and Control
                          ~1E          Inspection- and ' Enforcement
                             IEB-     . Inspection and Enforcement Bulletin
                             IFl      -Inspector Followup Item
                             IGSCC'    Intergranular Stress Corrosion Cracking                                                                                                              ;
                             IPBS      Integrated Planning, Budget'ng and Scheduling
                             IRM       Intermediate Range Monitor                                                                                                                           '
                             LC0~      Limiting Condition for Opetation
                         -LER          Licensee Event-Report'
                             LLRT    -Local Leak Rate Test
                             LPCI      Low Pressure Coolant Injection
                             MSL       Main Steamline
               '
                             MST       Maintenance Surveillance Test                                                                                                                         -
                             NRC       Nuclear Regulatory Commission                                                                                                                        i
                             NRR       Nuclear Reactor Regulation
                             PA        Protected Area
                         .PCIS         Primary Containment Isolation System                                                                                                                 !
                             PNSC-   ' Plant Nuclear Safety Committee
                             PSID      Pounds per Square Inch Differential                                                                                                                  i
                             PSIG,     Pounds per-Square Inch Gauge
                             PT       ' Periodic Test
                             QA        Quality Assurance
                             QC-       Quality Control.          -
                                                                                                                                                                                            t
                             RBCCW     Reactor Building Closed' Cooling Water
                             RCIC-     Reactor-Core Isolation Cooling                                                                                                                       ,
                             RFP       Reactor Feed Pump

. RHR = Residual Heat Removal

                       ,
                         ,RICSIL       Rapid Information: Communication Service Information Letter                                                                                          i
                             RPM       Revolutions Per Minute
                         'RPS:       ' Reactor Protection System
,                         .SDVt        Scram Discharge Volume'-                                                                                                                             :
      '
                         ~SF           Shift Foreman
                          iSRM         Source Range Monitor                                                                                                                                 i
                             STA       Shift Technical-Advisor-                                   -                                                                                         t
        ,                    TCV/TSV   Turbine Control-Valve / Turbine Stop Valve                                                                                                        .;
                             TS      >-Technical Specification
                         ' URI?        Unresolved. Item
                           -
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                             WR/J0:    Work. Request / Job Order
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