05000324/LER-1993-003

LER 93-003-00:on 930408,identified That Drywell Spray Outboard Isolation Valve Installed in Reverse Direction. Caused by Design & Installation Error.Appropriate Documents Will Be revised.W/930507 Ltr

ML20056C225
Person / Time
Site:	Brunswick
Issue date:	05/10/1993
From:	Jonathan Brown, Jones T CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BSEP-93-0070, BSEP-93-70, LER-93-003-01, LER-93-3-1, NUDOCS 9305110313
Download: ML20056C225 (6)

LER-2093-003,

Event date:
Report date:
3242093003R00 - NRC Website

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Carolina Poveer & Light Company $

armmesweremzmmmermawam Company Correspondence '

P. O. Box 10429 Southport, N.C. 28461-0429 MAY 071993 l

'i FILE: B09-13510C 10CFR50.73 Serial Not BSEP 93-0070 ,

[

U.S. Nuclear Regulatory Commission {

ATTN Document Control Desk Washington, D. C. 20555

.)

i BRUNSWICK STEAM ELECTRIC PLANT UNIT 2 DOCKET NO. 50-324 j LICENSE NO. DPR-62 l LICENSEE EVENT REPORT 2-93-03 .. j n

Gentlemen:

p In accordance with Title 10 of the Code of Federal Regulations, the enclosed' [

Licensee Event Report is submitted. This report fulfills the requirement for.a : l t

written report within thirty (30) days of a reportable occurrence' and is  !

submitted in accordance with the format set forth in NUREG-1022,L September 1983.  !

Very truly yours, f 1

. M. Brown, Plant Manager - Unit'l '

Brunswick Nuclear Plant  :

-s SFT/

Enclosure cc: Mr. S. D. Ebneter -]

Mr. P. D.~Milano.  ;

i BSEP NRC Resident-Office l

J g5110313930510  !

f S ADOCK 050003 M M n . . .

e n

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROtfED OMB NO. 3150-0104

, (S/92) EXPIRES: 5/31/95 E STIMATED BURDEN PER RE SPONSE TO COMPLY WITH THIS INFORM ATION COLLECT 80N REQUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT (LER) COMMENTS REr,ARD,NG URDEN EST, MATE To THt iNFoRuATioN AND PICDHDS MANAGEMENT BRANCH (MNBR 77141. U.S. NUCLE AR RE GULATORY COMMISSION. W ASHINGTON. DC PO555-DOO1, AND TO THE PAPERWORK REDUCTION PROJECT t3150 0104), OFFICE OF j MANAGEMENT AND BUDGET. WASHrNGTON, DC 20503.

FACILITY NAME (1) DOCKET NUVBER (2) PAGE{3l Brunswick Steam Electric Plant, Unit 2 05000324 1 of 5 TITLE d41 MISSED PRIMARY CONTAINMENT INTEGRITY SURVEILLANCE ON A BODY DRAIN VALVE FOR THE DRYWELL SPRAY OUTBOARD ISCLATION VALVE.

EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

M ONTH DAY YEAR YEAR M ONTH DAY YEAR NUMBER NJMBE R 05000 04 08 93 93 00 05 10 93 Faaun saut DOCKET NUMBER 05000 OPERATING THl3 REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR 1: (Check one or more of the followingM11)

E MODE (9) 20 402M 20.405tc) 50.73(a)(2Hav) 73.71(b)

POWER l LEVEL (10) 000 50.as(cH2) 20.405(aH1 Hii) So.73ta)(2Hvii) OTHER 20 405(aH1Hiii) X 50.73taH2Hil 50.73(aH2HviiiHA) (Specify in Abstract 5

20.405(aH1Hiv) 50.73(aH2Hii) 50.73(aH2HviiiHB)

. 20.405taH1 Hv) 50 73(aH2Heiil 50.73(a)(2Hx)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER Theresa M. Jones, Regulatory Compliance Specialist (919) 457-2039 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

C A USE SYSTEM COMPONENT M ANUF A CTURE R CAUSE SYS EM COMPDNE NT MANUF ACTURER D O PD -

t SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR EXPECTED SUBMISSION ,

YES ire v. compiet. E APE CTED susMisS10N DATEi z

No DATE (15)  !

ABSTRACT (Umst to 1400 spaces,i e. approximately fatteen single space typewritten lines) (16)

On April 8, 1993, with both units i- 'd shutdown, an engineering field inspection -

resulting from NRC concerns invol- t e surveillance of Primary Containment System Isolation (PCIS) valve vent and c .alves identified that the 2-E11-F016B, Drywell Spray Outboard Isolation Valve, was installed in the reverse direction. This ,

configuration exposed the associated body drain valve, 2-E11-V125, to primary containment pressure and thereby requires the valve to be periodically tested in accordance with the requirements of the Technical Specification. Because the installation configuration was not incorporated in the appropriate design documents, the 2-E11-V125 valve was not included in the PCIS valve surveillance program. Corrective actions include appropriate revisions to plant documentation to ensure the prcper classification and surveillance testing of the 2-E11-V125 valve and an examination of other plant installed PCIS throttle valves to ensure proper installation configuration.

1 The present configuration of the 2-E11-F016B resulted in the 2-E11-V125 being within the  ;

Appendix "J" test boundary-. Testing of the 2-E11-F016B valve verified that any observed  !

leakage was within the acceptance criteria and was included within the Primary l Containment Leakage total. Therefore, the installed configuration of the 2-E11-F016B does not create the potential for increased dose to the public.

i The cause classification for this event per the criteria of NUREG-1022 is (B) Design, '

Manufacturing, Construction / Installation.

NRC FORM 366A U. S. NUCLEAR REOULATORY COMMISSION APPROVED OMB NO. 3150-0104

, (5/92) EXP!RES: 5/31/95 E STIM ATED BURDEN PER RESPONSE TO COMPLY WITH THt$

INF ORM ATION COLLE CTION RE QUE ST: 60.0 HRS. FORWARD LICENSEE EVENT REPORT (LER) COMMENTS REGARomG euRoEN EsT,u ATE TO THE mFonMAnouNo TEXT CONTINUATION RE CORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAP RIGULATORY COMMISSION, WASHINGTON. DC 20555-0D01, AND TO THE PAPERWORK REDUCTlDN PROJECT (3150-01046, OFFICE OF M ANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (31  :

SE QUE NTIAL REVISION Brunswick Steam Electric Plant """ "" "

05000324 2 of 5' Unit 2 93 00 ,

A: .i

'EKT (1f rnare space is required, use additional NRC Form 366A's] (17)

TITLE MISSED PRIMARY CONTAINMENT INTEGRITY SURVEILLANCE ON A BODY DRAIN VALVE FOR THE DRYWELL SPRAY OUTBOARD ISOLATION VALVE.  !

r INITIAL CONDITIONS Unit 2 was in COLD SHUTDOWN in day 352 of a dual unit outage. An NRC Operational Readiness Assessment Team (ORAT) was on site. A member of the NRC team questioned why certain vent and drain valves on valves which are part of ' the primary .

containment boundary are not included in Periodic Test (PT) 02.2.4a, Primary  !

Containment Integrity Verification - Containment External.

PT-02.2.4a satisfies the PRIMARY CONTAINMENT INTEGRITY Technical Specification Surveillance 4.6.1.1.a . Technical Specification 4.6.1.1.a requires that integrity be demonstrated: ,

At least once per 31 days by verifying that all primary containment penetrations

• not capable of being closed by OPERABLE containment automatic -

isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in position, ...

The (*) allows certain valves, blind flanges and deactivated automatic valves which ,

are locked, sealed, or otherwise secured in the closed position in inaccessible areas, to be excepted from the 31 day verification and verified during each COLD ,

SHUTDOWh.

EVENT NARRATIVE ,

During a field inspection while responding to the NRC CRAT team member's question, ,

the System Engineer noted that the .2-E11-F016B, Drywell Spray Outboard Isolation l Valve, was installed in the reverse direction. This exposes the associated body i drain valve, 2-E11-V125, to primary containment pressure thereby requiring it to

.be verified in accordance with Technical Specification 4.6.1.1.a. On April 22,  ;

1993, PT-02.2.4a was revised to include a surveillance of the 2-E11-V125.  ;

The valves in question are globe valves. The design of globe valves results in the  !

body drain valves for outboard globe valves being outside the primary containment ,

pressure boundary. Therefore, the body drain valves are not required to maintain  ;

primary containment integrity and are not required to be tested in accordance with Technical Specification 4.6.1.1.a.

On June 21, 1974, the System Description, SD-12, Primary Containment Isolation ,

System, revision 00 was approved. The SD did not include the E11-V125. l On Septenber 9, 1974, a letter from United Engineers and Constructors Inc. (UE&C) was generated stating: l l

that valve 2-E11-F016B was installed so that normal flow is on top of i the valve disc instead of under the disc. . . contrary to that 1 prescribed by Anchor Valve Co. ... UE&C was requested to review this j problem and make recommendations... UE&C determined that ...

technically the valve will crerate creceriv and provide the thrcttlino

NRC FORM 366A U. S. NUCLEAR REGULATORY COMMISSION APPROVED OMB NO. 3150-0104

, (5/92) EXPIRES: 5/31/95 E STIM ATED ttuRDEN PER RESPONSE TO COMPLY WITH THl$

INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT (LER) COMMEWS uGA ,NG BUetN EST,M ATE 10 Tm ,,ORMolOuNo TEXT CONTINUATION M CO@S MANAGNEW BRANCH (MNEtB 77141. U.S. NUCLE AR P.iGULATOMY COMMISSION, WASHINGTON. DC 20$b5 0001, AND TO THE FAPERWORK REDUCTION PROJECT (3150-0104;. OFFICE OF MANAGEMENT AND BUDGET. % ASHINGTON. DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER 16) PAGE (3)

SE QUE NTIAL REVISION Brunswick Steam Electric Plant " " " " """

05000324 3 of 5 Unit 2 93 00

' EXT Uf more space is required, use additionalNRC Form 366A's) (17) capabilities required... Should it be required that the installation ,

of valve 2-E11-F016B be changed at this time, it could have a substantial schedule impact; therefore, UE&C recommends that valve 2-E11-F016B remain installed "as is".

The as installed valve configuration was not incorporated into design documents for future reference.

On January 13, 1980, PT-02.2.4, Primary Containment Isolation Valve verification, revision 00, was approved. This test included accessible and inaccessible valves and allowed for valves which were in ccessible during power operations to be marked "N/A". The test did not include a surveillance of 2-E11-V125.

On September 10, 1982, PT-02.2.4a, Primary Containment Integrity Verification -

Containment External, revision 00, was approved. The 2-E11-V125 valve was included for surveillance.

On September 14, 1982, The Report en the Accentability of the Primary Containment Isol ation Valves was approved. The report listed the 2-E11-V125 as a PCIS valve based on a conservative approach that generically incorporated body drain valves.

A revision to PT-02.2.4, revision 06, incorporated the report information and deleted the " accessible" (i.e. , external /31 day surveillance required) containment checks which the new PT-02.2.4a incorporated. ,

On August 24, 1983, SD-12, revision 04, was approved to incorporate the report information, including the determination that the 2-E11-V125 was considered a PCIS valve.

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 utilizing piping and instrument diagrams (P&ID). On December 29, 1989, s PT-02.2.4a. revision 17 was approved. The 2-E11-V125 was deleted from the procedure as a PCIS valve.

On March 27, 1990, SD-12, revision 14, was approved to incorporate the results of  ;

the 1989 penetration review.

During the first quarter of 1991, a cross check of the Equipment Database System (EDBS) listing of PCIS valves and SD-12 was performed to support the addition of the PCIS valves to Regulatcry Compliance Instruction (RCI) 02.6, Cross Reference to Technical Specifications. The PCIS designator for 2-E11-V125 in EDBS was removed based on the fact that it was a body drain valve for a globe valve.

On April 15, 1993, an Engineering Work. Request (EWR) #12141 evaluating operability (

of the 2-E11-F016B configuration was approved. The EWR considered that 2-E11-F016B  !

is a 10CFR50 Appendix "J" valve and is tested per the refueling /24 month cycle.  ;

In its present configuration the 2-E11-V125 is a part of the test boundary. During  ;

testing both valves are subjected to simulated accident pressures of 49 psig. The testing method used ensures. that any observed leakage is verified to meet the acceptance criteria and is included in the Primary Containment leakage total.

The Mechanical Analysis and Calculation for torque switch setting and seating thrust of the 2-E11-F016B has been revised to include the present installed configuration of the valve. Results of the VOTES testing performed this outage were reviewed against the newly revised calculations and the as left data was I determined to be within the rances specified in the calculation.

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NRC FORM 366A U. S, NUCLEAR REGULATORY COMMISSION APPROVED OMG NO. 3150-0104 (5/92) EXPIRES: 5/31/95 y ESTIMATED BURDEN PER RESPONSE TD C OMPLY WITH THIS INFORMATION COLLE CTION REQUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT (LER) cOMMtNTs RE o ARDiNo eURoE N ESTluATE TO THE iNFORu avion ANo RE C ORDS MANAGEMENT BRANCH IMNBB 7714), U.S. NUCLE AP TEXT CONTINUATION REGULATORY COMMISSION, WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, W ASHINGTON, DC 20503.

FACIUTY NAME (1) DOCKET NUMBER th LER NUMBER 16) PAGE 13)

SE QUE NTIAL REVISION Brunswick Steam Electric Plant """"" """""

05000324 4 of 5 Unit 2 ,

93 00

' EXT (If enore space is required, use additionalNRC form 366A'sl (1h The present hydraulic characteristics were determined to be bounded by the original hydraulic calculation.

The ENR concluded that direction of flow through the subject valve has no significant effect on the valve's ability to perform its intended function and that the 2-E11-F016B and 2-E11-V125 should be considered operable.

On April 22, 19 9 3, PT- 02. 2 . 4 a , revision 27, was approved to incorporated the 2-E11-V125 for surveillance.

CAUSE OF EVENT The cause of this event is failure to incorporate the installation configuration in the appropriate design documents for future reference.

CORRECTIVE ACTIONS On April 22, 1993, PT-02.2.4a was revised to include a surveillance of the 2-E11-V125.

The appropriate plant documents will be revised to incorporate the 2-Ell-V125 as a PCIS valve by December 1, 1993.

The 1989 penetration review deleted outboard PCIS globe valve body drain valves from surveillance testing based on the assumption that the globe valve are installed with the designed orientation. The reverse installation of the 2-E11-F016B invalidated that assumption. Therefore, to revalidate the penetration review an examination of the Unit 1 and Unit 2 PCIS globe valves was performed. The results of this examination did not reveal any deficiencies.

SAFETY ASSESSMENT The present configuration of the 2-E11-F016B resulted in the 2-E11-V125 being within the Appendix 'J" test boundary. Testing of the 2-E11-F016B valve verified that any observed leakage was within the acceptance criteria and was included within the Primary Containment Leakage total. Therefore, the installed configuration of the 2-E11-F016B does not create the potential for increased dose to the public.

PREVIOUS SIMILAR EVENTS This is considered an isolated event, design information related to original improper design installation was not properly documented.

EIIS COMPONENT IDENTIFICATION Sys t em /Comoonqqt;. EIIS Code Containment Leakage Control System (PCIS) BD

. iNRp[ORM 300A - U. S. NUCLEAR REGULATORY COMMISSION  ; APPROVED OME NO. 3150-0104

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' EXT tlf truire space os requerd. use additionalNRC form 36CA's! (17)

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