BSEP-93-0201, Responds to Violations Noted in Insp Repts 50-324/93-201 & 50-325/93-201.Corrective Actions:Alternate Safe Shutdown Drill Headphones Replaced W/Higher Quality,Periodic Test 48.4 Revised & Addl Emphasis Placed on C/A Program
| ML20046A625 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/23/1993 |
| From: | Warren C CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BSEP-93-0201, BSEP-93-201, NUDOCS 9307290136 | |
| Download: ML20046A625 (7) | |
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I Carolin.; Dower & Light Company..
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Brunswick Nuclear Plant P. O. Box 10429 Southport, N.C.
.28461-0429, July.23, 1993-r..
FILE:
B09-13510C
'10CFR2.201-SERIAL:
BSEP-93-0201 E-U.S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.
C. 20555 BRUNSWICK NUCLEAR 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:
The Brunswick Nuclear Plant.(BNP) 'has received NRC Inspectiori Report '50-325/93' -
201 and 50-324 /93-201 and' finds it does not cantain information of a proprietary-nature. This report included s Notice Of Violation.
Enclosed 'is Carolina Power & Light Company's response f to that. Notice Of j.
Violation.
Very truly yours,
'A Fcit-C.
C. Warren, Plant Manager Unit 2 Brunswick Nuclear Plant JFN/
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-Enclcsure cc:
Mr. S. D Ebneter Mr.
P. D. Milano i
'BSEP NRC Resident Office t
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ENCLOSURE 1
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.B UNSWICK STEAM ELECTRIC PLANT, UNITS 1 and.2-R fj i
NRC DOCKET NOS. 50-325 & 50-324.
OPERATING LICENSE NOS. DPR-71'& DPR-62' I'
REPLY TO NOTICE OF VIOLATION Li VIOLATION A:
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L 10 CFR-50 Appendix B, Criterion XI requires that.a test program be established'
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to. assure all' testing-required to demonstrate that systems and components-will' perform satisfactorily in service-is identified and performed.
n Contrary'to the above, on April 5-,' 1993, 'it. was determined. that 'an.inadequatie.
test program was in place for the sound powered communication system designated
'l for use durjng the. implementation of alternate shutdowns, contributing to.the ij failure of an alternate shutdown drill.
j This is a Severity Level IV violation (Supplement I)
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EJfSPONSE TO VIOLATION A;
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jhissionorDenialofViolation I.
l Carolina Power & Light Company (CP&L) admits the~ violation.
i; Rgsson for violation t
The violation occurred because the test method : for. the ' sound powered -phone circuits used for the Alternate Safe Shutdown Drill.-(ASSD) did not'. detect.that the original sound powered headphones were not adequate for use in the. intended application'. These headphones had less than adequate noise filtration, and' were -
subject.to performance degradation due to handling. In addition, although each.
of!the individual circuits and headphones had been tested, they were not tested'
.l inia configuration that accurately simulated the' annual drill.'
Periodic Test
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(PT) 48.4, ASSD Sound Powered Phone System Functional Test, did not test the-i circuits with a full-loaded capacity.
'Ihe PT was - revised ;to test the circuits with all eleven headphones connected. Operations personnel had noted problems with communication during. past' drills and specific fixes were performed.
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However, the broader corrective' actions needed to resolve the overall problem
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were not identified and resolved.
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f.grrective Actions Which Have Been Taken and Results Achieved-The following corrective actions have been implemented:
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.ASSD headphones _were replaced with a higher quality, self-amplified model with noise filtration.
Use of the improved headphones corrected thel system problems previously experienced.
2.
Periodic Test 48.4, ASSD Sound Powered Phone System Functional' Test, was revised to test each phone circuit in the drill configuration. This test was conducted successfully.
3.
Management has placed additional emphasis on the corrective action program to identify the root causes of issues and correct them in a timely manner.
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i Corrective Steos Which Will Be Taken to Avoid Further Violations
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No further actions are required.
Date When Full Comeliance Will Be Achieved Carolina Power and Light is in full compliance.
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- Violation B:
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- 10 CFR 50' Appendix-B, Criterion.V requires that activities 'affecting quality.
1 shall be described in procedures' appropriate.to the circumstances and shall be i
accomplished in accordance with these procedures.
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Contrary to the above, from March:29 through April 9, 1993, several licensee
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l activities affecting quality were not accomplished-in accordance with applicable '
procedures.as evidenced by the following examples-
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. Operator aids, which were net listed.on the operator aid ' log and not identified with a serial number as required'by Operating. Instruction OI-J!
41, Operator Aids, Revision 009, were post'ed on the main control room panels, the doors' of the control, room back panels, and on.the remote shutdown panel.
2 '.
Periodic Test Procedures PT 12.6, Breaker Alignment Surveillance, and'PT 4.2.2, Turbine Building Effluent Flow Device Test,.were not revised.to reflect plant modifications (PM)90-001 and PM 87-098, respectively, as' d
required by the CP&L Nuclear Plant Modification Procedure, Section 5.5.2.
1 3.
Containment manual isolation valve E11-V125 was not. included in. the j
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Periodic Test Procedure PT 2.2.4a, Primary Containment Integrity i
Verification, and therefore was not verified closed once per 31cdays as required by Technical Specification 4.6.1.1.a.
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The licensee failed to perform independent verification of valve positions following jet pump instrument calibrations as required by procedure PLP-21, Independent Verification, Revision 01.
5, The work control center supervisor f ailed to ensure that current plant conditions support the accomplishment of ~ the
. ork, as required - by.
w procedure PLP-24, Work Management Process,. Revision 0,
Section 5.8.B.
This resulted in the replacement of the reactor building door seals-concurrent with the Secondary Containment Integrity. surveillance test l
15.4; thus, not meeting a prerequisite in the surveillance procedure.
This is a Severity Level IV violation (Supplement I).
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EfSPONSE TO VIOLAT: ON B:
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Admission or Denial of Violation Carolina Power & Light Company admits the violation.
U Reason for Violation Vi03ation B - Examo)e 1 A survey of operations and maintenance personnel was conducted to determine f amiliarity with the operator aid control procedures, and to identify the f actors contributing to viol stion of this procedure. The contributors are listed below:
1.
Individuals were aware of the existence of controlling procedures. These procedures, however, were perceived as difficult and time consuming'to use.
2.
Operators did not identify and remove unapproved ' aids once installed because they perceived them as effective in assisting with operating activities, and in reducing the likelihood of human performance problems.
3.
There had been no adverse consequences associated with the use of the unapproved aids and this contributed to a lack of management. focus on identification and removal of unauthorized aids.
- i Violation B - Example 2 The Operations review of plant modifications PM 90-001 and PM 87-098 resulted in appropriate-revisions to several plant procedures; however,cthe review was not sufficiently detailed and did not identify PT 12.6 and PT 4.2.2.
This error was identified during the first performance of the aurveillance af ter completion of the modifi cat. ions. The individual performing the PT noted the error, reviewed.
the situaticu with shift management, and initiated the proper procedure change document.
Raision of these procedures was in progress. when noted by the inspector.
Violation B - Examole 3 The original design for the Residual Heat Removal Outboard Containment Spray Isolation Valve, 2-E11-F016B, placed the body drain valve, E11-V125, on the upstream side of the globe valve. This arrangement placed the E11-V125 outside of the containment boundary.
During construction, the E11-F016B was installed backwards, which placed the E11-V125 inside the containment boundary.
United Engineers ar?3 Ccnstructors reviewed this error and determined that the reversal of E11-F016B would not af fect the proper operation of the valve. The review did not consider the role of E11-V125 as a Primary Containment Isolation System (PCIS) valve and was not incorporated into design documents.
The E11-V125 was included in Periodic Test (PT)
- 2. 2. 4 a,. Primary Containment Integrity verification, when it was originally approved in September, 1982. In 1989, a review of primary containment penetrations was ' conducted by System Engineering to eliminate testing of valves which do not meet the PCIS valve criteria.
This review was performed using piping and = instrument diagrams (P&TDs). Since the design documents had not been updated to reflect the reversal of the E11-F016B, the engineers believed the body drain valve was not a PCIS valve and the E11-V125 was deleted from PT 2.2.4a in December, 1989.
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- 4 I Violation B'+-
Examole 4 b
.The violation'was due to independent verification not being performed'.
PLP-21, Independent Verification, Revision-. 01, allows independent: verification requirements to be waived when excessive radiation exposures would result..-The procedure documents exposures ' in excess of 10 mrem.as a guideline.
PLP-21 requires the respective supervision to authorize the waiver.1 The. contractors-perforrning the - jet pump calibrations. waived the independent. verification:
requirenent, without their responsible supervisors authorization, due to a "I rem per hour" posted hot spot adjacent to the area.. The actual dose rates:in the area were 3-5 mrem / hour.
When questioned by the inspector, the contractors believed the requirements allowing independent' verification to be waived were applicable since the 10 mrem / hour dose rate was only a. guideline.
Violation B - Examnle 5 The Secondary Containment Integrity Surveillance test, PT 15,4 was scheduled.-to commence on April 3,
1993, in support of returning secondary containment'.to operability following an extended ou' age.
Prior to the test, an air lock door seal was to be replaced. The Work Control Center (WCC) Senior Reactor Operator.
(SRO) approved the door seal work package on April 2, 1993, but did not inform-the Control Room. The WCC SRO was authorized to' release work packages,.and was required to inform the Control Room only lof significant work. items that were to
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be performed.
The W2C SRO felt the work was not.significant since seconda9y containment was not required to be operable. Also, the PT would not be performed until the following day and the seal replacement work was to be completed that' day.
The door repair was started on April 2, 1993, and was completed on April 3,
1993.. The Control Room and the Work Control Center f ailed to, adequately ~-
-communicate, which allowed the. door repair and the start of the secondary containment test to be performed concurrently.
Corrective Actions Which Have Been Taken and the Results Achieved-The following corrective actions have been completed:
Violation P - Examnle 1 1.
Removed uncontrolled operator aids from the Unit 2120 VAC cabinets listed-in OPM-PNLOO1, and the Unit-2 125/250 VDC Remote Shutdown Cabinets.
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Issued a memo to Site Management addressing expectations concerning plant labeling and operator aids.
As a result of that. correspondence, and subsequent management reinforcement in the work groups, plant-personnel are now more sensitive to the requirements for obtaining approved aido.
No unapproved operator aids have been identified since these actions were taken.
Violation B - Examnle 2 1.
Revised PT 12.6 and PT 4.2.2 to reflect the as-built conditions following.
implementation of TM 90-001 and PM 87-098.
2.
Counseled procedure writers / plant modification reviewers to heighten sensitivity regarding the need to capture all applicable. procedures needing revision.
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Violation B - Examole'3
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Revjsed PT 02.2.4a.to include a surveillance.of-2-E11-V125.
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-2, Revalidated the :1989. penetration review by examining Unis ' l' and. 21 PCIS l
globe valves. -No additional deficiencies were noted.
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1 Violation B - Examole 4 1.
Outage Maintenance / Management craft supervision,' technicians,.and field-engineering, received training.on the procedural requirements:for PLP-21.
2.
Work on the jet pump calibration was resumed.with supervision monitoring
.i the' independent verification.
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Violation B - Examole 5 i
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Computer data query capabilities providing an' accurate listing of;
'l authorized Work Request / Job Orders (NR/JO) has been made available to Work Control Center personnel.
This listing can be used to assist. turnovers and evaluate authorized work against a change in plant conditions.
2.
Training wa's provided to Work Control Center Senior Reactor Operators.on-PLP-24 during Phase 4 of Licensed Operator Retraining from May 31; 1993; through July 1.
1993.
Corrective Actions Which Will Be Taken to Avoid Further Violations The following corrective actions are planned or are in progress:
5 Violation B - Examole 1 1.
Evaluate and determine appropriate. revisions to the-program for 1 the '
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control and approval of operator aids. This will ' include consideration of
'c user needs, and coordination with plant' operating procedures.
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Revise applicable cabinet cleanliness procedures to include provisions for j
removal of uncontrolled operator aids; i'
3.
Perform walkdowns of Unit 1 120 VAC Cabinets listed in OPM-PNLOO1,1 and:
125/250 VDC Remote Shutdown Cabinets and remove uncontrolled operator aids-from these cabinets.
i Violation B - Examoles 2, 4 and 5 l
-No further actions are required, j
Violation B - Examole 3
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Revise appropriate plant documents to include' 2-Ell-V125 as a PCIS valvei
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