ML20098E213
| ML20098E213 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/27/1992 |
| From: | Spencer J CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9206020030 | |
| Download: ML20098E213 (9) | |
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I CP&L rNemem8F2tsune maTaste s Careitna Power & Light Company Exmmrmmacenn:umm:n Brunswick Steam Electric Plant MAY 2 71992 File: B00-135100 10CFR 2.201 United States Nuclear Regulatory Commission NiTENTION: Document Control Desk Wnhington, DC 20553 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50 324/UCENSE NOS. DPR-71 & DPR-02 REPLY TO NOTICE OF VIOLATDN AND NOTICE OF DEVIATION Gentlemon:
The Brunswick Steam Electric Plant has recotved NRC Inspection Report 50 325/02 04 and 50 324/92-04 and finds that it does not contain Information of a propriotary nature. This report includod a Notico of Violation and a Notico of Deviation.
Enclosed is Carolina Power & Light Company's responso to that Notice of Violation and Dovlation.
Yours very truly, 0,.
(J W. Spencer, Go er Manag9r a
swick Nuclehr Project SFT/
Enctosuto ec:
Mr. S. D. Ebneter Mr. R. H. Lo BSEP NRC Resident Offics U1CCbd 9206020030 920527 PDR ADOCK 05000324 0
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ENCLOSURE BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50425 & 50 324 OPERATING UCENSE NOS. DPR 71 & DPR42 REPLY TO NOTICE OF VIOLATION AND NOTICE OF DEVIATION VIOLATION:
During an NRC inspection conducted on February 17 March 27,1992, a vidation of NRC requiremms was identified. In accordance with the ' General Statement of Polley and Procedure for NRC Enforcement Action.
- 10 CFR Part 2, Appendix C, (1992), the Violation is listed below; 10 CFR 50.59 requires that changes to the facility as described in the safety analysis report be reviewed for determination that an unrevlowed safety question does not exist.
ASME Boller and Pressure Vessel Code,Section XI, IWA 5000 requires that a system pressure test be conducted following replacement of pressure boundary parts.
Contrary to the above, on January 5,1992, the temporary replacement of Residual Heat Removal Service Water Pump 1B with blank flanges was not reviewed to determine if an unreviewod safety question existed nor was a system pressure test performed.
This is a Severity Level IV violation (Supplement 1).
EfjPONSE TO VIOLATION:
Admission or Dental of Violation:
y Carolina Power & Light Company adretts to this violation.
Reason tor the Violation:
On December 31,1991, the B Loop of the Residual Heat Removal Service Water (RHRSW) system was placed under clearance to support repair of the Unit i 1B RHRSW pump. Due to HHRSW system design, work on one of the two pumps comprising the B loop, requires a clearance that makes both pumps inoperable. This condition required a seven day Technicit! Specification Limiting Cond!!!on of Operation (LCO).
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On' day four of the sovon day LCO, the decisicn was made to remove the 1B RHRSW pump casing to facilitate the repair. Because the timo requirod for removal, repalr, and rolnstallation of the pump casing would exceed the seven day LCO, a plan was developed to isolate the 1B RHRSW pump piplag from the redundant pump (ID RHRSW pump) in order to declare the redundant pump operable and extend the LCO to thirty-one days as allowod by Technical Specifications. Blanking off the 1B RHRSW pump suction and discharge piping was determined to be the appropriate approach to accommodating pump Isolation. A plan was developed to L:ank off the suction and discharge piping by use of blind flanges.
During planning of the blind flange installation activity, the determination was made to evaluate the solsmic concerns associated with removal of a selsmic anchor (i.e., the pump casing itself) and acceptability of using non-O flanges. On January 5,1992. Engineering Evaluation (EER) 92 004 was approved confirming th3 system mot Short Term Structural Integrity (STSI) requirements and the acceptability of the flanges. On January 61992, the blind flanges were installed, the redundant pump was declared operable, and the soven day LCO extended to a thirty-one day LCO.
On January 6,1992, after extending the seven day LCO but prior to the end of the original seven day LCO, the NRC resident inspector raised concems regarding the nood for pressure boundary testing to ensure the adoquacy of the temporary condition created by the installation of the blind flanges and a safety evaluation verifying acceptability of the temporary change. Based on the resident inspector's querlos, the decision was made to conduct a pressure boundary test in accordance with ASME Section XI requirements. The test was completed satisfactorily within the original seven day LCO period in addition, an Adverse Condition Report (ACR)92-010 was initiated on January 9,1992 to address the prograrnmatic aspects of this activity which allowed a temporary condition to exist without performance of a safety evaluation.
The violation occurred for the following reasons:
1.
Enginooring persnnnel prepared ard approvod an Engincoring Evaluation (EER) In support of a planned change which was established to provide system operability. The evaluation did not include the required safety evaluation. The following summary of causes was the basis for this act'on:
a.
The Nuclear Engineering Department (NED) prepared a Short Term Structural Integrity (STSI) EER without a safety evaluation based on the mindset used for 'as found" conditions. "As found* STSI conditions do not require safety evaluations per NSAC 125 guidance. Although the STSI ovaluation which was performed did verify the acceptability of the involved piping suppoda as meeting STSI requirements, the ovaluation did not address the installation of the blind flanges as a planned temporary condition.
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The following factors influenced the preparation of the evaluation performod:
. Er.J aring Evaluation Procedure, ENP 12, does not specifically require a safety evaluation for STSI conditions which are planned changos or for short-term /tomporary conditions which are dovlations from the Final Safety Analysis Report, design, drawings, code or quality toqulromonts.
. NED did not follow ENP 12 guidance and classify the EER as a temporary condition even though it included justification for the use of a non-Q flango.
. NED Involved personnel did not have a complete and adequate understanding of what constitutes a planned temporary change versus
- as found' STSI conditions and the appropriate cafety evaluation requirements.
. The Technical dupport (on-site engineering) hvolved personnot provided insufficient direction via written communication by directing NED to perform a 'ssismic study" and to evaluate the acceptability of using non-O flanges. Technical Support personnel did not request NED to perform a complete evaluation of the acceptat:',ity of the plannod temporary change. Though additional verbal discussions occurred betwoon NED and Technical Support personnel, NED, being famillar with structural assessments, percolved their assignment as addressing structural issues only.
The following factors influenced the review and approval of the eva!uation performed:
. Although Technical Support questioned NED on the need for a safety evaluation, ICED's justificat'on was accepted due to Technical Support's unfamiliarity with the generic safety evaluation performed for STSI conditions. During the course of this communication, NED stated that individual safety evaluations for STSI conditions were not required por plant procedure. This basis was incorrect as the safety evaluation can only be walved for "as found" STSI conditions, and the installation of the bilnd flanges was a planned chango.
. The Technical Support personnel involved did not have a complete and adequate understanding of what constitutes a planned temporary change versus "as found' STSI conditions and the appropriato safety evaluation requirements.
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2.
The Malntenance planner responsible for developing the work Instruction did not recognize that the installation of the b!!nd flanges would create a temporary cond! tion or that an 'in-p6ocess test * (i.e., test required to testore system operabuity prior to completion of a maintenance actMty) was required prior to return!ng the system to operability. The following summary of causes was the basis for this action:
a.
The ' Nature of Trouble
- discussion contained in the Work Requ st Job Order (WRJO) did not trdicate to the planner that the system wc., be returned to service.
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While Maintenance procedure, OMMM-003, Corrective Melntenance.
(Automatod Maintenance Management System), provides guidance for preparation of WRJO repair Instructions for " temporary repairs', the procedure does not provide the necessary guidance to the plannor regarding *tsinporary changes" or situationc re:;uir;ng "in process testing".
b.
The Post Maintenance Testing Requirement (PMTR) process assigns the responsibility for the determination of post maintenance testing requirements to the planners; however, a planner's work background and training do not adequately prepare a planner for making determinations as complex and varying as Inservice Inspection (ISI) and Code testing requirements.
While the existing PMTR process provides controls for testing following completion of maintenance, the process is not designed to accommodate 'in-process testing *,
l Malntenance and Engineering personnel were insufficiently aware of the -
c.
Impact of using temporary blind flanges on system operability. This condition was exacerbated by a long standing practice of considerina j
the installation of blind flanges on the Residual Heat Removal Service -
Water system pumps as an *in process' maintenance activity not representing a change to the faculty, d.
An earlier review of the institute of Nuclear Power Operation Good Practice on Temporary Modifications (which identified requirements for installation of temporary bilnd Sanges), did not identify the need for appropriate process and procedure changes regarding the use of blind flanges.
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CorrectNo Steos Which Have Been Taken and Results Achieved:
The ellowlng corrective actions have been taken:
1 The original STSI evaluation has been revised to inch de a safety evaluation which addresses the impact of the temporary installation of the blind flanges on the operability of the Residual Heat Removal System. Additionally, the safety evaluation determined that the actkity did not constitute an unreviewed safety question.
2.
As an interim measure, a Management directke has been established requiring a Technical Support ISI group review of WRJOs initiated against ISI Class 1,2,3 or S (Special encompasses ISI augmented inspection items) equipment to ensure appropriate ISI testing requirements are specified. Based on this review, appropriate changes can be made to the PMTRs priot to work execution.
3.
Appropriate Maintenance, Operations, NED, and Technical Support personnel have boon informed of the need to be sensitive to those work activities which establish temporary conditions and the need for ensuring appropriate evaluation and testing.
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Corrective Actions That Will Be Taken To Avoid Further Viotallom:
The following corrective actions will be taken to evold further violation:
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Engineering Evaluation Procedure, ENP 12, is expected to be revised by l
June 30,1992 to require a safety evaluation of all planned temporary l
changes whettwr those changes constitute an STSI or other condition.
2.
Evaluation of the effectiveness in existing Technical Support and NED training programs and identification of the potential deficiencies which contributed to a failure to identify the Installation of blind flanges as a temporary condition requiring a safety evaluation and completion of the actions necessary to correct the deficiencies will occur by September 30,1992.
3.
OMMM403, Corrective Maintenance (Automated Maintenance Management System), will be revised by July 31,1992 to require ISI review of WRJOs initiated a0ainst ISI Class 1,2,3 or S (Special.
encompasses ISI augmented Inspection items) equipment to ensure appropriate ISI testing requirements are specified. This revision will also provide clearer expectations of planner actions associated with work Instruction preparation and directions for planning and testing of -
temporary changes, including blind flange installations.
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4.
A Staff Assistance Team has been tasked to develop a PMTR matrix in conjunction with Operations and Technical Support for issue in November,1992. The matrix will defino PMTR responsibility as related to applicable site organizations. This matrix will be hcluded within a PMTR plant procedu.
The PMTR plant procedure will provide guidelines for selection,.t testing requirements and a flow chart for PMTR performance. This proceduriis expected to be completed by November 30,1992.
5.
A performance based planner / analyst training program including training to address temporary changes and associated *ln-process testing" req'.'Irements wlli be implomonted b/ December 31,1992.
6.
An evalJation of the adequacy of those plant processes (l.o., clearance procedure, Indallation of mechanical and electrical jumpers, WRJO, etc.)
which create temporary conditions will bo performod by October 1, 1992. Special consideration will be given to consolidating the current processes associated with temporary conditions and ensuring 10CFR 50.59 requirements for performance of safety evaluations are met.
A review of the event with the Site Work Force Control Group represen:atives will be performed by September 30,1992 to ensure a higher sensitivity to temporary conditions and associated testing requirements during the screening and scheduling of worl< activition.
Date When Full Comollance Will Be Achieved:
Based on the intorim nroasures which olovato plant personnol's awareness of tetporary conditions requiring evaluations and "in-process testing", and require ISI review of all IS) rthied WRJOs prior to work execution, Carolina Power and Light believes that compilance has been achieved. To ensure continued compliance those additional corrective actions delineated herein wRl be completed by December 31,1992.
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DEVIATION:
During an NRC inspection conducted on February 17 - March 27,1992, a deviation of written commitmerd was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Action',10 CFR Part 2 Appent? C, (1992), the deviation is listed below:
Notice of Violation dated March 12,1991 required a written statement (" Reply to a Notice of Violation") including corrective steps that will be taken to avoid further y
violations and the date when full compilance will be achieved.
h The assointed Reply to a Notica of Violation dated April 11,1991 stated that " Improved guidance with respect to determination and conduct of Post Maintenance Testing Requirements will be devenal by August 19,1991,*
Contrary to the above, improved guldance with respect to determination and conduct of
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Post Maintenance Testing Requirements was not developed by August 19,1991 in that these actions had not been completed by March 12,1992.
RESPONSE TO DEVIAT1QN:
Admission or Dental of Deviation:
Carolina Power & Light Company admits to this deviation.
Reason for the Deviation:
The magnitude of the effort required to improve the Post Maintenance Testing Requirement (PMTR) process was much greater than anticipated.
Corrective Steos Which Have Been Taken and Results Achieved:
As an interim measure, a Management directive has been issued requiring Technica! Support inservice inspection (ISI) group review of Work Request Job Orders (WRJOs) !nitiated against ISI Class 1,2,3 or S (Special - encompasses ISI augmented inspection items) equipment to ensure technical accuracy.
Based on this review, appropriate changes can be made to the PMTRs pr!gr to work execution.
Corrective Actions That Will Be Taken To Avoid Further Violations:
A StaU Assistance Team has been tasked to develop a PMTR matrix in conjunction with Operations and Technical Support for issue in November,1992. The matrix will define PMTR responsibility as related to applicable site organizations. This matrix will be included within a PMTR plant procedure. The PMTR plant procedure will provide guidelines for selection of testing requirements and a flow chart for PMTR pe:formance.
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1 OMMMM3, Corrective Maintenance (Automated Maintenance Management System), will be revised to '-
require ISI review of WRJOs initiated against ISI Class 1,2,3 or S (Special encompasses ISI -
augrr, anted inspection items) equipment to ensure technical accuracy. This revision will also provide -
clearer expectations of planner actions associated with work Instruction preparation and directions for -
planning and testing of temporary changes, including bilnd flange installations.
Date When Corrective Actions Will Be Comolete:
The PMTR plant procedure is expected to be completed by November 30,1992. The revision to'0MMM-003 is expected to be completec' by July 31,1992.
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