ML19332E906

Responds to Violations Noted in Insp Repts 50-324/89-32 & 50-325/89-32.Corrective Actions:Members of Inservice Insp Group Received Specific Counseling Re Details of Subj Equipment Clearance Violation

ML19332E906
Person / Time
Site:	Brunswick
Issue date:	12/08/1989
From:	Harness J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BSEP-89-1093, NUDOCS 8912130136
Download: ML19332E906 (5)

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4 Md . ' 4f f Carolina Power & Light Company Brunswick Nuclear Project P. O. Box-10429 Southport, NC- 28461-0429 December 8,1989 FILE: B09-135100 ~

10CFR2.201 SERIAL: BSEP/89-1093 U;S. Nuclear Regulatory Commission

' KITN : Document Control Desk-Washington, DC 20555 p ~BRUNSWICR STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCRET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS Gentlemen- I i

The Brunswick Steam Electric Plant (BSEP) has received ISE inspection Reports N 50-325/89-32 and 50-324/89-32 and finds that it does not contain information of a proprietary nature. -

This report 1dentified nine items.that appeared to be in noncompliance with [

lNRC requirements. Enclosed is' Carolina Power & Light Company's response to "these violations. I

-l Very truly yours, ,

/ h j J. L. Harn ca, General Manager v runswick h cicar Project MJP/mcg Enclosure- i cci Mr. S. D. Ebneter Mr. E. G. Tourigny  ;

BSEP NRC Resident Office .,

8912130136 891208 '

PDR ADOCK 05000324 l Q PDC l 7

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[ - EVIDIhTION A h 10CFR50ll Appendix'B,_ Criterion XVll, and the liccasee's accepted Quality.

W.  : Assurance (QA) Program collectively require that sufficient records be _l

@' maintained to provide. documentary evidence of the accomplishment of. activities - J affecting quality. Technical Specification 6.10.1 further states that= records of surveillance activities shall be retained for at least five years.-

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Contrary to'the above, records of activities regarding the venting and

-draining' of cont.ainment penetrations before local leak rate testing were not being maintained for five years.

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

, ' RESPONSE' u

Acceptance or: Denial of the Violation

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, CP&L~ acknowledges that the documentation necessary to verify that no-O; static water head exists external to a test valve, which could mask

' leakage during the performance of the local leak rate test, is not;being s maintained.for the required five year period.

4 I I .-- Reason for the Violation

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The periodic test procedures (i.e., PT-20.3.and PT-20.3a.1 .4) governing the performance of Appendix J Type 'C' local leak rate tests'specify draining of the test volume. To ensure that the test volume is drained, the test procedures are written to initiate an equipment clearance. When Operations personnel hang the' equipment clearance, they open the appropriate valves to drain the test volume. In-addition, a step is

. -incorporated-in each test procedure to have the: test technician accept

.the equipment clearance. This-acceptance verifies the equipment clearance. reflects the required position specified in the procedure. ,

J' g . Some test procedures may have water in the test volume after the equipment o clearance. For these tests, step (s) are included in the test sequence to ensure the test volume ~is drained prior to the performance of the test. These test procedures are QA records and are retained as required .)

by Technical Specification 6.10.1. j i

Where static water head is 'known' to exist external to the test valve, the test procedure is written to elevate the test pressure to overcome the known water head, or provisions are stated in the test procedures to provide proper guidance for draining. For these tests, Technical Speci-g' fication 6.10.1 is met since the test procedure is a QA record and retained as required by Technical Specification 6.10.1. j i

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.For-the remaining tests-within a fluid-boundary, the present practice is l

as stated in'the violation. The-151~ group completes a Clearance; Request.

Formf(Attachment L'of AI-58), along with the-appropriate equipment clearance for proper _ valve alignment. The completion of the Clearance Request Form identifies. the reason of the request (i.e., LLRT of valve

XX-XXX), whether a fluid boundary exists, and whether-the system needs to

- ?O lbe drained.

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In these cases,-'the ISI' group-has not specified how the system should be 1

drained. Not specifying how operations will drain the affected system 1

$ allows Operations personnel to review.the work on the affected system and initiate'one clearance to establish an appropriate boundary. This is a' U g'ood ALARA practico. By not providing Operations with specific. directions for- draining a systemL for- the performance of a LLLRT, some tests may have I;' '

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, static water head against the tested valve if the system is drained by y Operations personnel not familiar with-Appendix J requirements, n This inadequacy in the test. procedures in believed to have had no effect-on the previous Appendix'J Type 'C' local leak rate test results. If

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static water is present on the test valve after draining,-this water will-be at a minimum because of the orientation of the piping and the location of the. vent. Thus, head pressure is minimum, and the water should not mask' leakage at the required-test pressure (49 psig). In addition, the ISI-EE group has.provided the necessary communication with the Operations. personnel hanging-the-draining ~ clearance to ensure they understand how the-system b should:be drained for local leak rate testing.

-III. Corrective Action Which llave Been Taken Until the; appropriate test procedures are permanently revised, a temporary revision will be initiated by the ISI group, as required, to provide the

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necessary guidance and' documentation (i.e., how to drain the system; H ..

elevate the-test pressure, etc.) to ensure that-any water which may exist:

on the back side of the valve will not mask leakage. This temporary revision will become a QA record and comply with Technical Specification

'6.10.1.

IV. - Corrective Action to Prevent Recurrence and Date of Full Compliance I b The ISI group will revise the appropriate test procedures to provide the necessary guidance and documentation (i.e., how to drain the system,-

g' elevate'the test pressure, etc.) to ensure that any water which may exist on the back side of the valve will not mask leakage and to ensure com-pliance with Technical Specification 6.10.1. The permanent revision of appropriate test procedures will be completed by the start of the Unit 1  ;

Refueling Outage, currently scheduled to start June 1990.  !

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- p VIOLATION B.

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J :10CFR50~ Appendix B, Criterion XIV and the licensee's accepted QA Program.

, (FSAR) Section.17.2.14)'co11ectively require that measures shall be:

-established!for indicating the operating status of. structures,isystems, and w

' components of the nuclear power plant such as by-tagging valves and switches, eto prevent inadvertent operation. Additionally, the licensee's Administrative Instruction'Al-58,. Equipment Clearance Procedure,-Revision 29, provides k controls for plant systems.and equipment under clearance and states the' duties:

fis and responsibilities of various plant personnel for controlling clearances L(valve tags). ;l i

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, Contrary to the above,' an unauthorized licensee-employee was observed-

operating a service air valve that was under an active clearance (tagged-

-closed).

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This-~is,a Severity-Level V Violation (Supplement I),' applicable'to Unit 2-

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RESPONSE

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• I '. . Admission,or Denial of the Alleged Violation t

E ' Carolina Power &-Light acknowledges the violation occurred as stated.

'II. Reasonifor the Violation:

While' setting up1 test equipment, to supply' Service Air (SA) pressure from SA isolation valve 2-SA-V351;to perform a local leak rate test (LLRT),

K th'e involved'LLRT technician, who is a member of the In-Service Inspection-(ISI) Group, failed to-visually determine that the valve was under equipment 1 clearance in the closed position.- The technician stated-that the. equipment clearance tag on the valve w'as partially obscured from

-the view by a-coiled electrical cord wrapped around the valve. When the technician opened the valve approximately one turn in order to purge the test equipment, the electrical cord partially fell away from the valve-

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p 'handwhcc1 to reveal the existence of the clearance tag at which time the-n technician immediately closed the valve.

CP&L's-assessment of the circumstances of this occurrence determined that 3; the subject clearance tag was sufficiently visible for visual detection i'. by the technician prior to operation of the valvo. The tag was visible l from several feet away by the Resident NRC inspector who witnessed the .

event. :As such it is concluded the event was the result of isolated 1 g personnel error due to inadequate attention to detail by the involved j technician. The basis of this conclusion is supported by an HPES causal analysis of the event.

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b- '111.l Corrective Steps Which llave Boon Taken

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k, lAs a. result of<this occurrence, appropriate / administrative; disciplinary .

. action was taken concerning the involved: technician. On. September 13.and

[(g 14',X1989, members of the ISI Group' received specific counseling- t concerning- this ; event that includedca discussion- of the~ following:

l h .1. . The details of the~ subject equipment cicarancefviolatlon.  ;

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y. 2. The importance of procedura1' compliance:and: attention to detail.- ,,

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- .3.' Ensuring adequate time is devoted to_ accomplish the' job properly.  ;

f 4 ', Steps.which should.be immediately tak'en should.such an event

. reoccur. .

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- In addition, the circumstances of this occurrence were covered during

, 'Real-Time' Training for members-of the plant = Technical Support Group, ,

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. completed.on November 2, 1989.

IV. Corrective Steps.Which Will be-Taken and When Full Compliance will be-

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No further-action is. planned regarding this occurrence'as it isifelt full compliance has-been achieved. . .

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