ML20101J736
| ML20101J736 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/24/1992 |
| From: | Spencer J CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9207010222 | |
| Download: ML20101J736 (4) | |
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-m mtawawn - m Carolina Power & Ught Company WaaravgEaaacMJw&traccuets Brunswich Nuclear Project P. O. Cox 10429 Southtcrt, N.C.
28461-0429 JUN 2 41M2 FILE:
B09-13510C 10CFR2.201 U.S.
+1elear Regulatory Commission A1TN Document Control Desk Washington, D.
C.
20555 BRUNSWICK STEAM ELECTRIC PIANT UNIT 1 & 2 DOCKET NOS. 50-325 & 50-324 1
LICENSE NOS. DPR-71 & DPR-62 BEPLY TO A NOTICE OF VIOLATION Gentlemen The Brunswick Steam Electric Plant (BSEP) has received NRC Inspection Report 50-325,324/92-11-01 and finds that it does not contain trformation of a proprietary nature. This report included a Notice Of V'.olation.
Enclosed is Carolina Pcw r & Light Company's respot.se to that Notice of Violation.
Vety truly yours, Q
J.
- Spencer, eneral Manager ru swick Nuclear Project RSK/
Enclosure cc:
Mr. S.
D.
Ebneter Mr.
R.
H.
Lo BSEP NRC Resident Office 6
9207010222 920624
/
PDR ADOCK 05000324 i l O
ENCLOSURE BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 & 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NO. DPR-71 & DPR-62 REPLY TO NOTICE OF VIOLATION VIOL % TION At Technical Specification 3.7.2 requirse that two independent control room emergency filtration systcrs shall be operable and allows one control room emergency filtration system to be inoperable no more than saven da/s or shur both units down.
t ntrary to the above, on April 13, 1992, the 2A control building emergency air filter was found not to be fastened on one sloe, which rendered it seismically inoperable. This condition had existed since initial installation. Due to this s
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condition, train 2A ^* the control room emergency filtration system has been inoperuble (but available) since initial plant operation. The licensee had three opportunities to identify this condition; initial testing and during the 1987 and 1992 inspections and evaluations for seismic qualification.
This is a severity level IV violation (Supplement I).
Reference:
Inspection Report 92-11 s
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RESPONSE TO VIOLATION:
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Admission or Derd_al of Violations j
i CP&L accepts the violation.
i BIh>'_ON FOR VIOLATION:
The historical document investigation into the ca.use of the Control Building Emergency Air Filtration (CBEAF) missing clip angle welds has produced limited information. The original construction print did not show the clip angle welds.
J A revision to this drawing added detail 'W',
which shows the clio angle welds with a note 'to be installed by others'. The historical records indicate that the print containing d ta.1
'W' wao in effect at the time the 2A CBEAF uni.t housing was mounted on the foundation in November,1973. As a result, the reason the clip angle welds were not installed cannot be jetermined from the historical records.
4 The Brown & Root Equipment Record Card does contain a Quality Control (QC)-
inspection sign-of f in December,1974, for the 2A CBEAP housing installation. The d
extent of this QC inspaction could not be determined from the equipment record card and other associated documents.
In October 1987, an engineering request memorandum was issued on the CBEAF unith j
identifying bent stude, nute that were not tightened down, and vibration isolators that were out of adjustment. The memorandum requested an evaluation on the effect of these conditions relative to CBEAF operability / seismic.
qualification. The individual who performed this evaluation le no longer employed by Carolina Power & Light but was contacted concerning this evaluation. The discussion indicateG that the subject of the evaluation was the bent-stude, however; an overall inspection of the unit was performed at that time. The individual indicated that he did look on the underside of the unit where the clip angles are located, but did not notice the welds were missing. The inspection and evaluation performed by this individual addressed the bent stude, nuts that were not tightened and' vibration isolators that were out of adjustment; however, it did not identify the mis >ing clip angle welds.
i In April 1992, an auxiliary operator raised a seismic concern on the 2A and 2B CBEAF units due to bent anchor bolts not making full contact.with the I beam. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Limiting Condition for Operation was. initiated to have an operability evaluation performed on both units. The Technical Support group wan nctified and they contacted the Nuclear Engineering (NED)- group. An NED engineer performed c r
j preliminary engineering evaluation on both CBEAF units. Basti.d on the preliminary evaluation, the NED engineer decided to focus - on qualifying the 2B CBEAF unit first. A more detailed waination on the 2B CBFAF unit was subsequently i
performed.
i Based on information provided by the Technical Support group, an NRC Resident Inspector thought that the NED engineer had-finished evaluating the kA CBEAF l
unit As a result, the inspecto*' proceeded to perform an examination of the 2A 1
.CBEAF unit'and noted that the clip angles were not welded to the unit. He then notified personnel in the Technical Support group and they conta cted the Centrol Room to declare the 2A CBEAF unit inoperable. duo lto seismic concerns.
The third event shculd not be considered a missed opportunity to find the unwelded clip angles since the NED evaluation was still in progress when the NRC Resident notified licensee personnel of the condition.
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:
n The welds were f abricated at the clip angles that attach the equipment to the foundation beam. The 2A CBEAF unit is seismically qualified.
r& ERECTIVE A GIONS WHICH WILL BE TAKEN TO AVOID PURTHER VIOLb110NS A revision to the ENP-12, Engineering Evaluation Procedure will be made to empnasit2 the need to thoroughly verify as-built records and field inspections including the functional attributas prior to making an operability assesament.
Training on the ENP-12 revision will be provided to appropriate Technical Support and NED personnel.
Revisions to the DG-II.20, Design Guide for Civil Structural Operability and JG.III-16, Brunswick Nuclear Project Structural Scope Documents will be-made.
Thase revisions will stress the importance of comprehensive field inspections to ensure acceptability of relevant civil fur.ctional attributes ior qualification of equipment.
Training on DG-II.20 and DG-III.16 will be provided to appropriate NED personnel.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
CP&L is in full compliance.
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