ML19332C479

Suppls 891023 Response to Violations Noted in Insp Repts 50-324/89-20 & 50-325/89-20.Corrective Actions:Proper Valve Lineup Restored to 2,714 & Sys Returned to Operable Status & Reactor Power Reduced to Less than or Equal to 2,436 Mwt

ML19332C479
Person / Time
Site:	Brunswick
Issue date:	11/20/1989
From:	Harness J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BSEP-89-1049, NUDOCS 8911280177
Download: ML19332C479 (25)

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' Carolina Power & L6ght Company

-Brunswick Nuclear Project

' = P. O. Box-10429 Southport, NC 28461-0429 November 20, 1989

, FILE: B09-135100 10CFR2.201 SERIAL: BSEP/89-1049 U.S. Nuclear Regulatory Commission A'ITN: Document Control Desk Washington, DC 20555-4 I

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BRUNSWICR STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENTAL RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS Gentlemen:

The Brunswick Steam Electric plant (BSEP) received 1&E Inspection Reports  !

50-325/89-20 and 50-324/89-20 and provided a response to that report on  !

October 23, 1989 (SN: BSEP/89-0970). Based on a telephone conversation. t between Mr. ll. C. Dance (Region II) and myscif on November 14;-1989, a supplemental response .s being provided to provido additional-information on l several of tho_. identified violations. This response supersedes the October-23, ,

1989, response.

Very truly yours, -

( W ,

L. Harness, General Manager  :

Brunswick Nuclear Project  !

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-Enclosure ,

-cc: Mr. S. D. Ebneter l Mr. E. G. Tourigny .t BSEP NRC Resident Office i

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. . CD&L Carolina Power & Lipht Company

&_ r Brunswick Nuclear Project P. O. Box 10429 Southport, NC 28461 0429 November 20, 1989 >

7 FILI: B09-13510C 10CFR2.201' SERIAL:- BSEP/89-1049 ,

U.S. Nuclear Regulatory Commission r ATTN: Document Control Desk

.-Washington, DC 20555 4

y BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 l LICENSE NOS. DPR-71 AND DPR-62

- SUPPLEMENTAL RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS  ;

Gentlemen: f The Brunswick Steam Electric Plant (BSEP) received I&E Inspection Reports 325/89-20 and 50-324/89-20 and provided a response to that report on i October 23, 1989 (SN- BSEP/89-0970). Based on a telephone conversation between Mr.11.- C. Dance (Region II) and myself on November 14, 1989, a i supplemental response is being provided to provide additional!information on several. of the identified violations. This response supersedes the Octcher 23, 4 1989, response.

' Very truly-yours, Origine! Signed By JOSEPH L HARNESS s J. L. Harness, General Manager

• Brunswick Nuclear Project

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cc: Mr. S.-D. Ebneter Mr. E. G. Tourigny

, BSEP NRC Resident Office g-bec: Mr. R. M. Coats Mr. A. M. Lucas Mr. D. C. Whitehead Mr. C. W. Crawford Mr. R. E. Morgan INPO

'Mr. A. B. Cutter Mr. C.11. Moseley On-Site Licensing L Ms. R. S. Gatewood Mr. W. R. Murray File

BC/A-4

.Mr. W. P. Guarino Mr. J. O'Sullivan SHEEC Training

• Mr. M. D.11111 Mr. W. W. Simpson keforence Library

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Mr. L. E. Jones Mr. R. B. Starkey Jr.

Mr. M. A. Jones Mr. L. V. Wagoner l

Mr. L. I. Loflin Ms. T. A. Ward i

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Violation A ,

,- 10CFR50, Appendik B, Criterion XVI, requires that measures shall be established to assure that conditions adverse to quality such as. failurns, malfunctions,-

deficiencies, deviations, defective mat erial and equipment innd nonconformances ,

are promptly identified and corrected. .In the case of significant conditions adverse to quality,' the measures shall assure that the cause of the condition is' determined and corrective action taken'to preclude repetition.

' Contrary .to the above, the licensee f ailed' to take prompt corrective action, in that on March 31, 1989,- after the identificetion of a third. example of a=

corroded service water pump lubrication water support resulting in the possible [

inoperability of the associated service water pump. the' licensee failed to

,_ promptly identify and correct other degraded service water pump lubricating water piping supports.

RESPONSE ,

I.- ' Admission or Denial of the Violation j

9 CP&L acknowledges that, between 3/31/89 and 4/5/89, during the course of evaluating corrosion problems associated with the Service Water (SW) pump  !

I lubricating water piping supports, it failed to promptly. identify and correct other SW pump lubricating water piping support operability concernc.

IJ. Reason For Violation.

The failure to promptly identify and correct'other SW pump lubricating water piping support operability concerns tietween 3/31/89 and 4/5/89 was a 4 result of miscommunication, l t

CP&L bngan prompt and timely corrective actions-immediately upon being- '[

informed of the initial corroded support by the Resident inspector on 3 3/9/89. The actions taken the next day were tot i

1. Verify if there were similar SW lube water pump supports which had potential operability concerns due to corrosion by shock testing and j cvisually inspecting the other system lube water supports,  ;

2. Initiate preliminary assessments of the operability of the pumps .['

based on the corrosion found during the support inspections and

3. Initiate a seismic analysis for the entire pump atructure to  !

determine SW pump operability with the corroded supports.

At this time, two pumps were determined to havn potential operability concerns relative to visibic corrosion damage of the lube water supports, j the 2A Nuclear SW pump (NS"p) and the IB Conventional SW pump (CSWP).

Repairs were initiated, implemented and completed on these pump supports by 3/22/89.

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[' On 3/31/89, during clean-up activities of the SW lube water supports, a -!

potential corrosion' problem was found on the 2A CSWP local to the installed Horne Flex. which is a grouting material used to seal the supports in place under base level.- An engineering assessment of the seismic quali- ,

fication of the support was begun that day.' Upon determination that the  ;

support may not be seismically qualified, the system engineer initiated a ,

.~ WR/JO with an Operating' Instruction (01)-04 operability assessment on the '

' 2A CSWP. . Repairs were begun on 3/31/89 under the guidelines of Direct-

-Replacement (DR) 89-0112 for the 2A CSWp support.

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< Based on the findings for the 2A CSWP, a discussion between the Technical  :

Support Manager and the plant General Manager was held on 4/5/89 and at that time t'ne recommendation was made that if another problem was discovered

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underneath the Horne Flex, which would be the second indication, then l action would have to be taken to remove the llorne Flex on all SW lube >

water supports for immediate investigation. This was the approach agreed ,

[ upon and subsequently carried'out upon determination that the next inspected >

support had similar corrosion

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p 111. Corrective Actions Which Have Been Taken

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~ An' appropriate and timely action plan was established once management became aware of the significance of the corrosion beneath the Horne Flex. ,

This' plan was implemented based on discussions between the Technical ~ .

Support Manager and the Plant General Manager. The service water. pump 'f lube water supports have been inspected and repaired as necessary. t I

b The completed analysis of the SW pump support structure concpded that the SW pumps were not inoperable due to the corrosion conditfons found on  !

the supports.  ;

L The communication problems encountered during this event hava been

. assessed both by site management and through an independent. Human 7 9 Performance Evaluation of the event. 'Although site management does not  :

completelyagreewiththeHPEdescriptionofeventssurroundpgthis incident, the recommended corrective actions from the report 6 ave been 1 F addressed specifically as follows and are complete:

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1. This event is considered to be an isolated / individual evcut and is. i not indicative of generic communications problems at the Brunswick l Plant.

2. The System Engineer has been counseled on ensuring effective communications to and from supervision.

3. A memorandum has boon issued to Technical Support personnel from the Technical Support Manager notifying them that the full management i chain of Technical Support is to be involved for issuance of 01-04 or LCO conditions by members of the Technical Support staff, i P

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4, 'Real-Time Training (RTT) on this issue for the Technical Support '!

staff has been completed.

The intent of the memorandum and the RTT is to assure that Technical r i Support Management, and consequently site management, is made aware of y such events in a timely manner to assure that the event / condition.

actually represents an operability condition and that timely resources '

y aretidentified and directed to correcting the event / condition in parallel with establishing the LCO.-  !

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,5. Revision 2 to Plant Procedure (PLP)-04, the site Corrective Action

,p Procedure, has been issuod. This revision was initiated-to' ,

improve the identification and documentation of potential ,

operability concerns : including increased management' attention to'  !

these concerns.-

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6. .To' assist in driving out perceptions at the site that raising .

operability concerns is resisted by management, this subject is addressed at regularly held unit meetings and ongoing working ,

l, lunches between the Plant Manager and plant supervision. T L 7. A Senior Site Hanagement [ Technical Assistant to the Plant General b- ~ Manager (TAPGM)) position reporting directly to the. Plant Manager has  !

been; filled'to. direct the site Corrective Action Program.

8. A senior level position has been approved and filled as Humari- 'i Ferformance Evaluation System Coordinator._ This position, working ,

I closely with the TAPGM,'will heighten-sen'sitivity to inadequato f human performance and communications,-ensuring' appropriate *

. corrective actions are taken.

L The' corrective actions taken to this point are considered sufficient to ,

prevent recurrence of a similar event. As a result, no further corrtutive <

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c actions are considered necessary for this event. '!

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-,s Violation B Technical Specification 6.8.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972,

1. Section D of Appendix A requires Operating Procedures for safety-related BWR systems. Operating Procedure 1-OP-24, Containment Atmosphere Control System, Revision 32, provides the system valve lineup for the Containment Atmosphere Dilution System, a safety-related system.

Contrary to the above, Operating Procedure 1-0P-26 was inadequately established, in that, on and before July 20, 1989, it failed to specify the position for the manual override for valve 2-CAC-CV-2714. The manual override and valve 2-CAC-CV-2714 were shut instead of open from June 7, 1989, to July 20, 1989, with no other documentation of the valve's position.

2. Section D of Appendix A requires instructions for filling and venting the Standby Liquid Control (SLC) System. Operating Procedure 2-0P-05, Standby Liquid Control System, Revision 27, provides instructions for filling and venting the SLC System.

Contrary to the above, Operating Procedure 2-0P-05 was not adequately xmplemented, in that, on August 6, 1989, valve 2-C41-F017, Return to Test Tank Valve, was throttled during filling and venting of the SLC System without any instructions to do so in 2-0P-05.

This is Severity Level IV violation.

Response

I. Admission or Denial of the Violation

1. Inadequate CAD Procedure Carolina Power & Light admits that OP-24, Containment Atmosphere Control System, is inadequate in that it does not identify the manual override valve for 2-CAC-CV-2714.

II. Reason for the Violation

1. Inadequate CAD Procedure An investigation into the cause of the manual override valve for the 2-CAC-CV-2714 being found shut, on July 17, 1989, has been unsuccessful in determining specifically what events led up to the closure. However, on June 27, 1969, when 2-CAC-CV-2714 would not stroke during Periodic Test 16.3, CAD Valve Operability Test, an

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Auxiliary Operator (AO) reported to the Control Operator (CO) that the manual override valve was not. manually closed and that the manual override handwheel was in the "open" position. The A0 initiated a Work Request / Job Order (WR/J0) on the 2-CAC-CV-2714 which was placed on hold by the Maintenaa'.~ Plcnner until a Q list solenoid could be procured. Based on a caa orn of the Resident Inspector, a request for upgrading a commercial grade solenoid valve was initiated approximately two weeks after placing the VR/JO on hold. During the process of upgrading the solenoid, the System Engineer (SE' requested that an attempt to stroke the valve from the Control Room be conducted with Instrumentation and Control (160) technicians stationed at the valve. On July 19, 1989, an I&C technician noticed that the manual override handwheel was in the

" closed" position. The A0 verified that the valve stroked from both Unit I and Unit 2 control boards and the maintenance PMTR was signed off satisf actorily. On July 20, 1989, applicable portions of PT-16.3 were perfornied satisfactorily and the Operations PMTR was signed off.

As evidenced by the above narrative, CP&L has not been able to determine exactly when the manual overrido valve was placed in the closed position. Based on statements of the A0 involved, CP&L is confident that the manual override was "open" on June 27, 1989. The work involving the air accumulator for the 2-CAC-CV-2714 was completed and the cicarance was removed from the air header ,

isolation valve on June 7, 1989. Therefore, CPGL beideves that the work did not result in the mispositioning of the manual override.

However, CP&L acknowledges that had the manual override been listed in OP-24, it would have been added to the clearance and would have been documented as being verified in the "open" position.

In the past, it has been CP&L's policy that valves which are part of a vendor supplied skid system are not listed in ops unless they need-to be manipulated by Operations during startup', shutdown or normal operation of the involved system. Therefore, the manual overrido valves were not placed in OP-24 because their manipulation would only be required if 2-CAC-CV-2714 were to fail to operate pneumatically.

III. Corrective Actions Which Have Been Taken

-1. Inadequate CAD Procedure The investigation and corrective action determination into this event has been coincident with the violation response and no corrective actions have yet been completed.

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," IV. t : Corrective Actions Which Will Be Taken and Dates of Full Compliance (y  :- 1. - -Inadequate CAD Procedure l -a. -PT-16.1-will be revised to require position verification'of the i ' manual override' handwheel for CAC CV-2714 by Noven.ber 30 .

1989.-

b.- OP424 will bs revised to identifyfthe manual override handwheel and its required position by November 30, 1989.

c.- .SD-24 will be' revised to describe the operation of.-

2-CAC CV-2714'by November 30,.1989.

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,d.- -A review will be conducted'by Technical Support to: identify

- < other valves of the same' type as 2-CAC-CV-2714 by December 20,-

, , 1989.

!- e. The valves identified in'the review will have revisions to pts,.

ops, SDs,-P& ids, training and other procedures, as. appropriate,.

.by June 30, 1990.

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I. Admission or Denial of the Violation i

2. Failure to Follow SLC Operatir.g Procedure Carolina Power & Light admits that the operator failed to follow the SLC fill and vent procedure, OP-05, Section 8.1.

II. Reason for the Violation

2. Failure to Follow SLC Operating Procedure On August 6, 1989, the Unit 2 Standby Liquid Control (SLC) system was under clearance. At approximately 1100, Operations was sent up ,

to pull the cicarance, fill and vent the system (in accordance with OP-05, Section 8.1) sad run the applicabic portions of the monthly operability performance test PT-06.1.

After successfully filling and venting the suction side piping, the procedure drains the test tank. Prior to connecting a vent rig to the high point vent valve the procedure lines up the pump discharge to the test tank by opening 2-C41-r016 and 2-C41-F017 (the SLC pump '

discharge header test tank isolation valves).

When the F016 and F017 valves are opened, a flow path exists from  ;

the domineralized water header through the pumps and into the test tank. At this point, the operator is required to remove the pipe cap and attach plastic tubing to the high point vent valve.

By the time the Operator had attached the vent rig he noticed that ,

the test tank was already approximately 50% full and he was  :

concerned that he would not have sufficient test tank capacity to <

! prevent overflowing the test tank during the run. Since the procedure did not address another draining of the test tank until after filling the discharge piping with the 'A' SLC pump, the operator decided to throttle closed the 2-C41-F017 valve to limit '

the amount of domineralized water flow into the test tank. When the "A" SLC pump was started, the pump discharge relief valve lifted and discharged back to the SLC system common suction piping causing the "B" SLC pump suction flange gasket to blow out. The operator did not realize that by throttling the F017 valve the discharge pressure ,

would increase to the point of lifting the discharge relief valve.

Operating philosophy at CP6L allows operators to take actions which are necessary to place equipment in a safe condition from which a procedure can be used. In this instance the operator realized that the test tank level was getting too high but took an inappropriate action by throttling th* discharge of a positivo displacement pump instead of taking other 4rsilable actions to drain the test tank or decrease the supply to it.

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k% III.' Corrective Actions Which llave Been Taken 2.' Tailure to Follow SLC Operating Procedure g_ a.; ' Involved personnel-have been counseled. l IV. Corrective Actions'Which Will'Be.Taken and Dates of Full Compliance -

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2. Failure toLFo110w'S14 Operating procedure a.' The current _ fill'and vent procedure will be evaluated'and' .. [

- ' revised, as appropriate.- to minimize the time from opening the '

C41-F017'to starting the SIC pump and/or to; caution the

' operator on potential 1 filling of the SLC test tank by December 15;-1989.

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b. :This event will be reviewed during Operations Real Time

,' Training by January 30, 1990. .j ;

c.' , Appropriate operator training will-be revised to-include  :;

- training'on the effects of throttling valves at the discharge  ?

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of positivo displecement pumps by June' 15, 1990.  !

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, . 3- Violation C

- Technical Specification 6.8.1.c requires .that written procedures. shall be-established, implemented; and maintained covering survaillance and test activities of safety-related equipment. MMM-03;. Corrective Maintenance, Revision 1.-Section 4.2.8.3. states that postmaintenance. testing requirements

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^ contain legitimate requirements that will verify the maintenance activity has been completed-satisfactorily or the equipment has been returned to service

properly.-LWork Requests / Job Order (WR/J0) 89-AHGE1 specified postmaintenance  ;

test' requirements for containment atmosphere dilution valve 2-CAC-CV-2714 Laf ter repair / replacement of. the accumulator.

. i Contrary to the above, written procedures for postmaintenance' test activities .

.were inadequate for 2-CAC-CV-2714, in that the valve was not cycled on June-7, ,

-1989.-to'show it functioned, nor was the accumulator's ability to hold "E

2-CAC-CV-2714 shut tested. (This testing would have also revealed that the u

-manual: override.for 2-CAC-CV-2714 had been shut.) *

' This is Severity Level IV violation; [

Response-1 I. Admission or Denial'of the Alleged Violation r i

CP&L acknowledges that the written procedures for postmaintenance, test . .

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requirements were inadequate to verify the operability of the 2-CAC-CV-2714.  ;

.11. Reason for.the Violation. -

, Both Maintenance and Operations personnel failed to recognize that the I

, replacement of- the accumulator could have an adversa ef fect on the <

operation of the 2714.

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The' accumulator performs a passive function in that1 1tJstores-the required

- amount of air:that will hold 2-CAC-CV-2714 closed if the supply control ,

' air pressure is low. Normal' operation of the valve is provided through  !

the station pneumatic system and does not use the accumulator. This  ;

, passive function.is -controlled by a snap acting solenoid, which ports the l accumulator ' air to 2-CAC-CV-2714, and a check valve, which prevents loss ,

of accumulator air pressure to the air system. Replacing the accumulator- a '

should-not affect the design function of the 2-CAC-CV-2714. Replacing a solenoid could affect the design function of 2-CAC-CV-2714 because a solenoid could be ported wrong, wired incorrectly or stuck in position. l The involved maintenance activity did not involve the solenoid or the check valve. The accumulator was replaced with an accumulator of the same volumetric capacity and was verified: not to leak. The rational for'not  ;

verifying the operability of the valve following accumulator replacement was the belief that the changoout could not affect operability. As the j accumulator provides the motive force for valve operation in certain e

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conditions, operability.of the valve should have also been verified by ther g

PMTR.x Restoration of the system in accordance with the Operating' . >

_ Procedure was intended to'be,the. vehicle assuring a proper' valve lineup;i.

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showever, as-noted in Violation B, the Operating Procedure was found.to be .

inadequate.

't Ill'.' Corrective Steps Which Have Been Taken j f

< The proper: valve' lineup was restored to the 2714 and the-system was ; ,

returned to operable status. ,

" ' W - Corrective Steps to be Men and When Ful1~ Compliance Will be' Achievhd  !

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-f , ,Real-Time Training will be conducted;for appropriate Maintenance.and 4 g

. Operations personnel on this event; emphasizing the necd'to carefully- -l

assess the possible affects of components not.directly involved-in the maintenance.. This training will address the need to assure that the

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operability of safety-related components / systems is verified-following .

maintenance on the component / system or on subcomponents/ subsystems which .:

s'upport its operability. This1 training will be completed during-the 1990 '!

first quarter. training session' scheduled to be, completed by March 30,  ;

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F 4 b . t t . Violation D. -I V i Technical Specification 6.8.1.c' requires that written procedures be -I L - established governing surveillance activities of safety-related equipment.

Technical Specification 4.6.S.1 requires that Secondary Containment Integrity i be demonstrated by. verifying at 1sast once every 18 months by operating-a- '

standby gas treatment system for one hour and maintaining greater than or

• equal to one quarter inch of vacuum, water gauge, at a flow. rate not exceeding C 3000 cfm. PT-15.4, Secondary Containment Integrity Test, Revision 14,._ l h implements this requirement. t Contrary to the above, surveillance procedure PT-15.4 was inadequately  !

p established, in that .it did not specify the testing configuration of the.

F railroad airlock doors. This resulted in operation, on at 1 cast two

- occasions,-outside the tested configuration. The two occasions when the' inner railroad doors were open were from about 1

30 p.m. until about midnight on 3

- August 1, 1989, for Unit I and from about 2:00 p.m. on August 23, 1989, until' L 9:30 a.m. on August 24, 1989, for Unit 2.  ;

This_is a Severity Level IV violation (Supplement I)'.  ;

Response ,

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p - 1. Admission of Denial of the Alleged Violation .

Carolina Power & Light Company admits that PT-15.4 was inadequate in that

'it did not test for the' operating configuration where an individual  :

railroad access airlock (inner or outer door) was open, q

~ II. Reason for the Violation [

Technical Support Group personnel responsible to ensure the adequacy of

• the' subject periodic test failed to recognize the necessity of ,

individually testing both doors of the airlock in order to account for-expected operating configurations where either door.is opened for an extended' period of time.

III. Corrective Steps.Which Have Been Taken As-an interim measure, on September 1, 1989, Standing Instruction 89-057 was implemented to require establishment of a Limiting Condition for Operation to ensure Secondary Containment integrity of the Reactor Building airlocks whenever it is requested that one of the doors of an airlock is to be opened for greater than one hour, p

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e ' On. September 9, 1989i Special' Procedure SP-89-050_ was performed, which; verified Secondary. Containment zintegrity could .be maintained inL 't accordance with Technical Specifications with the inner railroad-door ,

E open. . Based upon.the test results,~it.is' felt reasonable to conclude-p ,that Secondary Containment was being maintained during the past 18 months ,

p whenever-the inner railroad door was open.

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IV. Corrective Steps to be Taken and When Full Compliance will be Achieved ..

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'PT-15.4 is run at.least once per 18 months,.-to satisfy Technical Specifi- .;

. . cation- 4.6.5.1.b, and 'is normally run during refueling outages.1The-  ;

-next test on Uniti1 will be run on Unit 1 by February'9. 1991, and on l h

Unit 2 by July 28,'1991. The test procedure will be revised by the end  !

of the' current Unit 2 outage (presently scheduled to end February _15, l

1990) to' include a requirement for individual. inspection'of the personnel q

- airlock- and inner ' railroad door seals and for testing with the inner i L , railroad doors open. ..These changes will, help assure that Secondary Containment is maintained whenever one door of a Secondary Containment p 1 airlock is opened and that gross door seal leakage does.not go undetected.

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Violation E

Technical. Specification 6.8.1.a requires that written procedures be .;

established during the activities' recommended in Appendix A of Regulatory Guide 1.33, November 1972. Appendix A,' Section A.3, recommends procedures

- for equipment control (e.g. , loc. king and tagging). . l M .- .- . .

'i Administrative. Instruction al-58,' Equipment Clearance Procedure, Step 15.3.5.2, i

requires that the boundary of a clearance will provide adequate safe working conditions for the scope of work to be performed.

Contrary to the above Al-58 was inadequately implemented, in that..on August i .-

3, 1989,.the boundary of.a clearance did not provide adequate conditions for.  ;

the < secpe of work. Iocal Clearance 2-886 (Clearance to Support StandbyL Liquid Control (SLC) System Relief Valve Removal) for the removal of relief valve 2-C41-F029Ar af fected both SLC ' pumps instead of just the 2A pump as originally intendsd.

This is a Severity Level IV violation (Supplement I) cpplicable to Unit 2 only. .This. clearance problem is a repeat violation. ,

Response

l I. Admission or Denial of the Alleged Violation Carolina Power & Light Company acknowledges the violation occurred as stated. It is noted that an evaluation by the plant Technical Support' l Group determined that during the time frame that the valve flange of 2-C41-F029A was loosened, the 2B SLC pump and associated piping would have beenic~apable of performing the design function.

11. Reason.for the Violation This violation is-attributed to failure to adequately recognize the design of the SLC tank and pump suction piping as the. result inadequate

- attention to detail by the involved Unit 2 Senior Operations Specialist,

, who developed the' clearance, by the responsible Senior Reactor Operator

-(SRO);of the Operations Clearance Center, who verified and approved the adequacy of the clearance, and by Maintenance personnel accepting the clearance.

Contributing factors to this event woro:

1 1. A mind set-on the part of the involved personnel of the Operations Clearance Center, who. wanted to ensure operability of the 2B SLC pump and piping in order to meet Technical Specifications (TS) requirements

(" - for Limiting Conditions for Operation (LCO). TS provides for a seven-day LCO whenever one SLC pump is out of service; however, an eight-hour LCO is entered whenever both SLC pumps are out of service.

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jf My 2.L The involved SRO. utilized a reduced size plant drawing to verify tho' s clearance boundary, which contributed to his. overlooking-the fact

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that- both SLC pumps' utilize a con. mon suction pipe from the SLC

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-3. Due to the relative simplicity of the.SLC System, the~ involved l clearance' accepter. failed to adequately review the scope of the

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1 clearance,las' hung, prior to acceptance for work.  ;

Following the determination that the involved clearance was inadequate,-

a the valve flange of 2-041-F029A was retightened and the clearance'was l

' canceled. A visual inspection of the' valve flange connection was then 'l 1 performed which verified the system integrity and the SLC System was

• returned to standby readiness.

-III.~ Corrective Actions Which llave' Been Taken  ;

i 3 As a result of this event, the involved personnel of the' Operations -'

Clearance Center as well as the involved clearance acceptor were counselod-  !

in order to. stress the importance of attention to detail. In addition, 1 the' involved SRO has been removed from activities requiring a license indefinitely as'a result of this and other past events.

On October 12, 1989, a corporate task' force was initiated to perform an d independent'onsite programmatic review of the equipment-cicarance process .

at the Brunswick Station in order to identify areas for improvement. The-task force,-which is headed by a Nuclear. Staff Support Section Manager, who previously held an SRO license at the Brunswick Station, is comprised of four personnel. - Areas expected.to be covered during this review-will include the following:

Observe the operation of the Operations Clearance Cei.ter.

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@' -2. Evaluation of the historical patterns and trends of equipment cicarance problems. .

3. Comparison of appropriate regulatory guidelines to the-equipment clearance procedure.

IV. ~ Corrective Actions.Which Will Be Taken The task force is intended to complete the. involved field work by the end of October 1989, and will provide a report, by November 30, 1989, for review by the station management and implementation of action (as required). On or before December 31, 1989, a status of the results of the corporate task force study will be submitted which will include a summary of actions planned to help in the prevention of future similar violations.

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m: Violation F' m

]-g ,The Brunswick Steam Electric' Plant, Unit 1. Updated Facility. Operating

' License, DPR-71, Section 2.c.(1), authorizes the facility to operate with

~g- l maximum steady state reactorfcore power levels not in excess of.2436 megawatts.

thermal.

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. Contrary to the above, the facility operated in excess.of 2436 megawatts L thermal from.approximately 7:00 p.m., on August 23,.1989, until epproximately p 6:00 a.m.,on August' 24,'1989.

Response-p B? ;I, , Admission or Denial of the Alleged Violation CP&L acknowledges that Unit 1 operated in excess of 2436 megawatts thermal during the time period noted in the violation.

i II. Reason for the Violation This violation.is' attributed to personnel error by the control operators on Unit I during this time period. These operators failed to recognize

_that reactor thermal power was exceeding the licensed allowable and take effective action, j_ ' During normal operation, reactor. power is continuously recorded in "% ~

power"-on.the reactor turbine gage board through the average power range

~

r . monitors'(APRM), and reactor powerfis recorded in-megawatts thermal hourly on both the balance of plant (BOP) typer and the core-performance periodic!1og P-1. Interviews with the-operators involved determined that they were aware that the reactor power level was high and took actions Eduring the shift to restore power to less than or equal to 2436 megawatts.

On,the shift in question, the Plant Monitor (a licensed control operator) noted that the BOP typer and the P-1 thermal power levels were in excess of 2436 megawatts-thermal and informed the BOP Operator (licensed coperator responsible fortreactivityrcontrol). 1The Plant-Honitor recalls making several recirculation flow reductions on shift and performing a OD-03's, Instantaneous Core Thermal Power and APRM Calibration, to verify a reduction in thermal power. OD-03 printouts for this time period could

-not be found to verify the power reductions as they are not a controlled 3 log, nor are they retained. The result of the flow reductions were not significant enough, nor would they be expected to be significant enough,

-to have been observed on the APRM recorders nor on the recirculation flow recorders. Other than the noted flow reductions, no other actions were identified which the operators took to ensure reactor power was reduced to allowable limits.

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- III;-Corrective Actinns Taken v-; , Reactor power was: reduced toiless;than-or equal'to 2436' megawatts

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, ' thermal.~ The operators involved _were> counseled on the need to assure

, y positive results for-actions taken...in this case, reactor power.less than' '

p. l2436~ megawatts ~following flow reductions and the need to assure operation' f ~

~'withinLlicensed conditions. In addition, specific: requirement's=were B established to monitor reactor thermal power on'an hourly; basis and to ,

['a positively. reduce power!to allowable values.if found-above 2436  !

p: megawatts,. .

L IV. . Corrective Actions Which Will Be Taken and the Date Fcr Compliance c .' . Real-time training is'to.be conducted'for appropriate Operations-' , . --

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. personnel on this' event.';This training is to-be-completed by December-  :

. 15', 1989. '!

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5  ! Violation G b.

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' Technic'a1 Specifications 4.1.5.c.3, requires that the Standby Liquid Control f/U , (SLC)1 System:shall-be demonstrated OPERABL.E at least once per 18 months ddring Lahutdown,byfdemonstrating that'the' pump relief valve setpoint is 1450 +/- 50

.psig.

Contrary to the above,;the Unit 2 SIC System was not demonstrated OPERABLE -

during shutdonn,'in that,-on August 3-6, 1989, .the pump relief valves' setpoint"s-

. - were demonstrated during power operation of Unit 2.

Response

"~ ' Admission or Denial of the Alleged Violation 1.

'CP&L acknowledges that the requirements of Technical Specification 4.1.5.c.S were not properly-implemented by, performing the testing during power operation on Unit 2.

II. . Reason.for the Violation =

In the 1983 time frame, CP&L identified a conflict with performing required surveillances on the diesel generators "during' shutdown" as required by technical specifications. The BNP Technical Specifications

. required that,all fourediesel generators be operable with either or'both units in modes 1, 2, or 3.- As noted in paragraph 40 on page 9 of.the inspection report, the technical specification wording would require that both' units be shutdown in order,to complete the. surveillance

' requirements. Discussions were' initiated with the NRC, through the:

Region II-Section Chief on the potential for discretionary ~onforcement or' an emergency Technical Specifications change to avoid what was considered

-an unreasonable and unjustified dual unit shutdown to perform the noted L surveillance.

LVerba1Eguidance was provided by the Section Chief to Senior Plant Management on the requirements-for testing the diesel generators'"while shutdown." The guidance.provided was:

L1. It is not intended that both units be shutdown to perform required

+

surveillance testing on the diesel generators.

" - 2. The Definitions section of Technical Specifications provides the definitions for the various operational modes. These terms, as q noted in the definitions, are written in upper case, signifying the k uniqueness of the conditions (i.e., hot shutdown, cold shutdown, refuel, etc.). Whenever the technical specifications require that a surveillance or other activity or ACTION be performed in a specific-mode, that node is so noted. An example is found in Technical y Specifications 4.4.1.1.1, where the valvo cycle for the designated  ;

valves is to be performed in COLD SHUTDOWN.  !

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, The wording;found in the diesel generator. specification is written

t. in the lower case; therefore, "during shutdown" applies.to the-

!J , component / system and not the plant operational conditions.

O '

h Based on the guidance.provided by the NRC on the diesel generator testing (dualJunit shutdown concern), the testing requirements were extrapolated W

to- the' SLC relief valves (single unit shutdown concern) for this . testing cycle. During the past, SLC- testing was L,eing performed during COLD i

p ' SHUTDOWN.or REFUEL,.as.the plant fully believes that it,is more appropriate g to do so.-

p g III. Corrective Steps Which Have Been Taken E< Plant management personnel responsible for.providing,the guidance for technical specification required testing and ' operating philosophy now understand the intent for the "during shutdown" guidance previously'given Lonly applies to. dual unit shutdown concerns. This understanding will prevent future misunderstandings of this type from occurring... In addition,.

E. . .the surveillance. test scheduling system was annotated to schedule the SLC:

.iclief valve surveillance-during an outage.

A review of other "during shutdown" requirements in the technical specif1-cations was conducted to ensure compliance was being met. Two additional technical specification surveillances were identified which are not being P performed in accordance with this "during shutdown" definition. Those

surveillances are 4.7.7.1.2.c.1 for the diesel-driven. fire pump and.

4.8,l'.1.2.d.1 for the emergency diesel generators. These surveillances.

-are dual unit shutdown concerns and are considered u .'.se.in agreement b with the guidance provided in 1983. The remaining surveillances'were

.found to be properly echeduled.

IV;- Corrective Steps To Be Taken and When Full Compliance Will bi Achieved CP&L will submit appropriate technical specification changes to clarify..

the surveillance requirement to remove the dual unit shutdown concern for-its emergency diesel! generators by March 30, 1990. The surveillance on

-. <the diesel driven' fire pump will be resolved by CP&L's technical specifi-

, cation" change request--per Generic Letter'86-10. removal of fire protection equipment from technical specifications, o

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Violation Hi h Technical Specification 6.2.3.2 requires that tue .'.'dM t a Nuclear ~ Safety _(ONS)

. Unit be_ responsible for maintaining surveillance of facility. activities to' 1 b provide-independent verification that'these activities are performed correctly, i

-Contrary to the above, as.specified in Regulatory Compliance Instruction .

O L(RCI)-06.6, Rev.~0;: Site Event' Investigation Process, ONS functions as a member of theisite incident" investigation team, a facility activity that-ONS

~

j g 'also maintains. independent surveillance.  ;

i _This is a Severity Level ^IV violation.

Response

n

'I. Admission'or Denia'l of the Violation CP&L acknowledges that it violated Technical. Specifications by allowing C _the ONS_ independent review function of site incident investigation team (SIIT) results to be-performed by the ONS member of the SIIT. -

17. Reason for the Violation .

The SIIT:was established to provide an independent assessment of ,

significant events at Brunswick. CP&L failed-to recognize that having ONS on the SIIT could compromise the independence of ONS should the ONS

• SIIT member also be the independent reviewer. As the SIIT was designed to be independent, and the Technical: Specifications-allow ONS to perform independent reviews of the same type events, CP&L felt that it.was in 4

compliance with Technical Specifications.

III.TCorrective Steps Which Have Been Taken $

CP&L will ' continue to call out ONS when the SIIT is' activated;. however, >

the ONS SIIT member will be performing an independent review function and will not be assigned any specific responsibilities or sign-off functions. There have been no event investigations by the SIIT since the.

notice of violation; therefore, this corrective action has:not been needed to date.

A review'of ONS site activities revealed that ONS performs no other ,

activity similar to the SIIT function which would compromise their -

independence; therefore, this is not considered to be a generic issue.

IV. Corrective Step Which Will be Taken and When Full Compliance Will Be G Achieved RCI-06.6 will be revised by December 1, 1989, to indicate that the ONS member on the SIIT is performing an independent review function and will not be assigned specific responsibilities or sign-off functions.

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Violation I

~ 10CFR50.54(h) requires that the operating license be subject to all Orders of the Commission". Confirmatory Order EA-82-106, dated'Docomber 22, 1982, j J

required the. licensee to implement the Brunswick Improvement Program.(BIP). i BIP Item VI-5 required the licensee to hold' quarterly nuclear safety review meetings.

Contrary to.the above, quarterly corporate nuclear safety review meetings wero~

not held at least during'1988 and 1989.

-Response  ?

1.- -Admission or Denial of-~the Violation r1 CP&L acknowledges that it violated 10CFR50.54(h) by failing to continue {

holding quarterly Corporate Nuclear Safety Review Board (CNSRB)- '

meetings.

L

'II . Reason for the Violation Pursuant to Confirmatory Order EA-82-106, dated December 22,-1982, andlin ,

accordance with 10CFR50.54(h), CP&L expeditiously impicmented the.  :

Brunswick Improvement. Program (BIP), including item VI-5,'which required quarterly CNSRB meetings. 'This fact was confirmed by NRC Region 11

~

. correspondence to CP&L, dated April 3, 1984, which advised that.they ,

". . .have inspected each task action item in the BIP and that CP&L has .!

satisfied the requirements imposed by Confirmatory Order EA-82-106." l Further, Region II stated that."With regard to ongoing items, we find-that.a status report submitted at six-month intervals will be satisfactory."- Of note iscthat one of the original 134 detailed-BIP tasks.specified that'the.167 Management Analysis Corporation (MAC) .

recommendations be reviewed and implemented. The ongoing ~ items referred'  ;

to. by Region II were only 7 of the '168 MAC. recomniendations. CP&L's final ~

six-month. status report (Scrial NLS-86-166), dated May. 30, 1986, stated that those final ongoing items were completed. The intent of the referenced December 22, 1982-Order,.as described in the NRC's transmittal

~

. letter, was to ensure ". . . positive and expeditious completion. . .". of the t -initiatives identified in the Brunswick Improvement Program. CP&L fully ract this intent by impicmenting the vast majority of the BIP items during 1982 (prior-to the Order) and 1983, and completing the remaining seven' ongoing items by May 1986.

With respect to BIP Item VI-5,.the first CNSRB meeting was held on

' October 29, 1982, and meetings continued to be held into 1988. The last available documented meeting minutes are dated September 30, 1988.

However, beginning in late 1987, it became apparent that the primary

-CNSRB goal--an independent assessment of potential safety concerns at

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g CP&L uuclear plants--was being' effectively performed by the Corporate.

k@ Nucicar' Safety (CNS)'Section, and that elimination of the CNSRB could-F' prov_ide additional-stimulation to ensure that potential nuclear safety

,4 4

issues were adequately' addressed within the normal line function.

-Subsequently, based on a belief that the previously referenced correspondence from Region II andz our Hay.1986; Final Status' Report had'

@_ . > " closed" the Order, the CNSRB was: discontinued.'

+

Confirmatory Order EA-82-102 was somewhat 'different than a typical Order ir that it-included tasks that were of-an administrative nature as well

> as tasks of a strict regulatory compliance nature. This has led to' confusions-as to exactly what was required to change or improve specific tasks within overall BIP objectives. By . lett er - dated October- 26,,1987c

-(Serial:. -NLS-87-188), CP&L requested. concurrence with revising specific-4

'BIP commitmants for performance of periodic reviews. Further, by. letter dated October'11, 1988 (Serial: NLS-88-211), CP&L submitted' relevant Justification and requested discontinuance of Confirmatory Order M EA-82-106. To date, no response has been received.

In summary, Carolina Power & Light recognizes that Orders Issued by the NRC under 10CFR50.54 are binding until formally rescinded by the NRC. Duo-to the nature of this order and through referenced correspondence, particular1y'the April 3,1984, NRC to CP&L Letter, CP&L failed 'to

-recognize that the inspection noting compliance was not a rescinding of the order.

III. C_orrective Steps Which Have Been Taken While each of the specific BIP actions taken was appropriate at the timo

' of implementation,- CP&L does not believe that it was the NRC's intent sto require continued implementation of actions that are either no longer necessary or actions whose objectives can be achieved in a more safe or efficient manner. CP&L's conclusion is supported by 10CFR50.59(a)(1).

'The action _in question--existence or nonexistence of CNSRB meetings--will not result, either way, in a change to the technical specifications orlan- 1

. unreviewed safety question, q i

CP&L believes that its justifications for discontinuing the CNSRB remain l valid and does not intend to restart the CNSRB quarterly meetings. The '

strength of our Corporate Nuclear Safety program and our existing corporate structure contain the-necessary tools to implement the goals of L the CNSRB, and to meet the overall intent of BIP Objective VI which stated, "Hore effectively utilize the technical expertise of the ONS and ,

CNS staffs =in enhancing the safety and reliability of plant operations." j

' To improve communications with the NRC, CP&L, in 1988, began development of the CP&L/NRC Interaction Plan. The program goal is to promote 1 improved relationships with the NRC through the guidelines, policy  !

statements, plans and processes contained within the program manual.

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(IVi Corrective ~ Steps Which N111 Be Taken .

As.ovidenced-by-our recent' response _to the NRC's-Diagnostic Evaluation'of

~

w Brunswick, CP&L =is : continuing to focus attention on < those issues which :

will-ensurof that' Brunswick _ operates.at-the: level of excellence that is' idesired'and expected. 'CP&L' expeditiously: implemented.the BIP.as evidenced-by.the-fact that manyjBIP tasks were completed prior to:the issuanceiof.the NRC order. . . Further, _ we will- continue to appropriately -

y change,-;1mplement.and/or modify,our: management. actions to ensure that  ;

the goal of excellence is'meti- The CP&L/NRC interaction Plan'is an~

exaciple of management. actions in response to the need for improved' communication.  :

%- .In this case, we have inadvertently misinterpreted the-methodology._for j making' changes subsequent tof full _ Implementation of Order requirements- *4 however, we have made_ ef forts to have- the Order rescinded and will continue-to do so.

No further corrective actions.are considered necessary as a result of  :

-this violation. ,

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