ML20099E797
| ML20099E797 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/07/1992 |
| From: | Spencer J CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BSEP-92-0005, BSEP-92-5, NUDOCS 9208110208 | |
| Download: ML20099E797 (6) | |
Text
r o.
.m '
.,m Carolina Power & Light Company REEPNatf7& m aa m m m m man ma Brunswick Steam Electric Plant AUG 0 71992 File: B09-135100 10CFR 2.201 BSEP-92-0005
. United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 -
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NCS. 50-325 & 50424/ LICENSE NOS. DPR 71 & DPR-62
. REPLY TO NOTICE OF VIOLATION AND NOTICE OF DEVIATION -
Gentlemon:
The Brunswick Steam Electric Plant has received NRC Inspection Report 50-325/92-14 and 50-324/92-14 and finds that it does not contain information of a proprietary nature. This report included a Notice of Violation and a Notice of Deviation.
Enclosed is Carolina Power & Ught Company's response to that Notice of Violation and Deviation.
Yours very truly, p
. W.
pencer, Gene M nager runs ick Nuclear Project SFTf Enclosure cc:
- br, S. D. Ebneter Mr R. H. t.o.
. BSEP NRC Resident Office
.g i:
InnA
)
I 9208110208-920007 PDR -ADOCK 05000324 a
l*
O' PDR j
l
ENCLOSURE BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKIT NOS. 50 325 & 50-324 OPERATING LICENSE NOS. DPR 71 & DPR-62 REPLY TO NOTICE OF VIOLATION AND NOTICE OF DEVIATION VIOLATION:
During an NRC inspection conducted on April 27 May 29,1992, a violation of NRC requirements was identified, in accordance with tho
- General Statement of Policy and Procedure for NRC Enforcement Action, " 10 CFR Part 2. Appendix C, the Vio!ation is listed below:
10 CFR 50, Appendix B, Criterion V, requires that actMiles affecting quality be prescribm! by documented Instructions or procedures and chall be accomplished in accordance with these instructions or procedures. Paragraph 2.4 of CP&L Engineering Procedure ENP-12 requires that an operability assessment be performed within 30 days of identification of deficiencies in safety related components and/or systems.
Contrary to the above, operability assessments were not performed within the 30 days period for deficiencies identified during 1991 in structural steel platforms construction.
The time for completing the required operability assessments exceeded six months.
Thls is a Severity Level IV violation (Supplement 1).
RESPONSE TO VIOLATION:
1\\rimission or Denial of Violatior):
Ccro!!na Pcwor a Light Company adm!ts this vlotation.
Egason for the Violation:
As a result of commitments establisned to resolve the issues addressed by.
J25/88-035, Brunswick in!tlated the 'As-Bullt Verification of Miscellaneous Steel
- project, PCN-80060A in July,1990. The initial program consisted of the following major phasos:
Selection of six supplementary structun ', teel samples located in each unit's Reactor Building Development of a comprehensive procedure for as-built information.
a 1
E
_l q ~.
Assembly of loading information based on walkdown data
~
i Performance of engineering evaluatloas e
. Where deficiencies were encountered the necessary reconculation would be performed
- Where Short Term Structural integrity critoria could be mot an Engineering Evaluation would be developed por plant procedure Compilation in a report of thn walkdowns and evaluations e
Development of a motbod for permanent retriovabulN of the supplemental structural stool as built condition and,saluations As evidenced by the aforementioned elements, operability assessments would be performod only after accumulailng the data associated with a miscellaneous steel structure and then evaluating the overall conoblon. At that point, the requirement for completion of the evaluation within thirty days would be invoked if doomed appropriate. This interpretation of the requiroments within ENP 12 was considered prudent and necessary to ensure proper assesstnent of deficiencies constituting potential operabuity
' Concents.'
Following Site Review Group approva' of the project funding, inspections were initiated in late 1990 and continued into 1991. Some of the deficiencies identified by the NRC anci cited in inspection Report 92-14 were also identiflod during these inspections.- At the ilme of the NRC April 27,1992 inspection, the evaluation phase of the project had not boon completed due to limitations on resourcer.
Corrective Steos Which Havo Been Taken and Reputts Achieved:
Due to concerns associated with the adequacy of the As-Bullt Verification of Structural Steel project, th3 project has been significan1y enhanced. The enhanced program, retitled "Misenllaneous Steel Verification Program", was initiated in June of 1992.. Details of the program componencs were communicated to the Division of Nue: ear Roactor Regulations via Nuclear Licensing Section totter NLS-92-203, dated July 27,1992. The enhanced program has been designed to include an engineering -
wa!kdown to support pre!!mv.ary assessment of ldentified pott.ntial operab!!!!y ccacems. Phase One consists of an englnoering walkdown of the miscellaneous steel outside the drywell. Tl:Is walkdown is directed toward providing an immediate appraisal of miscellaneous steel members and connections.
Phase One is approximately 36% complete. Phase TV,o of the program applies to both the drywell platform steel and the miscellaneous steel in the Reactor Building, outside the drywell and consists of-
.two parts.~ One part consists of a prollminary analysis of representative platform sections in the drywell
.and in the Reactor Budding outside of the citywell Part Two provides more detailed verification and documentation of miscellaneous structural steel Phase Two is approximateiy 6% complete. CP&L
' management is committed to the Miscellaneous Steel Verification Program and has dodlcated the necessary resources to ensure its completion as delinoated in the aforemontioned letter of commitment.
B 2
=
' Corrective Actions That Will Be Taken To Avoid Further Violations:
Assessment of the deficiencbs identified during the As-Bullt Verification of Structural Steel project 1990 1991 Inspections will be performed prior to startup of the affected unit as a result of the Misco!!aneous Steel Verification Program efforts. Those deficiencies identified as operability concerns will be either reconc!!od on repaired prior to the startup of the affected unit in accordance with the elements of the Miscellaneous Steel Verification Program.
The Brunawick integrated Sci.adule (BlS) program will identify to the NRC projects such as that from LER 325/88-035 and provkie a schedule for completion and a status update overy six months.
Consequently, reallocation of resources required to support major regulatory committed projects will not occur without CP&L rnanagement concurrence and NRC notification.
Date When Full Comollance Wl'1 Be' Achieved; Based on implementation of the Miscellaneous Steel Verification Program, CP&L is in compliance.
i l
I-l 3
l L.
h 4
s b
?
] g?Q
-1C DE"lAT'4)Jff;
~
Durin(
3 Inspection conductcc' on / aril 27 May 29,1992, a.eviatiori of written commitment was identiflu, scordance whh the "G : ret d Statement of Policy and Procedure for NRC Enforcement f:
4 4 Actic f, s Part 2, Append!x C, +.e deviation is listed %Iow:
k:: e W.
V FSAR Section 17. A.3.4.4.4., d.1 and o 3 states ths all structural steel construction was Y
.{
. inspected for confumance to Araerican InstiMe of Steel ConstrLction (AISC) e sp xliimtions, and that field welds were visually inspectd for conformance with AWS 6pecifications.
14 s
FSAR Section 3.8.4.5.b states that structural steel was designed ln accordance with AISC-1963 sMcifications.
Contrana 'n t'ne above, f tructural steel construction was not adequately inspected for
(
i
^,"
o AlSC specifications and field welds were not adequately visually
.,onformance with AWS specifications. Thlt,is demonstrated by the
- oversized and flame cut holes in structural steel connections, structural steel 5
......J in accordance with construction drawing requirements, and field welds which do not conform to AWS requirements or details shown on the structural steel construction drawings, Do:,ign evaluation of several structural steel platforms indicate that the stresses in the structural steel exceed AiSC design a.4owable values.
RESPONSE TO DEVIATION:
.Mmiss!cn or Dental of Deviat!on Carolina Power & L!ght Company admits this deviation I
ERREQD for the Deviat'on:
The Inspections performed to verify construction of misco'laneous ster" during original plant cons'.cuction were inadequate.
4
ou n y,;
~.
.(
l Corrective Stepji Which Have Been Taken and Results Achieved:
The Miscellaneous Steet Ve'rlfication Program tes been initiated to ensure compilance with the design criteria delineated in the Brunswick Plant Updated F61 Saluty Analysis Report (?SAR). Due to the magnitude.of miscellaneous steel the program is divided into two phases. Phase One consists of an
. engineering walkdown of the miscellaneous steel outside the drywell. This wa!kdown is di'ected toward
. providing an immediat's acpraisal of miscellaneous steel memben, and connections. Phase One is 36%
' complete.- Phase Two of the program appilos to both the drywell platform steel and the miscellaneous steel in the Reactor Buliding outside the drywell and consl.* d two parts. One part cot.sists of a
- preliminary analysis of representative platform sections in tue.fwell and in the Reactor Bt,lding outside of the drywelle.Part Two provides more detailed verificatio and documentation of miscellaneous structural steel.
in contrast to the level of requirements in affect during initial plant construction specification > d plant modification procedures have beer' enhanced to ensure adequate verification of civil attributes prior to tumover of newly installed miscellaneous steel structures.
Correctlyg,Ac.fionr. That Will Be Taken To Avoid Further Violations:
Phase One rand the portion of Phase Two that will be completed prior to plant operation will provide a
? high confidence that the miscellaneous structural steel is adequate to function in a safe manner for def'ncd cr:veloping plant loading conditions.
Those deficiencies identKled as operability concerns will be either reconciled or repaired prior to the startup of the affected unit in accordance with the elements of the Misceilaneous Steel Verification Program.
4
- Date When Corrective Actions Will Be Comotete:
Phase One of the Miscellaneous Steel Verification Program will be completed prior 'a startup.
i i' amp etion of Phase Two of the Miscellaneous Steel Verification Program is scheduled for November kJ3
[ '
-4.-
I 5-t 79 se ar