BSEP-93-0231, Responds to NRC Re Violations Noted in Insp Repts 50-324/93-41 & 50-325/93-41.Corrective Actions:Moved LPRM Cables to Temp/Humidity Controlled Storage Area & Engineering Evaluation Rept Generated

Responds to NRC Re Violations Noted in Insp Repts 50-324/93-41 & 50-325/93-41.Corrective Actions:Moved LPRM Cables to Temp/Humidity Controlled Storage Area & Engineering Evaluation Rept Generated

ML20058K481
Person / Time
Site:	Brunswick
Issue date:	12/10/1993
From:	Hinnant C CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BSEP-93-0231, BSEP-93-231, NUDOCS 9312150252
Download: ML20058K481 (10)

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Carolina Power & Light Company .

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Brunswick Nuclear Plant  !

P.O. Box 10429 Southport, NC 28461-0429 December 10,1993

.l SERIAL:BSEP 93-0231 10CFR2.201 -

• U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REPLY TO A NOTICE OF VIOLATION Gentlemen:

On November 4,1993, the Nuclear Regulatory Commission (NRC) issued a Notice of Violation -

for the Brunswick Steam Electric Plant, Units 1 and 2. The basis for the violation is provided in NRC Inspection Report 50-325/93-41 and 50-324/93-41. Carolina Power & Light Company finds the inspection does not contain information of a proprietary nature. Enclosure 1 -

provides Carolina Power & Light Company's response to the Notice of Violation inaccordance with the provisions of 10CFR2.201.

Please refer any questions regarding this submittal to Mr. R. C. Godley at (910) 457-2412.

Very truly yours, fin 0W C. S. Hinnant, Director-Plant Operations Brunswick Nuclear Plant JFM/jfm Enclosures

1. Reply to Notice of Violation

2. List of Commitments cc: Mr. S. D. Ebneter, Regional Administrator, Region ll Mr. P. D. Milano, NRR Project Manager - Brunswick Units 1 and 2 Mr. R. L. Prevatte, Brunswick NRC Senior Resident inspector 9312150252 931210 PDR ADDCK 05000324 U 0 //'$

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Enclosure List of Regulatory Commitments The following table identifies those actions committed to by Carolina I-. & Light Company in this document. Any other actions discussed in the submittal represent intended or planned actions by Carolina Power & Light Company. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Msnager-Regulatory Affairs at the Brunswick Nuclear Plant of any questions regarding this document or any associated regulatory commitments.

Commitment

1. Revise PMC-02, Receiving, to indicate that documents received, such as vendor field installation procedures, etc. will be reviewed by the M&CS Material Technical group to ensure proper actions, such as storage requirements, are taken.

2. Receipt, storage, and maintenance information will be identified and maintained for all inventory items and will include storage requirements. This will enable Materials Control to identify and comply with any special storage requirements.

3. Revise PMC-03, Storage, to provide instructions for repressurization of inert gas covers and to clarify requirements for desiccant control

4. Revise appropriate procedures to ensure stock items are not removed from the Materials Control database before disposal tags are in place.

5. Develop a comprehensive storekeeper training program.

6. Revise OP-08, CRD Hydraulic System Operating Procedure, to include guidance on CRD isolation with cooling water in service.

7. Revise Special Process Procedure OSPP-HYDRO 500 to include considerations of the system configuration.

8. Revise OP-50, Plant Electric System Operating Procedure, to provide appropriate procedural steps to disable the automatic speed demand feature when in UAT Backfeed.

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ENCLOSURE f I

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 and 2 l NRC DOCKET NOS. 50-325 & 50-324 t OPERATING LICENSE NOS. DPR-71 & DPR-62 i REPLY TO NOTICE OF VIOLATION I

, VIOLATION A-t 10CFR 50, Appendix B, Criterion XIII Handling, Storage and Shipping requires that '3 measures be established to control the handling, storage, shipping, cleaning and  !

preservatien of material and equipment in accordance with work and inspection [

instructions to prevent damage and deterioration. When necessary for particular j products, special protective environments such as inert gas atmosphere, specific j moisture content levels, and temperature levels shall be specified and provided. j I

1. Specification for Procurement of Silicon Dioxide Insulation Cables and >

Connectors, specification No. 113-030, Rev 0, Step 2.10.3 required that I the seller furnish receiving, storage, and handling instructions for l warranties and/or guaranties and to preserve the integrity of the cables  !

placed in indoor storage.  !

Field Installation Procedure for Local Power Range Monitor (LPRM) Cables,

- FIP-9233, Rev. O, section 4.0 required that end openings for cables be  !

capped with halogen free plastic caps, and desiccant be placed on each  ;

connector cable end and that cable assembles be sealed in heat scalable l polyethylene bags.

Contrary to the above, on October 5, 1993, several boxes of.LPRM cables in  !

different storage containers were stored in polyethylene bags that had i been opened and were not properly resealed. Several of the cables ,.e  !

not properly heat sealed prior to shipment from the vendor. In addit h , j desiccant material was not placed in each bag and one cable connector was  !

missing an end cap.

2. Procurement and Material control Procedure, Storage, OPMC-03, Rev. 16, provides requirements for the storage of safety related and nonsafety-related items. Step 6.10.3, requires that items pressurized with inert gas be monitored each week to ensure that the gas pressure is maintained within specified limits. Step 6.17.1 of OPMC-03 requires that Q listed ,

material designated for QA review or hold be relocated to a designated l area. j Contrary to the above, on October 5, 1993, the inert gas pressures on two i spare electrical penetrations were below the 15 psig posted minimum limit. l The weekly warehouse inspection reports for July, August and September '

1993, revealed that the inert pressure had been below the posted minimum l value for at least this three month period. The inert gas pressures and '

desiccant indicator inspections had not been performed as required during  ;

the week of September 13, 1993. Additionally, on October 5, a control rod drive piston rod which was tagged for OA hold had not been placed in a designated storage area. Also, several other control rod drive piston rods were found to have expired desierant indicators.

This is a Severity Level IV violation (Supplement I).

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r RESPONSE TO VIOLATION:

Violation A - Example 1 Admission or Denial of Violation Carolina Power & Light Company admits this violation.

Reason for Violation This violation occurred because the proper storage requirements for the LPRM cables were not provided to the Materials and Contract Services (M&CS) department. The purchase specification listed storage requirements for " Level C" equipment and required the vendor to furnish any additional receiving, handling, and storage instructions. The purchase specification was sent to the vendor for review and comment. The vendor made no comments related to storage.

Subsequently, the vendor supplied additional storage instructions in the " field installation procedure". The storage requirements provided at that time included requirements for cable end caps, that desiccant be attached to each connector, and that the cables be stored in heat-sealed polyethylene bags. The additional storage requiretaents were received but were not addressed as design requirements and were not included in the purchase order. The material receipt process does not currently include review of field installation procedures. Each CP&L unit has specific procedures that cover their assigned areas; however, there was a.

failure to communicate between the different units regarding the storage requirements.

Corrective Actions Which Have Been Taken and Results Achieved

1. The LPRM cables were moved to a temperature / humidity controlled storage area.

-2. An Engineering Evaluation Report was generated . providing disposition instructions to bring cablea currently in storage in compliance with the vendor's field installation procerbire.

3. The Engineering /QA approvals were removed from the Materials Control Database for the LPRM cables to prevent future reorders until the database can be revised to incorporate storage requirements from the vendor's field installation procedure.

4. A review was performed to identify items which are subject to unique storage requirements and verify the adequacy of storage conditions and acceptability for use.

Corrective Steps Which Will Be Taken to Avoid Further Violations

1. Procurement and Materials Control (PMC-02) , Receiving, will be revised to indicate that documents received, such as vendor field installation procedures, etc. will be reviewed by the M&CS Material Technical group to ensure proper actions, such as storage requirements, are taken.-

2. Receipt, storage, and maintenance information will be identified and maintained for all inventory items and will include storage requirements.

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This will enable Materials Control to identify and comply with any special storage requirements.

Date When Full Compliance Will Be Achieved Carolina Power & Light is in full compliance. -;

i Violation A - Example 2 {

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'l Admission or Denial of violation

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Reason for Violation  ;

This violation occurred due to inadequate procedures and training. PMC-03,  !

Storage, requires that the minimum and maximum pressure limits for storage will i be established by manufacturer specifications or by an engineering evaluation and '

identified on the container or box. The container was posted 15-17 psig but had no identified actions if actual pressure f alls outside that range. . The . procedure instructs the storekeeper to ensure that the gas pressure is maintained within specified limits. There was a lack of a " questioning attitude" among the storekeepers regarding pressure limits and the compensatory actions if _ the >

. pressure falls below the posted minimum. .;

The vendor limit for the electrical penetrations is 62 psig maximum. For long-  !

term storage, a pressure of 15-17 psig is suggested, with a repressurization-  ;

approximately every 3 months when the pressure has dropped to 5 psig. This information was not indicated on the container and was not accessible to Material t

. Control personnel.  ;

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PMC-03 requires that items with desiccant indicators shall be monitored each '!

week. Upon subsequent investigation, the weekly inspection was performed for the l week of September 13, 1993. There was a programmatic problem which contributed l to the expired desiccant indicators on the control rod drive piston rods. The -)

items were being prepared for disposition in the inventory reduction program. .j The items had been taken off of the database, but had not been individually  ;

marked with "1598 Disposal" tags . When the items were removed from the database, - j the desiccant inspection was not required or performed. There was one piston rod l which had a " Materials Hold" tag attached. The other piston rods could have been  !

issued even though they had been removed from the database and had expired l desiccant indicators. The process to dispose of material is inadequate in that i the waterial can be removed from the database, thus eliminating any required i inspections, before the "1598 Disposal" tags, which prevent issuance, are in place.

Corrective Actions Which Have Been Taken and Results Achieved

1. The penetrations were evaluated as acceptable by an Engineering Evaluation Report. The minimum or maximum pressure limits had not been exceeded.

2. Training was provided to the appropriate M&CS personnel regarding inert gas covers and the requirements to keep the pressure within the specified j limits. '

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3. The weekly desiccant inspection form was revised to incorporate _the new )

range requirements, j l

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Corrective Steps Which Will Be Taken to Avoid Further Violations 1.. PMC-03 will be revised to provide-instructions for re-pressurization of inert gas covers and to clarify requirements for desiccant control.  !

2. Appropriate procedures will be revised to ensure stock ' items are'not removed from the Materials Control database before disposal tags are in place.

3. A comprehensive storekeeper training program will be developed to increase procedural knowledge and stress adherence to procedures.

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Date When Full Comn1 dance Will Be Achieved -

i Carolina Power & Light is in full compliance.  ;

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VIOLATION B- '!

i Technical Specification 6.8.1 (a) requires that written procedures shall be established, implemented, and maintained covering the activities referenced in- i Regulatory Guide'1.33, Appendix A, November 1972.

1. Regulatory Guide 1.33, Appendix A, Section 1(c) requires procedures for  !

control of plant equipment. AI-58, Equipment Clearance Procedure i implements these requirements. Clearance 1-93-2488 was established on i September 3, to isolate and depressurize the Control Rod Drive (CRD)  !

Hydraulic Control Units (HCUs) for the 68 control rods withdrawn to  ;

f acilitate the shroud inspection. The clearance was to prevent rod motion. l on a scram signal. 3 contrary to the above, the established clearance was inadequate in maintaining the accumulators depressurized, and therefore did not prevent ,

rod motion when a manual scram signal was inserted on September 24, 1993. '

Receipt of this scram signal resulted in 50 of the 68 control rods under clearance inserting into the core.

2. Regulatory Guide 1.33, Appendix A, Section 4 (m) requires procedures for l the system line up of the turbine generator system. FP-82236, Steam =

Turbine EHC System Field Line Up Instructions, implements the requirements l for the plant electrical system operating in the backfeed node, j i

Contrary to the above, procedures FP-82236 and 1-OP-50 were inadequate in j that neither procedure provided prerequisite conditions or steps to -

prevent the Group I Isolation Signal which occurred on September 28, 1993, ,

as the result of resetting the turbine trip (while backfeeding via . the .

Unit Auxiliary Transformer) per procedure FP-82236.

This is a Severity Level IV violation (Supplement I).

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RESPONSE TO VIOLATION: l l

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Violation B - Example 1 (

I Admission or Denial of Violation i Carolina Power & Light Company admits this violation. -l f

f Reason for violation j t

This event was due to the failure to properly establish and provide necessary i guidance and precautions for the clearance. At the time of the event, a hydrostatic test of the Scram Discharge Volume (SDV) was about to commence. The >

purpose of this test was to re-establish the operability of the CRD Hydraulic System and allow control of the system to be turned over to Operations. A manual scram was to be inserted as a preliminary step to depressurize the 69 charged HCU [

accumulators and assist in filling the SDV. However, because inspections of_the l core shroud were in progress, the 68 control rods in the outer two rings of the  !

core had previously been fully withdrawn and placed under clearance. The 't clearance was prepared to prevent the control rods from moving into the core l while maintaining cooling water to the drive mechanisms for flushing the drive  ;

piston seals. I When the clearance was written, it was recognized that some minimal valve leakage past the charging header isolation valves was possible. The Clearance Center {

Senior Reactor Operator believed that the clearance was adequate based on a i verbal understanding that the Technical Support Engineer intended for Operations ,

to keep the water side of the accumulators drained (depressurized); The water [

side of the accumulators were drained, but the nitrogen side was not J depressurized. The water side was verified drained twice per shif t by observing i accumulator pressure was not greater than 955 psig - (accumulator low pressure alarm ' point). The instructions to verify that the ' accumulators were .!

depressurized were poorly communicated and executed. Without being'given the 1 reason for depressurizing ' the HCDs, Operations did not realize that merely keeping the HCUs' pressure below the low pressure alarm setpoint did not meet the intent of the clearance. ,

The vendor instructions discuss HCU isolation with cooling water flow and specifies that the gas side of the accumulators is required to be discharged in '

order to prevent CRD movement in response to a Reactor Protection System (RPS) l signal. The gas side of the accumulators was not bled down because of previous l problems involving the bottoming-out of the accumulator pistons, ALARA concerns, and experiences where this particular lineup was used successfully.

• l The hydrostatic test of the CRD System Scram Discharge volume was scheduled to be performed concurrently with the core shroud inspection. The clearance in  !

place for the core shroud inspection was deemed appropriate for the CRD system )

test. Management did not adequately address the specific rod configuration or the f act that this test would insert a manual scram and therefore challenge - the clearance that was in place to prevent rod motion.  ;

CP&L believes programmatic controls exist to ensure appropriate coordination and evaluation of plant activities. However, the implementation of these processes ,

was less than adequate as described above.  !

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- l Corrective Actions Which Have Been Taken and Results Achieved 'l

1. The control rods were inspected with no damage found.

2. Work Requests / Job Orders were written to repair the charging header  !

isolation valves that were identified as leaking by. ,

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3. Briefings have been conducted with the Operations shift personnel j detailing the lessons learned from this event and the management 1 expectations.  ;

4. Individuals involved have been counseled on the need for a questioning attitude and the positive aspects of thorough communications. i

5. A letter from the Director, Site Operations to appropriate plant i management concerning the details of this event and the expectations of F plant and work control when recovering from an outage has been issued.  ;

Corrective Steps Which Will Be Taken to Avoid Further Violations

1. Operations procedure OP-08, Control Rod - Drive (CRD) Hydraulic System i Operating Procedure, will be revised to include guidance on CRD isolation with cooling water in service.

2. Special Process Procedure DSPP-HYDRO 500 for the CRD System Scram Discharge l Volume will be revised to include considerations of the system "

configuration.

Date When Full Compliance Will be Achieved /j t

Carolina Power & Light is in full compliance. 'l Violatien B - Example 2 [

t Admission or Denial of Violation Carolina Power & Light Company admits this violation  !

i Reason for Violation This event was due to procedural deficiencies. The Unit Auxiliary Transformer [

(UAT) Backfeed procedure does not support maintenance activities requiring  ;

movement of the turbine control valves. The main turbine trip is reset several times during an outage to support valve timing and other maintenance activities. .

As long as the main generator Power Circuit Breakers (PCBs) are open, the 1800 i RPM speed select will not be activated. When the unit is being supplied through J a UAT backfeed, the main generator PCBs are closed. With the PCBs closed and the l turbine trip reset, the Electrohydraulic Control System (EHC) will automatically j select a turbine speed of 1800 RPM which will open the turbine control valves.

When the turbine control valves open, the low condenser vacuum Group 1 isolation is enabled.

In previous outages, the unit was normally supplied from the Startup Auxiliary Transformer (SAT) with the main generator PCBs open. The UAT Backfeed procedure was developed to provide an alternate power source if outage work was scheduled 7 of 8

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to be performed on the SAT or the Emergency Diesel Generators. The procedure i enabled the unit to be supplied from offsite power through the main generator _j PCBs and the UAT. When developing the UAT Backfeed procedure, no steps were j included to defeat the auto speed select as the use of the backfeed coincident  ;

with the EHC con-rol setup was not expected. l Corrective Actions Which Have Been Taken and Results Achieved  ;

l A Caution Tag was placed on the main turbine trip reset switch warning of the- i potential for the Group 1 isolation. j t

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Corrective Steps Which will Be Taken to Avoid Further Violations .l Operating Procedure 50, Plant Electric System Operating Procedure, will be f revised to provide appropriate procedural steps to disable the automatic speed i demand feature when in UAT Backfeed. l t

Date When Full Compliance Will Be Achieved Carolina Power & Light is in full compliance. ,

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