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Carolina Power & Light Company

-,nrns Ai0 0b;, Brunswick Steam Electric Plant! P. O. Box 10429'

Southport, NC 28461-0429December 2, 1982

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FILE: B09-13510ESERIAL: BSEP/82-2679

! Mr. James P. O'Reilly, DirectorU. S. Nuclear Regulatory CommissionRegion II, Suite 3100

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i 101 Marietta Street N.W.

| Atlanta, GA 303031

) BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 & 2'LICENSE NOS. DPR-71 AND DPR-62DOCKET NOS. 50-325 AND 50-324

RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS,

I Dear Mr. O'Reilly:

The Brunswick Steam Electric Plant (BSEP) has received IE Inspection Report50-324/82-39 and 50-325/82-39 and finds that it does not contain anyinformation of a proprietary nature. As per a telephone conversation with

j Mr. A. K. Hardin on November 23, 1982, this response is being submitted five

j days late.*

: The report identified three items that appear to be in noncompliance with NRCI requirements. These items and Carolina Power & Light Company's response to

each are addressed in the following text:

Violation A: (Severity Level V)

Technical Specification 6.8.1.2 requires that written procedures shall be'

implemented covering activities specified in Appendix A of Regulatory Guide 1.33,November 1972. Item F.2. requires procedures for loss of flux indication.

j Procedure EI-13, SRM or IRM Neutron Monitoring System Failure, step 3.2.1.8,requires that Technical Specifications be consulted if more than two SRMs are L

inoperative. Technical Specification 3.3.5.4.b requires that when two or moreSRMs are inoperable, lock the reactor mode switch in the shutdown position

i within one hour.

Contrary to the above, on October 12, 1982, Technical Specifications were not i

| consulted for loss of SRM in that reactor mode switch was placed in theshutdown position within one hour, but was not locked as required by Technical

i Specification 3.3.5.4.b. This condition existed for one hour and forty-fiveminutes before the SRM's drive power was restored and the SRMs were inserted.

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! 8301040399 821209PDR ADOCK 05000324G PDR

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Mr. James P. O'Reilly -2-

Carolina Power _& Light Company's Response

Carolina Power & Light Company acknowledges that the failure to lock thereactor mode switch in the shutdown position within one hour after identifyingthat the SRMs were inoperable is a violation of NRC requirements. A critiqueof this violation revealed that approximately twelve emergency procedures wereapplicable, at least in part, during the events which precipitated thisviolation. Although the procedures were reviewed during the event, the reviewwas not performed in adequate detail on the loss of SRM/IRM monitors to detectthe requirement to lock the modo switch in shutdown.

During the time frame from the realization that the SRMs were inoperable untilthe time when the SRMs were returned to service, the reactor was beingmonitored and maintained in a safe shutdown condition. Following the scram,the mode switch was immediately placed in the shutdown position. When it wasnoted that the SRMs would not drive back into the core to supply reactor powerindication in its appropriate range, additional monitoring was performed onthe rod position indications to ensure that all rods were inserted. Also,decreasing power was verified on all channels. The probability of a rodwithdrawal was extremely remote due to the rod blocks generated both with themode switch in the shutdown posit. ion (even though it was not locked) and withthe low count rate on the SRMs with them withdrawn.

Prior to realizing that the mode switch should be locked in the shutdownposition, power was restored to the SRMs and they were inserted and returnedto service. A memorandum was issued by the Manager - Operations onOctober 22, 1982, briefly reviewing this event and reinforcing the need foradequate reviews of all applicable Emergency Instructions during a casualtysituation. Also, to further define the use of Emergency Instructions,Operating Instruction 1, Operating Principals and Philosophy, will be revisedby December 1982, to provide more detailed guidance on the use of EmergencyInstructions during an emergency situation. To provide procedural guidance

i for restoring power quickly to a deenergized emergency bus, OperatingProcedure 50-1 was revised on November 3, 1982, to allow cross-tying the busto an operable diesel generator.

Violation B: (Severity Level V)

Technical Specification 6.8.1.a requires that written procedures shall beestablished covering activities specified in Appendix A of Regulatory Guide 1.33November 1982. Item 3, of the guide, requires procedures for startup,operation and shutdown of safety-related BWR systems.

Contrary to the above, adequate procedures were not established for theoperation of safety-related instrumentation in that a valve required for theproper alignment of containment isolation switches B21-PS-N056C and D was notaddressed in its controlling procedure OP-30.

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Mr. James P. O'Reilly -3-

; Carolina Power & Light Company's Response

Carolina Power & Light Company acknowledges that the failure to establishadequate procedures for the containment isolation pressure switchesB21-PS-N056C and D is a violation of NRC requirements. When developing thevalve lineup listing for Operating Procedure 30 (OP-30), piping diagram9527-D-2025 was used to obtain the valve listings for the instrumentation. It

was not realized at that time that all valves associated with theinstrumentation were not on the piping diagram, as some valves are also found,

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on the instrumentation diagram (9527-LL-7044 in this case). A subsequentcontributor to this event was the Auxiliary Operators' failure to recognizewhile performing system lineups that the valve found shut was not included onthe lineup. It could not be determined how the valve was closed.

The isolation valve for the B21-PS-N056C and D instruments was immediately

i opened to restore the instruments to service. A complete instrument line| walkdown was performed which identified several valves which were not included

on the valve lineup. OP-30 has been revised to include all instrumentisolation valves.

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; As a result of the valve discrepancies identified with the N056 instruments, a

i complete instrument piping walkdown was performed on those safety system! instruments listed in Operating Instruction 18. This walkdown revealed

several other discrepancies which are noted along with the corrective actionsin Attachment 1. This walkdown included both units' instrumentation piping.

The root causes of this event appear to be the lack of understanding byOperations personnel of the interrelationship between the piping diagrams andthe instrument diagrams, and the failure to recognize during previous lineupsthat valves associated with instrument piping were not included in the valve

i lineup. A standing instruction will be developed to alert Operationspersonnel of the piping / instrument diagram interface and to caution thosepersonnel to investigate apparent discrepancies between procedures and"as-builts." A copy of this information will be forwarded to the Training

| group for incorporation into operator training. This instruction will be

| established by December 31, 1982, and will be reviewed by the Operationspersonnel by January 31, 1983. Additionally, the plant is currently rewriting

i all of its Operating Procedures. This information will be reviewed with the

! individuals working on that project to assure appropriate actions are taken to

|include all instrumentation valves in their respective operating procedure.

| Violation C: (Severity Level V)

Technical Specification 3.3.2, Table 3.3.2-1 item 1.e., requires the condenservacuum - low isolation actuation instrumentation to be operable in conditions1 and 2 with reactor steam pressure greater than 500 psig.

Contrary to the above, on September 3, 1982, with reactor in condition 2 andreactor steam pressure at 548 psig, the condenser vacuum - low isolationactuation instruments were inoperable in that the instrument bypass switcheswere found in the bypass position.

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Mr. James P. O'Reilly -4-

Carolina Power & Light Company's Response

Carolina Power & Light Company acknowledges that the failure to have thecondenser vacuum - low isolation actuation instrumentation operable at lessthan or equal to 500 psig reactor vessel pressure was a violation of NRCrequirements.

This event occurred due to inadequate communications between the siteRegulatory Compliance personnel and NRC personnel. While performing theTechnical Specification procedural controls review required by the July 2 andJuly 20, 1982, Confirmation of Action letters, several items in the BrunswickTechnical Specifications were identified as requiring amending prior tocperation due to their nonapplicability or other identified reasons.Following discussions with I&E and NRR personnel, it was agreed that enerechanges were administrative in nature, that they should ba submitted forapproval prior to startup, and that operation would be regulated by therequested changes until the amendment was submitted by NRR. Due to anapparent lapse in communications, the Regulatory Compliance Unit thought thatthe condenser vacuum - low change was included in that group of administrative

: changes, and thus the requirement was removed from the plant procedures.

Appropriate plant procedures have been revised to require that the condenservacuum - low isolation actuation instrumentation be operable when reactorvessel pressure is greater than 500 psig. To prevent violations of this

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nature'in the future, plant procedures will be developed to provide guidancefor hand 1 big unique changes to the Technical Specifications. These proceduresshould be implemented by February 28, .1983. Should any unique change be

; required prior to the implementation of the procedure, specific approval ofthe NRR/CP&L agreement will be obtained by the Plant Nuclear Safety Committee

1 and the On-site Safety Committee.

Very truly yours,i

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C. R. Dietz, General ManagerBrunswick Steam Electric Plant

RMP/mcg/LETCG

Enclosure

cc: Mr. R. C. DeYoung

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ENCLOSURE 1

UNIT INSTRUMENT NUMBER DISCREPANCY CORRECTION

1 and 2 B21-PS-N056A-D Instrument root valves Added valves to OP-30not listed on valve valve lineup sheet andlineup sheet and in repositioned to cor-the incorrect physical rect position.position. (OP-30, revision 18)

1 C71-N002B,C,D Instrument isolation OP revised to add.

Ivalves not listed on additional instrument

; valve lineup sheets. valves.(OP-01, revision 20)

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2 C72-N002A,B,C,D Instrument isolation OP revised to reflectvalves missing from missing valves andvalve lineup sheets correct nomenclature.,

and/or mislabeled. (OP-01, revision 20)

1 B21-PT-N015A-D All four rack isolation OP revised to add rackvalves missing from isolation valves.valve lineup sheets. (0P-25, revision 15)

1 B21-PDT-N006B Instrument valves not OP revised to reflectincluded on valve all instrument valves.,

lineup sheets. (0P-01, revision 19)

i 2 G31-dFS-N603A,B Some isolation valves All valves are noted on; to AP detectors that corrected OP-14,

! feed this instrument revision 38were not included onvalve lineup sheets.

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