IR 05000324/1988030

Insp Repts 50-324/88-30 & 50-325/88-30 on 880731-0805.No Violations or Deviations Noted.Major Areas Inspected: Followup to Licensee Safety Sys Functional Insp of HPCI Sys & Followup to Deficiencies in Engineering Work Request Sys

ML20154J165
Person / Time
Site:	Brunswick
Issue date:	09/01/1988
From:	Belisle G, Degraff M, Russell Gibbs NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20154J156	List: IR 05000324/1988030 ML20154J153
References
50-324-88-30, 50-325-88-30, NUDOCS 8809220266
Download: ML20154J165 (7)

Text

_ _ _ _ _ _ _

, ,

,p"Af 820 UNITED STATES

, 9'o NUCLE AR REGULATORY COMMISSION

'# REGION il

[" ) n y,.

• '

,, j 101 MARIETTA STREET. 'e ATLANTA, GEORGIA 3o323

%' o 4*...*s'

Report Nos.: 50-325/88-30 and 50-324/SS-30 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.. OPR-71 and DPR-62 Facility Name: Brunswick 1 and 2

,

i Inspection Conducted: July 31 - August 5, 1938 Inspectors: st / ,[/f[3 R. Giobs b' 2[ K2 Date Signed

/ *

fl $G ?1f YZbb??

M.'DeGraff Date Signed Approved by: / % .: # iY//i4

~

G. A. Belisle, Settlon Chief D' ate Signed Division of Reactor Safety l

I l SUMMARY

!

'

Scope: This routine, unannounced inspection was conducted in, the areas of followup to the Carolina Power and Light Company Safety Systen Functional Inspection of the High Pressure Coolant Injection system and followup to deficiencies identified in the Engineering Work i Request system identified in NRC Inspection Reports 50-324/57-31 and l 50-325/87-3 !

Results: In the areas inspected, violations or deviations were not identified.

J r

.

I

i j

f$[kob

$4

,

,

-

o .

. .

.

,.

.

!

REPORT DETAILS t

.

,

Persons Contacted Licensee Employees i

!

• K. Altman, maintenance Manager 0. Anderson, Project Engineer, Fire Protection {

.

• R. Creech, Supervisor, Instrumentation and Controls

• Doorman, Quality Assurance Supervisor

• K. Enzor, Director, Regulatory Compliance D.~Foti, Contractor, Fire Protection  :

• J. Harness, General Manager  !

,

• A. Hegler, Operations Superintendent i

• R. Helme, Manager, Technical Support l

, *P. Howe, Site Vice President  ;

, *M. Jones, Director, On-Site Nuclear Safety  ;

• R. Poulk, Project Specialist  !

! *C. Robertson, Supervisor, Engineering and Construction i

,

• J. Smith, Director, Administrative Support '

1 M. Worth, Engineering Supervisor, Discipline  !

• T. Wyllie, Manager, Engineering and Construction t

'

Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, security force members, '

technicians, and administrative personne t 4 NRC Resident Inspectors  !

!

• Levis f l

,

"Attended exit interview l Action on Previous Inspection Findings {

i (0 pen) Violation 50-324/87-31-01 and 50-325/87-32-01: Lack ef prompt and l

adequate corrective action in resolving site engineering work request ;

'

See paragraph 3.a.

i (0 pen) Violation 50 324/87-31-02 and 50-325/87-32-02: Failure to document !

'

the results of engineering reviews of site engineering work requests. See !

j paragraph 3, '

i i (0 pen) Violation 50-324/87-31-03 and 50-325/87-32-03: Failure to maintain ,

'

the core spray suction relief valves installed as required by United Sates l

>

of America Standard B31.1, Power Pipin See paragraph 3, !

!

(0 pen) Violation 50-324/87-31-04 and 50-325/87-32-04: Failure to conduct i adequate audits of the site corrective action program See paragraph 3.c. l

.

,

, ,

_. _ _ _ . . __ _____ _____ _ _ _ _ _ _ _ ____ _

. .

. ,. . .

.

'

!

i 2 ,

'

! (Closed) Unresolved Item 50-324/87-31-05 and 50-325/87-32-05: Potential !

inadequscy relative to maintaining an adequate water supply to meet fire  ;

protection requirements. See paragraph l

3. A portion of this inspection was conducted to review the status of correc- '

tive actions initiated by the licensee as a result of the deficiencies  !

,

identified by the Quality Assurance Assessment Inspection performed in

September of 1987 (reference NRC Inspection Report Nos. 50-325/87-32 and

! 50-324/87-31). This interim followup inspection was accomplished by  !

reviewing corrective action documentation and conducting discussions with i

responsible site and corporate personnel concerning tha status of these [

i items. The original QA assessment inspection resulted in four violations -

j of NRC requirements and one unresolved items as follows: l

i

-

Violation 50-324/87-31-01 and 50-325/87-32-01 concerned lack of t I adequate and timely corrective action for site engineering work l

! request (EWRs) which resulted in a significant backlog, approximately [

l 1900, outstanding / unresolved EWR As a result, the licensee (at j i the time of the inspection) was unable to address, with certainty,

the contents of the backlog nor the safety significance thereof.

)  :

i -

Violation 50-324/87-31-02 and 50-325/87-32-02 was issued due to the  !

fact that the licensee had not documented the results of engineering

'

l

'

reviews of many of the backlogged Engineering Work request I I -

Violation 50-324/87-31-03 and 50-325/87-32-03 was issued due to the l

fact that the licensee had failed to maintain the core spray system [

in its as-designed configuration in accordance with United States of f I America Standard B31.1, Power piping, by removing the suction relief (

i valves from both Unit 1 t*ains and blank flanging the relief valve l

{ connections, thereby negating the system overpressure protection ,

l feature provided by these valve This condition had existed for a t i period of several year ;

I l

-

Violation 50-324/87-31-04 and 50-325/87-32-04 was issued due to the t

fact that licensee conducted Quality Assurance Corrective Action  !

i audits were not thorough enough to determine that the EWR program was  !

'

a corrective action prbgram, thereby, necessitating compliance with i 10 CFR 50, Appendix l

/

l -

Unresolved Item 50-324/87-31-05 and 50-325/87-32-05 was issued due to  !

j a potential inadequacy relative to the site maintaining an adequate

,

water supply to meet fire protection commitment I As a result of the above deficiencies, the licensee initiated actions -

l to correct the noted deficiencies, to investigate for other similar  :

l deficiencies, and to prevent recurrence of the deficiencies, as follow ,

l Evidence of these corrective actions was reviewed by the inspector -

during this inspectio A summary / conclusion for each item is provided here to enhance future closeout of the findings: l l

.

,  :

I _!

- - _ _ _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

. .

.

,.

a. Violations 50-324/87-31-01, 50-325/87-32-01, 50-324/87-31-02, and 50-325/87-32-02:

(1) A review of the EWR Backlog for "safety significance" was conducted by the Onsite Safety Group (ONS). A prioritization scheme for correction of the EWR problems was developed and an appropriate criority was assigned to each EWR. This action was

,, completed in c'anuary 198 ..

(2) A corporate level review of the Brunswick corrective action program was completed in December 1987. Corrective action for this review is being tracked by site nonconformance report NCR S-87-04 (3) The procedure for processing EWRs was revised to clearly establish the EWR as a corrective action document and the requirements of 10 CFR 50, Appendix B were included (e.g., revision included root causes analysis determination, 3-day operability determination, corditions adverse to quality defined, significant conditions adverse to quality defined, reportability determination, 30-day engineering final evaluation, etc.). Reference ENP-20 Rev. 007 of 12/30/8 (4) ENP-20 was revised to provide additional enhancement Reference ENP-20 Rev. 008 of 05/12/8 (5) A project team was created to work specifically on EWR (6) The project team was incorporated into the existing plant structur Summary / Conclusion: The licensee was unable to establish firm commitment dates for completion of corrective actions until July 28, 1988 (3rd response to the violations). This was primarily due to the lack of progress in reducing the EWR backlog during the period from January - May 1988 (total backlog remained at approximately 1900).

Improved performance in reducing the backlog was accomplished during the June / July timeframe (the total backlog as of August 4, 1988 was reduced to 1387. The backlog of "old" EWRs was at 1135.). The commitment date for having Engineering Evaluations performed / documented on the ONS most significant EWRs is September 12, 1988. The commitment date for having Engine + ring Evaluations performed / documented on the remainder of the "oldd EWRs is February 12, 1989. There are no commitments for closecut of the "old" EWRs; however, the responsible Engineering Supervisor indicated that about 50 percent of the EWRs were being closed out when they are evaluated. These violations will remain open for additional followup by the NR .- - -_____ - _ _ - - _ _

, .

'

. ,. .

.

I 4  ! Violation 50-324/87-31-03 and 50-325/87-32-03:

(1) Site Technical Support Engineers were trained in the need for !

timely restoration of temporary repairs.

' '

(2) A review was conducted to assure no other ASME code violations existed on sit This review included Temporary Repair [

'

Evaluations, mechanical jumper logs, and plant special procedure !

,

'

(3) ENP-12. Engineering Evaluations, was revised to require plant manager concurrence on extensions of temporary repairs. See ,

'

Revision 17 to ENP-1 l l (4) The core spray system was to be restored to the original design ;

j by installation of the relief valves by July 15, 198 ;

l (Reference licensee commitment in the first response to this !

i violation; licensee memorandum file B09-135/0C, Serial I

BSEP/88-0099 of February 9, 1938.) j l '

Summary / Conclusion: The "A" train core spray relief valve had been

< reinstalled. The "B" train valve had not been reinstalled. The ;

,

licensee committed at the exit to provide an additional response to i the NRC specifying a new completion date for installation of the "B" i'

r train valv !

!

l Violation 50-324/87-31-04 and 50-325/87-32-04- '

,

'

! Summary / Conclusion: Corrective action for site QA has included a j performance review of site corrective action programs for timeliness t t of corrective actions. Results of this review were not yet issued (

, during this inspection. Corporate QA has added an attribute to all i

functional area audit checklists to review the corrective action 5

programs in the functional area. Formal responses to this item from

site and corporate QA are due to site licensing by September 1, 198 [

t

' Unresolved Item 50-324/87-31-05 and 50-325/87-32-05:

, (1) Since the original inspection, site surveillances have assured a i capacity of 240,000 gallons in the fire protection tan !

'

!

) (2) The calculations for the two hour supply of water have been [

reperformed and show that 226,200 gallons of water are require l (3) The tank has a "keep fill" feature which automatically provides [

make-up water when the tank level is below 260,000 gallon ]

i (4) Two additional EWRs have been generated which will result in a !

l plant modification to change the low level alarm setpoint and l

,

which will result in a technical specification change to a ;

value above 226,200 gallon i 1 i i i

,

[

!

L

- .

.

.. .

.

Summary / Conclusion: Due to the facts outlined above, as well as, the fact that EWRs 84;362 and 82-294 are carried as examples of inadequate correcti,e action under violation 50-324/87-31-01 and 50-325/87-32-01, this Unresolved Item is close . The NRC evaluated certain corrective actions brought about as a result of a licensee initiated High Pressure Coolant Injection (HPCI)

system Safety System Functional Inspection (SSFI) in 198 Based on this review, no operability concerns were identified. However, other concerns were identified and are discussed below:

-

During the SSFI, the licensee determined, through evaluation, that three motor operated valves in the HPCI system had potentially undersized motors. They were E41-F012, E41-F007 and E41-F008. Although the licensee intends to change out the motor en E41-F012, it appears that the resolutions concerning E41-F007 and E41-F008 have not adequately addressed the original concer The calculation performed for E41-F007, to determine available torque, uses the stall torque / stall thrust value Discussion with the licensee indicates this type of calculation is used in a "real world" or justification for continued operation approac Additionally, there have been no calculations to determine available torque for E41-F00 To adequately address the original concern, the licensee should perform the necessary applicable calculation The HPCI S$FI identified a concern that the team could not locate any documentation which evaluated the installation of sheet metal over the grating in the HPCI roo Following the SSFI, the licensee determined the sheet metal was analyzed for in the Reactor Building Environmental Report. The concern in this area is with the licensee's ability to retrieve data relating to plant modifications or design change Without the information in place which clearly defines tne design intent, future groups could initiate plant modifications which could result in a configuration which contradicts the original inten The licensee should review this and similar cases and ensure the necessary documentation is in place to support original design criteri In 1979 when the licensee replaced the auxiliary boiler, the heating steam lines to the reactor building were cut and cappe The S$FI team identified that this had been accomplished without the appropriate engineering or safety evaluation. Additionally, this item resulted in an NCR being generated by the Quality Assurance department. Although engineering is moving forward in evaluating the effects of temperature in the HPCI room, RHR room, etc., the original concern identified in the SSFI, specifically the safety evaluation, has not yet been complete The licensee should pursue measures to ensure that the identified deficiencies are promptly correcte . _ _ _ _ _ _ _ _ _ _ _ _ _ _ ________ ___-____

, .

. . . . .

..

.

4. Exit Interview

'

The inspection scope anc results were summarized on August 5,1988, with

,

those persons indicated in paragraph 1. The inspectors described the areas inspected and discussed in detail the inspection result Proprietary information is not contained in this repor The licensee committed at the exit to provide an additional response to the NRC

~

specifying a new completion date for installation of the "B" train core spray relief valve.

T J

!

I i

!