ML20005G692

Forwards Summary of Enforcement Conference on 891215 Re Svc Water Operability Brought to Light During Diagnostic Evaluation Performed Earlier in Yr.Concern Raised Re Promptness & Adequacy of Corrective Actions.Agenda Encl

ML20005G692
Person / Time
Site:	Brunswick
Issue date:	01/08/1990
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Eury L CAROLINA POWER & LIGHT CO.
References
EA-89-235, NUDOCS 9001220175
Download: ML20005G692 (27)

Text

{{#Wiki_filter:, y - / e JAN 081990 Docket'Nos. 50-325, 50-324-License Nos. DPR-71, DPR : i EA 89-235 ' Carolina Power and Light Company ATTN: Mr. Lynn W. Eury Executive Vice President Power Supply P. O. Box 1551 Raleigh,-NC 27602 Gentlemen:

SUBJECT:

ENFORCEMENT CONFERENCE

SUMMARY

- BRUNSWICK This refers to the Enforcement Conference held at our request on December 15, 1989.- This meeting concerned activities authorized for your Brunswick facility.

The issues discussed at this conference related to service water operability. A list.of attendees, a summary, and a copy of your handout are - enclosed. We' are continuing our review of these issues to determine the appropriate-enforcement action. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room. Should you have any questions concerning this matter, please contact us. Sincerely, (OriginalsignedbySDEbneter) l Stewart D. Ebneter I Regional Administrator

Enclosures:

1.. List of Attendees 2.

Enforcement Conference Summary l 3. Handout cc w/encis: R. B. Starkey, Jr., Manager Brunswick Nuclear Project Box 10429 Southport, NC 28461 (cc w/encls continued - See page 2) f$p2ggtb ![ lit ut'l

w, c Carolina Power and Light Company 2 M 08 W (cc w/encls cont'd) J. L. Harness bec w/encis: Plant General Manager Document Control Desk Brunswick Steam Electric Plant P. O. Box 10429 NRC Resident Inspector Southport, NC ?8461 U.S. Nuclear Regulatory Commission Star Rte. 1, Box 208 R. E. Jones, Ger.eral Counsel Southport, NC 28461 Carolina Power & Light Company P. O. Box 1551 Raleigh, NC 27602 Ms. Frankie Rabon Board of Commissioners P. O. Box 249 Bolivia, NC 28422 Chrys Bagget State Clearinghouse Budget and Management 116 West Jones Street Raleigh, NC 27603 Dayne H. Brown, Chief Radiation Protection Branch Divisien of Facility Services >N C. Department cf Human Resourc. 701 Barbour Drive Raleigh, NC 27603-2008 H. A. Cole Special Deputy Attorney Genera, State of North Carolina P. O. Box 629 Raleigh, NC 27602 Robert P. Gruber Executive Director Public Staff - NCUC P. O. Box 29520 Raleigh, NC 27626-0520 State of North Carolina RII:fP RII:DRP

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Fy. i E'E .* J 'Yhi ~ 'h I L',. .a-ENCLOSURE 1 4" LIST OF ATTENDEES. 1 Carolina Power & Light Company R;-A. Watson, Senior Vice' President, Nuclear Generation 'R.:B'. Starkey,, Manager Brunswick Project + DA.LM. Lucase Manager,' Nuclear Engineering Department (NED) s J l M.-Brown,nManager,_ Brunswick' Engineering Support, NED E. A., Bishop', Unit Supervisor, NED .M' R. 0ates, Manager,' Brunswick Licensing . R.. Paulk, Supervisor, Regulatory Compliance Nuclear-Regulatory Commission' 'S.,D. Ebneter, Regional Administrator J. L. Milhoan, Deputy Regional Adminstrator .L' A. Reyes, Director, Division of Reactor Projects (DRP)

D. M.cVerrelli, Chief, Reactor Projects Branch 1, DRP H.'C.' Dance,: Chief, Reactor _ Projects-Section.1A, DRP

- W.LH. Ruland,. Senior Resident Inspector - Brunswick, DRP R. E. Carrolli Project Engineer, DRP. E. T., Baker, Deputy-Director, Office of Enforcement G. : R'.' Jenkins, Director, Enforcement _ and Investigation Coordination Staff 1(EICS)_. B. Uryc, Senior Enforcement Coordinator, EICS 'R.' J. Goddard,. Regional Counsel 'E. G. Tourigny, Project Manager, Office of Nuclear Reactor Regulation E. W.-Merschoff, Deputy Director, Division of Reactor Safety (DRS) c - P.~0.LKellogg,' Chief,. Operational Programs Section, DRS -G.- A.. Belisle, Chief, Test Programs Section, DRS

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g W,7 y-N a. 1. ENCLOSURE 2 f ENFORCEMENT CONFERENCE

SUMMARY

The Deputy Regional Administrator opened the ceeting by. stating that its ~ ? purpose was to discuss those matters related to service water (SW) operability which-were brought to light during the diagnostic evaluation performed at Grunswick earlier this year. It was conveyed to CP&L that the promptness and adequacy of corrective actions -taken.as potential service water operability issues surfaced was of utmost concern. CP&L acknowledged a company-wide weakness in this area, indicating that recent/ ongoing efforts to improve i corporate and site culture and corrective action programs are having a positive effect in minimizing such problems. CP&L discussed in detail the potential single failure of SW valve V106, cross leakage between the nuclear-and conventional SW headers, SW pump motor overheating, the lack of a SW hydraulic model, SW pump motor thrust bearing i overload, SW pump run out, and residual heat removal (RHR) heat exchanger design basis with respect to Regulatory Guide 1.1. (The specifics of each of these items, including root cause corrective actions, are addressed in CP&L's handout which is' included as Enclosure 3.) With respect to the initial f di scovery of the potential single failure of SW valve V106 and the inappropriate decision that this had no detrimental effect on the SW system to i supply safety-related equipment (February 3 through June 2,1988), CP&L stated ~that the PNSC conclusions were valid. based on available information at the ' time. However, they did confirm through subsequent review, that the plant nuclear safety committee (PNSC) supporting engineering study was weak in that i .it did not' analyze the most limiting scenario and that component design flows,. .rather than actual flows, were utilized. Along the same line, when questioned dabout-the apparent slow response toward addressing SW motor overheating

• problems, CP&L-indicated that there was a lack of recognition-as tr the significance of overheating versus motor service life.

In conclusion, CP&L indicated that: (1) Inadequate design basis control, in that the SW system was not maintained in accordance with original design basis (resulting in cross tie valve leakage), and the lack of a single failure analysis on valve SW-V106 contributed to a degraded condition for worst case accident scenarios; (2) the failure to reference hydraulic calculations in plant modifications did not adversely affect system operability; and (3) the SW system would have performed under most accident scenarios and may have performed under worst case accident scenarios. In addition, CP&L stated that ] the present SW safety system functional inspection (SSFI) that is scheduled for completion by the end of December 1989, will be reviewed in conjunction with other completed SSFIs for potential generic design issues, trends, or patterns. They indicated that this effort, the program in progress to assemble system design basis documents, and the cultural changes that have and will continue to take place, are indicative of CP&L's strive toward improvement. The Deputy Regional Administrator closed the meeting by thanking CP&L for their time, the useful presentation, and stated CP&L would be informed at a I later date as to the NRC's deliberations on these matters.

,MJ.3, j ENCLOSURE 3 .c j CAROLINA POWER & LIGHT COMPANY 1 BRUNSWICK STEAM ELECIRIC PLANT ENFORCEMENT CONFERENCE i SERVICE-WATER DESIGN j DECEMBER 15,1989 i i AGENDA i e OVERVIEW R. B. STARKEY DETAILS J. M. BROWN

SUMMARY

R. B. STARKEY ' I b i { l.

-..:, y - g f :,;; V u. ' i ~ g. e '/l ~ DETAIIS ] 1 ~ SERVICE WATER ISSUES. - i SYSTEM DESCRIPTION, CP&L POSITION ' KEY EVENTS ISSUES REVIEW c , k ADDITIONAL ACTIONS-CONCLUSION. p I i 2 --

0,4 jd m ? SERVICE WATER ISSUES w 4

• - HYDRAULIC CAPABILITY

~ 4 CROSSTIE LEAKAGE y VULNERABILITY TO SINGLE FAILURE i f 9 FLUID HYDRAULIC CALCULATIONS l Y

• ' MOTOR OVERHEATING '
• ' THRUST BEARING OVERLOAD
• . SERVICE WATER PUMP RUNOUT DURING UNIT SHUTDOWN i

a l - * - RHR HEAT EXCHANGER DESIGN BASIS t f i { u 8 -3

., V a,_ e w CP&L POSMON

• - AGREE 'HIAT *nIERE HAS BEEN INADEOUATE DESIGN BASIS CON 1ROL OF SERVICE WATER SYSTEM THE SYSTEM WAS NOT MAINTAINED IN ACCORDANCE WITH ORIGINAL DESIGN BASIS (CROSSTIE VALVE LEAKAGE DEGRADED SYSTEM FLOW CAPABILITY)

FLOW CAPABILITY WAS FURTHER IMPACED IN WORST CASE ACCIDENT SCENARIOS DUE TO POSSIBILITY OF SINGLE AGIVE FAILURE OF VALVE SW.VIO6 TO CLOSE HYDRAULIC CALCULATIONS WERE NOT REFERENCED IN PLANT MODIFICATIONS. SAFETY SIGNIFICANCE SERVICE WATER WOULD HAVE PERFORMED ITS SAFETY FUNCTION UNDER MOST ACCIDENT SCENARIOS AND MAY HAVE PERFORMED UNDER WORST CASE ACCIDENT SCENARIOS. FAILURE TO REFERENCE HYDRAULIC CALCULATIONS IN MODIFICATIONS DID NOT ADVERSELY AFFECT SYSTEM OPERABILITY. l -4

' i gu i y,4 .c -+ KEY EVENTS ~ . FEBRUARY 3,1988 THROUGH JUNE 2,1988 it IDENTIFIED POTENTIAL DEFICIENCY ON INTERLOCK CIRCUITRY FOR VALVE SW.VIO6 DURING COMPONENT LEVEL Q LIST REVIEW FURTHER REVIEW IDENTIFIED POTENTIAL TO STARVE DIESELS AND. ~ VITAL LOADS IF VALVE SW.VIO6 FAILED OPEN PLANT NUCLEAR SAFETY COMMITTEE ACTIONS-(FEBRUARY 12,1988) SERVICE WATER MAY HAVE BEEN INOPERABLE BUT NEEDED ADDITIONAL DESIGN REVIEW IN ORDER TO COME TO CONCLUSION PNSC ACTIONS ESTABLISHED INTERIM RESTRICTION TO LIMIT RBCCW TO 5,000 GPM OR MAINTAIN ADDITIONAL NUCLEAR SW PUMPS (3 VERSUS 2) l INITIAL EVALUATION BASED ON DESIGN FLOW RATES CONTAINED IN ~ FSAR TABLE 9.2.1-1. THIS TABLE ENTITLED "SW FLOW DISTRIBUTION" 7 i SUMMARIZED EQUIPMENT REQUIREMENTS FOR ACCIDENT CONDITIONS AND DID NOT CONSIDER EFFECT OF A DEGRADED SYSTEM OR VARIATION IN SYSTEM FLOW DISTRIBUTION. ESTABLISHED ACTION ITEM TO PERFORM FURTHER ENGINEERING EVALUATION TO ADDRESS VALVE SW.V106 SINGLE FAILURE ISSUE. PNSC CONCLUSIONS WERE VALID BASED ON AVAILABLE INFORMATION ni m ; h;.,, - 1 o :t = e;, o

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',; g - ] m t...,. t < a [ KEY EVEN'Is (CONTD) e,., ll1 ENGINEERING STUDY IN FOLLOWUP TO PNSC CONCLUDED THAT' [,[ ADEQUATE SYSTEM FLOWS.WERE AVAILABLE WITH FAILURE OF SW.V106

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TO CLOSE.1

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'3 F1 - STUDY WAS WEAK j b 1 L DID NOT ANALYZE MOST LIMITING SCENARIO..' Q p. ASSUMED WRONG FAILURE POSITION FOR DIESEL m SUPPLY VALVE USED COMPONENT DESIGN FLOWS RATHER THAN ACTUAL FLOWS s ( ~_I,' -{ + 4 I i ^J 1- .N[ ll i i 'i i. i l 1. (n ._..J

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_f{. s KEY EVENTS (CONT'D) APRIL 16,1989 THROUGH SEPTEMBER 14,1989~ t APRIL 16,1989 - ENGINEERING TEAM FORMED.TO ADDRESS DET t CONCERNS ON SERVICE WATER OPERABILITY 6 EFFORT i ENGINEERING TEAM FORMED - SITE AND CORPORATE PERSONNEL, AVERAGE OF 6 CP&L ENGINEERS,60 PEOPLE - INVOLVED IN EARLY STAGES (APPROX. $2,000,000) ) ( :. PREPARED 8 ENGINEERING EVALUATIONS ESTABLISHED OPERATING RESTRICTIONS EVALUATED TEST RESULTS ESTABLISHED INTERIM DESIGN BASES DESIGNED AND INSTALLED 6 PLANT MODIFICATIONS STARTED ENGINEERING ON 2 OTHER MODIFICATIONS COMPLETED NEW HYDRAULIC MODEL ^ COMPLETED CANAL LEVEL STUDY COMPLETED PUMP TESTING TO RE-ESTABLISH DESIGN REQUIREMENTS, w -m w y ,y

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N.. s. i 4 KEY EVENTS (CONTD) a OPERABILITY L AT NO TIME DURING THE EFFORT WAS SERVICE WATER

DETERMINED TO BE INOPERABLE

? RESULTS q 1 CONCLUDED THAT A FAILURE OF VALVE SW-V106'TO CLOSE-AND CROSSTIE VALVE LEAKAGE WERE OPERABILITY CONCERNS UNDER WORST CASE ~ ACCIDENT SCENARIO WHICH INCLUDES A LOSS OF COOLANT ACCIDENT AND LOSS OF OFF SITE POWER IN COMBINATION WITH MOST LIMITING SINGLE FAILURE IN THE SERVICE WATER SYSTEM, DESIGN SERVICE WATER FLOWS CANNOT BE MET. ( :\\

y I i ,; A.-. g p e 4 a , f,. s . -? KEY EVEN'IS (CONTD)-

• . SEPTEMBER 14,1989 - ONE-HOUR RED PHONE REPORT 1

~ IOTENTIAL INOPERABILITY UNDER WORST CASE ACCIDENT CONDITIONS EXACT ASSESSMENT OF SYSTEM TO PERFORM UNDER WORST CASE ~ SCENARIOS IS COST PROHIBITIVE - t lJ l' l l i l l l l :- l -

3-4.s ISSUES REVIEW HYDRAULIC CAPABILITY f

• - LOWER HYDRAULIC CAPABHIIY DURING ACCIDENT SCENARIOS t

MEASURED CROSSTIE LEAKAGE ON UNIT 2 - APRIL 1989 3 CONCLUDED THAT SYSTEM WAS VULNERABLE TO SINGLE FAILURE OF VALVE SW-V106 TO CLOSE - APRIL 1989 ROOT CAUSES ) LACK OF RECOGNITION OF THE EFFECT OF CROSSTIE VALVE LEAKAGE ON.THE DESIGN BASIS VULNERABILITY OF THE SERVICE WATER SYSTEM TO SINGLE FAILURE OF THE SW V106 VALVE WAS NOT RECOGNIZED DURING ORIGINAL DESIGN 4 r_: 3m:.g ISSUES REVIEW (CDN'I'D) _ HYDRAULIC CAPABILITY (CONT'D) l

• ' CDRRECTIVE ACI1ONS STATUS T

U1 U2 INSTALLED MOTORS ON SW.VIO3 (IN LINE COMPLETE COMPLETE WITH SW V106) RESOLVES SINGLE JUNE '89 JUNE '89 FAILURE PROBLEM WITH SW VIO6 i NEW HYDRAULIC MODEL COMPLETE COMPLETE DEC. '89 DEC. '89 PERFORMED TESTING ON SYSTEM TO ~ DETERMINE CAPABILITY-DETERMINED SYSTEM HYDRAULIC COMPLETE COMPLETE PERFORMANCE CHARACTERISTICS JULY '89 APRIL '89 DETERMINED CROSSTIE VALVE COMPLETE COMPLETE LEAKAGE. MAY '89 APRIL '89 REPLACEMENT OF CROSSTIE VALVES WILL IN WITH NEW VALVES WHICH HAVE LOWER COMPLETE PROGRESS TOROUE REQUIREMENTS FOR SEATING 1990 REFUEL OUTAGE PERFORMED FACTORY TEST ON PUMP TO COMPLETE COMPLETE DETERMINE CHARACTERISTICS JUNE '89 JUNE '89 HYDRAULIC MODEL REPORT FOR SERVICE WILL WILL WATER (INCLUDING ACCIDENT SCENARIOS COMPLETE COMPLETE AND SINGLE FAILURE ANALYSES) DEC '89 DEC. '89 l l I-.

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,p uc .: + ISSUES REVEW (CONTD)- HYDRAULIC CAPABILITY (CONTD) CORRECHVE ACDONS (CONTD) STATUS 1 U1 U2 i SURVEILLANCE TESTING ON FLOW WILL WILL CAPABILITY (INCLUDING CROSSTIE PERFORM PERFORM . LEAKAGE) IN FUTURE IN PRESENT REFUEL REFUEL OUTAGES OUTAGE -PLUS' PJTURE REFUEL OUTAGES' SERVICE WATER TECHNICAL SPECIFI. WILL WILL CATION REVISION WILL ESTABLISH SUBMIT SUBMIT MINIMUM OPERATING PUMPS CONSISTENT FEB. '90 FEB. '90 WITH HYDRAULIC ANALYSIS 1 l l l :. I 1 l.' l' I

~. O ag g,.g .g.)- -.e 1 ~ TEUES REVIEW (CONTD) t ..g FLUID HYDRAULIC CALCULATION l i FLUID HYDRAUUC CAlfUIAP.ONS WERE NOT REFERENCED IN MODIFICA110NS i

• - ROOT CAUSE ~-

i t CALCULATIONS WERE NOT MAINTAINED BY THE COMPANY (ALTHOUGH CALCULATIONS WERE AVAILABLE FROM THE A/E) o 3 ' ENGINEERS USED JUDGMENT IN DETERMINING THAT LIKE IN KIND 4 I REPLACEMENU WOULD NOT SIGNIFICANTLY ALTER THE CALCULATIONS. ,[ p g I *- l: L l L, p. l < ~

. ~ igu :.6 ; ,;.i 1 1"UES REVIEW (CONTDY l I FLUID HYDRAULIC CALCULATION ' CORRECTIVE ACTIONS STATUS U1 U2 DEVELOP HYDRAULIC BASIS FOR COMPLETED COMPLETED SERVICE WATER DEC. '89 DEC. '89 v ' VERIFIED THAT MODIFICATIONS i DID NOT AFFECT OPERABILITY ' CONTINUE PROGRAM TO WILL WILL ASSEMBLE SYSTEM DESIGN BASIS COMPLETE COMPLETE ' DOCUMENTS DEC.'91 DEC. '91 INCLUDES LISTING OF DESIGN CALCULATIONS AS WELL AS r OTHER ESSENTIAL DESIGN t INFORMATION INFORMATION IS BEING RELOCATED TO CP&L TO IMPROVE ACCESS 5 OF 66 SYSTEM DESIGN BASIS DOCUMENTS COMPLETE INCLUDES A PLANT MODIFICATION REVIEW COMPARED TO ORIGINAL DESIGN BASIS WILL BE KEPT CURRENT AS PLANT i MODIFICATIONS ARE MADE i-(, -

a3 V.C j y.. ; ~ ' ISSUES REVIEW (CONT'D). - MOTOR OVERHEATING ' *" ' SERVICE WATER MOTORS RELIABILITY HAD DEGRADED DUE TO MOTOR - OVERHEATING - MO1DR FAILED FOLLOWING SPECIAL HYDRAULIC TESTING ' * = ROOT CAUSE + - LOW AIR FLOW THROUGH MOTOR , LACK OF RECOGNITION OF SIGNIFICANCE OF OVERHEAllNG .-VS SERVICE LIFE - '? d._

, yd g ' 'e g. 1 . 9 ISSUES REVIEW (CONTD) t MOTOR OVERHEATING ' CORRECHVE ACDONS - STATUS U1 U2 I INITIATED PROORAM TO MODIFY COMPLETED COMPLETEDI MOTORS TO IMPROVE COOLING - 1CC - 7/89 2AN - 9/89 - 'i 2AC - 8/89 2CC - 7/89 2 ADDITIONAL MOTORS IN 1990 UPGRADED MOTOR INSULATION CLASS . INSTALLED HIGH EFFICIENCY ROTOR FANS ENLARGED STATOR AND FRAME AIR PASSAGES INITIATED SERVICE WATER MOTOR TEMPERATURE MONITORING PROGRAM P ROUTINE MONITORING OF STATOR STARTED WILL ' RTD'S 1AC - 11/89 IMPLEMENT WILL 12/89 IMPLEMENT 12/89 DETERMINED CUMULATIVE AGING COMPLETE COMPLETE EFFECTS OF INSULATION 7/89 7/89

1 t

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. 1 s ISSUES REVIEW (CONT'D) THRUST BEARING OVERLOAD

• - FOUND DURING IWDRAULIC REVIEWS THAT SERVICE WATER PUMP MOTOR TIIRUST -

BEARINGS MAY BE OVERLOADED SHOULD ONE DIESEL SW INLET VALVE FAIL 1D J -OPEN a 1 ROOT CAUSE l ORIGINAL DESIGN DID NOT CONSIDER ACCIDENT SCENARIO WITH FAILURE OF DIESEL INLET VALVE TO OPEN (HIGH HEAD CONDITIONS) 1 ~ 1.: -.

4 r n',, ., x A oi s 3 l ~ ISSUES REVIEW (CONTD) THRUST BEARING OVERLOAD f

• '- - CORRECITVE ACI10NS STATUS U1 U2.

.a. .! t ' INITIATED FLOW LIMI'13 TO ASSURE -INITIATED INITIATED ADEQUATE FLOW IN ACCIDENT CONDITIONS 7/89 7/89-v VALVES SW V106 AND SW V103 -LIMITED TO 20% OPEN TO ENSURE. MINIMUM FLOW- - MINIMUM SW FLOW TO RBCCW PROCEDURALLY SET AT 2500 GPM X ONE RHR ROOM COOLER REQUIRED IN SERVICE REVIEWING ALTERNATIVE LONG-TERM WILL WILL SOLUTIONS - COMPLETE COMPLETE LATE '90 LATE % MINIMUM FLOW LINES IMPROVED THRUST BEARINGS ADDITIONAL THRUST BEARING TESTS HYDRAULIC MODEL REPORT FOR SERVICE WILL WILL WATER INCLUDING ACCIDENT SCENARIOS COMPLETE COMPLETE AND SINGLE FAILURE ANALYSIS DEC. '89 DEC. '89,

l; ;.,: C; su v of J ISSUES REVIEW (CONTD)'- SERVICE WATER PUMP RUNOUT DURING AOCIDENT SCENARIO INCLUDING A LOSS OF OFF4ITE POWER, SHUIDOWN ' UNIT AND RESIDUAL H REMOVAL IN SERVICE, SER\\1CE WATER PUMP RUNOUT MAY OOCUR - FOUND DURING HYDRAULIC REVIEW ROOT CAUSE. ACCIDENT SCENARIO WAS NOT CONSIDERED DURING ORIGINAL DESIGN

• - CORRECHVE ACTIONS STATUS U1 U2 INITIATED RBCCW AND RHRSW INITIATED INITIATED PROCEDURAL FLOW RESTRICTIONS 9/89 9/89-

. DURING SHUTDOWN (INTERIM ACTION) ? 4500 GPM MAXIMUM FLOW FOR RBCCW 5500 GPM MAXIMUM FLOW FOR RHRSW 1 IMPLEMENT MODIFICATION TO ADD WILL WILL i LOSS OF OFF-SITE POWER CLOSURE IMPLEMENT IMPLEMENT 'i LOGIC FOR VALVES SW.VIO3 AND SW.VIO6 NEXT NEXT REFUEL REFUEL OUTAGE '90 OUTAGE '91 = x .-(g b: o a ISSUES REVIEW (OONT'D). RHR HEAT EXCHANGER DESIGN BASIS SAFETY GUIDE 1.1 ' NET POSITIVE SUCTION HEAD FOR EMERGENCY CORE COOLING - AND CONTAINMENT HEAT REMOVAL SYSTEM PUMPS" CONFLICIS WITH THE FSAR. 4 FSAR TAKES CREDIT FOR CONTAINMENT PRESSURIZATION SAFETY GUIDE 1.1 RECOMMENDS THAT PERFORMANCE OF ECCS SYSTEMS BE INDEPENDENT OF CONTAINMENT PRESSURE CAUSED BY POSTULATED LOSS OF COOLANT ACCIDENTS.' DISCUSSION DESIGN REPORT 12 TOOK EXCEPTION TO SAFETY GUIDE 1.1. DESIGN REPORT 12 WAS SUBMI1TED TO AEC MARCH 30,1972. THE BRUNSWICK SER DATED NOVEMBER 1973 ACKNOWLEDGES DESIGN REPORT 12 BY REFERENCE TO THE SUBMITTAL IN APPENDIX A. BASED ON THE ISSUANCE OF THE SER, THE AEC ACCEPTED DESIGN REPORT 12. CP&L DOES NOT CONSIDER THIS AN ISSUE; HOWEVER, A FSAR REVISION TO REFLECT DESIGN REPORT 12 WILL BE SUBMITTED PER NORMAL FSAR UPDATE..-.

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4 e. I ADDITIONAL ACTIONS ~ STATUS U1-U2l SERVICE WATER SAFEIY SYSTEM FUNCTIONAL - INSPECITON IN PROGRESS ISSUES ARE BEING IDENTIFIED. NO SCHEDULED SCHEDULED-OPERABILITY PROBLEMS IDENTIFIED, COMPLETION COMPLETION TO DATE. DEC. '89 ' DEC. '89 REVIEW COMPLETED SSFI'S (SERVICE WATER, SCHEDULED SCHEDULED I IBGH PRESSURE COOLANT INJECTION, STANDBY COMPLETE COMPLETE LIQUID CONTROL) FOR POTENTIAL GENERIC JUNE '90 JUNE '90 1 DESIGN ISSUES, TRENDS, OR PATTERNS l ADDRESSING GENERIC LtinEK 89-13 ON

RESPONSE

RESPONSE SERVICE WATER PROBLEMS DUE DUE JAN. '90 JAN. '90 i 21 - I

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j 4 4 - t-CONCLUSIONS INADEQUATE DESIGN BASIS CONTROL i

• THE SERVICE WATER SYSTEM WAS NOT MAINTAINED IN ACCORDANCE WITH ORIGINAL DESIGN BASIS (RESULTING IN CROSSTIE VALVE LEAKAGE).

LACK OF A SINGLE FAILURE ANALYSIS ON VALVE SW-VIO6 CONTRIBUTED TO A DEGRADED CONDITION FOR WORST CASE ACCIDENT SCENARIOS. '-i TIIE FAILURE 'ID REFERENCE HYDRAULIC CALCULATIONS IN PLANT MODIFICATIONS DID NOT ADVERSELY AFFECT SYSTEM OPERABIIIIY. l SERVICE WATER WOULD HAVE PERFORMED UNDER MOST ACCIDENT SCENARIOS AND MAY HAVE PERFORMED UNDER WORST CASE ACCIDENT SCENARIOS

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