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Insp Repts 50-324/92-33 & 50-325/92-33 on 921005-09 & 19-23. Violations Noted.Major Areas Inspected:Miscellaneous Structural Steel Verification Program & Anchoring of safety- Related Motor Control Ctrs & Electrical Back Panels
	ML20126D868
Person / Time
Site:	Brunswick
Issue date:	11/18/1992
From:	Blake J, Lenahan J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20126D865	List: ML20126D862; ML20126D866; ML20126D868;
References
	50-324-92-33, 50-325-92-33, NUDOCS 9212280197
	Download: ML20126D868 (8)
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NOV 2 01992

i Report Nos.: 50 325/92-33 and 50 324/92 33

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Licensee: Carolina Power and Light Company

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P. O. Box 1551

1 Raleigh, NC 27602

Docket Nos.: 50 325 and 50-324 License Nos.: DPR-71 and DPR-62

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Facility Name: Brunswick 1 and 2

Inspection Condt te : October 5 9 and October 19-23, 1992

Inspect r: k- p r

jd. _/ onaian ) ate Signed _

Approved y1 ,6 _// f

Jf J/Blake, klIIEi,. Date Signed

h rials and Processes Section

f at6Engineering Branch

Division of Reactor Safety

SUMMARY

Scope:

This special announced inspection was conducted in the areas of the

miscellaneous structural steel verification program, anchoring of safety-

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related motor control centers and electrical back panels, and licensee action

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on previous inspection findings.

Results:

In the areas inspected, deviations were not identified.

One violation was identified for failure to take prompt measures to correct

inadequate weld inspection procedure - Parlsraph 2.b. The violation is

indicative of the continuing weakness in using inadecuate or draft procedures

to perform safety related work activities. This sae weakness was identified

in several previous inspections,

i An Unresolved item was identified regarding adequacy of corrective actions-to

! resolve MCC anchorage problems - Paragraph 3.

9212280197 921120

PDR ADOCK 05000324

PDR

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l REPORT DETAILS- !

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1. Persons Contacted

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l Licensee Employees 1

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- H. Beane, Manager, Quality Control l

l ***S. Callis, Licensing Engineer j

i *J. Brown, Unit 1 Plant Manager ,

- J. Cowan, Manager, Technical Support and Regulatory Compliance

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- R . Helme, Manager, Regulatory Compliance

***J. Holder, Manager, Outage Management and Modifications ;

*R. Knott, Principal Engineer, Nuclear ~ Engineering Department (NED) !

- - J. Leininger, Onsite Manager, NED i

- A. Lucas, Vice President, Engineering !

- **D McCarthy, Manager, Nuclear Licensing !

- - R. Richey, Vice President. Brunswick *

. **R. Morgan, Unit 2 Plant Manager

***G. <

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R.-Tripp,

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Thearling,il Civ Engineer, NEDSenior Specialist, Regulatory Compliance i

S. Vann, Misc. Steel Project Manager, NED l

- D. Waters, Manager, Brunswick Licensing Unit ;

- A. Watson, Senior Vice President ;

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H. Williams, Chief Civil Engineer, NED

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- L. Grzeck, Project Engineer, Misc. Steel, NED

W. Monroe, Principal Engineer, NED- !

Other licensee employees contacted during this inspection included

engineers, mechanics, technicians, and administrative personnel.

Other Organization i

R. Kosiba, Project Manager, Bechtel

T. Logan, Site Manager, Bechtel .

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S. Eder, Structural Engineer, EQE Engineering Consultants

G. Handy, Structural Engineer, EQE Engineering Consultants _

W.-Egan, Civil Engineer, McKim and Creed

Other Bechtel employees contacted during this inspection' included four

structural engineers.

Technical- Advisory Committee - Miscellaneous Steel Verification Program ,

Dr. J. Fisher, Lehigh University.

Dr. O. Gurbuz, Bechtel

Dr. G. Harstead, Harstead Engineering Associates

Dr. 4 Stevenson, Stevenson and Associates

E.-Thomas, Bechtel- .

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NRC Resident' Inspectors

- - R. Prevatte,- Senior Resident inspector

P. Byron, Resident Inspecto.r.

D. Nelson, Resident inspector

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i * Attended October 9 Exit Interview

l ** Attended October 23 Exit Interview

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- - Attended Both Exit Interviews

2. Miscellaneous Structural Steel Evaluation Program - Units 1 and 2 (37700)

a. Background

4 Miscellaneous structural steel consists of platforms and other t

beams / columns which provide personnel access and/or support for

i piping, electrical rrceways and conduits, HVAC ducts,

i instrumentation, and other equipment not supported from the main

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building structures. Numerous deficiencies in miscellaneous steel

i have been identified by either the licensee or NRC, including lack

of design calculations, lack of as-built drawings, missing bolts and

welds, incer tect size members, undersized welds, missing members,

and other construction deficiencies.

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The licensee retained Bechtel Power Corporation to perform walkdown

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inspections, prepare as-built drawings, and prepare design

calculations to determine if the structural steel is qualified. The

Bechtel 3rogram is a two phase project with the purpose of

, establisiing a high level of confidence that the miscellaneous steel

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is adequate for operation. The structural steel will be modified as

required to meet FSAR requirements. The inspector previously

inspected the Bechtel program during inspections documented in NRC

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Inspection Report numbers 50325,324/92-20,50-325,324/92-23,and

l 50-325,324/92-27.

, b. Review of Structural Steel Verification Program Procedures

The inspector examined a draft of Revision 3 to Bechtel Procedure

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No. WDP 002, Phase 11 Walkdown Procedure for Reactor Building

Miscellaneous Steel and Drywell Platform Steel. Revision 3 to

Procedure WDP-002 was written to resolve deficiencies in Revision 2,

identified by Region 11 inspectors, in an inspection conducted

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September 14-18, 1992 ano documented in NRC Inspection Report

l 50-325,324/92-27. A violation, number 325/92-27-02,was

issued as a result of. procedural deficiencies and errors

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in the Phase 11 walkdowns and design calculations

identified during the September 14-18 inspection. Some of

the errors identified during the walkdown were the result

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of an inadequate procedure. The licensee had continued

the Phase 11 inspections in the Unit I drywell and in the

Unit 2 reactor building since September 18, 1992, using

Revision 2 of Procedure WDP-002. Discussions with

licensee and Bechtel engineers disclosed that some of the

inspection work was continuing "at risk", and that

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walkdown personnel (field engineers) had received training

regarding proper identification of the partial penetration

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welds, which was not adequately addressed in Revision 2 of

WDP-002. Although the walkdown personnel may have

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received training to correct problems caused by the

i inadequate procedures, continuation of the Phase 11

l walkdown inspection activities for the five (5), week

period since violation 325/92-27-02 was identified using

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, an inadequate / outdated procedure is a violation of

10 CFR 50, Ap)endix B, Criterion XVI. Subsequent to the

inspection, tie licensee informed the inspector that

j Revision 3 of WDP-002 was approved and issued on

October 26, 1992. The fact that work continued using an

j inadequate procedure for the Phase 11 weld inspections and

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not taking prompt corrective action to revise procedure

WDP-002 to correct the deficiencies identified by the NRC

' inspectors on September 17, 1992, was identified to the

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licensee as violation item 325, 324/92-33 01, failure to

, Take Prompt Corrective Action to Revise Inadequate Weld

! Inspection Procedure.

j c. Technical Advisory Committee (TAC) Meeting

The inspector attended portions of the TAC meetings held at the site

on October 8 and 22, 1992. The Technical Advisory Committee for the

miscellaneous steel verification program is composed of recognized

, experts in the areas of structural steel design. The purpose of the

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TAC is to review the overall miscellaneous structural steel

! verification program, review design criteria, review the analytical

approach used to perform the design analysis of the platform steel,

j and provide technical guidance on evaluation and correction of

. construction deficiencies. The following subjects were discussed

during the meeting.

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Project status.

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Tolerances for measuring copes, welds, and other commodities,

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Methodology to evaluate stress on connector beam webs.

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Consideration of moments on clip plates bolted to webs.

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Sizing welds on welded plate angles.

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Evaluation of beams with axially slotted holes at both ends.

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Definition of faying surfaces.

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Evaluation of beam shear connections on built-up clip angles

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under significant transverse loads.

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Testing results performed on shear (clip) plates welded on one

side.

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Program for inaccessible items.

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Weld evaluation.

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Other Evaluation issues.

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lavisions to WDP-002 for inspection of slag covered welds and

partial penetration welds.

, The licensee is in the process of preparing the final report

containing the TAC recommendations.

Deviations were not identified.

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3. Anchorage of Motor Control Centers - Units 1 and 2 (37700)

In early 1989, while in the process of pre)aring a plant modification,

licensee engineers discovered that the anc1orage for a motor control

center did not conform to drawing requirements. A number of 1/2 inch

diameter hold down bolts / nuts were found to be missing. Licensee

engineers then performed an inspection of six motor control centers

(MCCs) on elevation 20 of the Unit I reactor building. This inspection

disclosed that the anchorage details for the six MCCs did not conform to

the requirements of Drawing Number 9527 F 18061. Reactor Building Unit _l,

Motor Control Center Foundation. The deficiencies involved eithW

missing nuts on the 1/2 inch diameter anchor bolts, or missing an; hor

bolts which were to attach the MCCs to their foundations. This pr@lem

was documented on nonconformance report (NCR) number A-89-015, datec

March 3, 1989. The corrective action for the NCR was to install the

missing nuts and tighten all nuts to a snug tight condition. Operabil'ty

of the MCCs was addressed in Calculation number 1-01534A-128, Unit 1

Reactor Building Elevation 20 MCC Anchor Evaluation. The inspector

reviewed this calculation. This review disclosed that the calculation

results indicated the MCCs were operable in the as-built condition with

the missing nuts. However, the calculation took credit for some existing

1/4 inch diameter bolts installed in the shipping channels for anchorage

of the MCCs to their foundation. The justification for closing out the

NCR was based on the calculation results and the initiation of trouble

tickets to install the missing nuts on the six HCCs.

The inspector reviewed the trouble tickets to determine the status of the

corrective action. This review disclosed that the corrective action,

i.e. installation of the nuts had not been completed. A description of

the problem, trouble ticket number and station is summarized in the Table

below.

TABLE

MCC Number and Deficiency Trouble Ticket No. Status ~

l X A - 1 missing nut 89 - ALXY1 Returned to NE0*

1 X DA - 14 missing nuts 89 - ALXXI Returned to NED*

1 X A2 - 8 missing nuts 89 ALXR1 Voided

1 X B - 16 missing nuts 89 - ALXZ1 Returned to NED*

1 X DB - 15 missing nuts 89 - ALYAl Returned to NED*

1 X B2 - 8 missing nuts 89 - ALYB1 Voided

The work specified on the trouble ticket could not be performed and

the trouble ticket was returned to Nuclear Engineering (NED) for

further evaluation.

During the current outage, licensee engineers inspected all 46 MCC

installed in the Unit I and 2 reactor buildings, the diesel generator-

building, and the control building. Numerous deficiencies were

identified, including one MCC (2-2xB-2), which had no anchorage. This

MCC was reported to NRC as inoperable in Licensee Event Report 92-05 for

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l Docket Number 05000324 (Unit 2) on June 27, 1992. The results of the

l inspections and the deficiencies are summarized in Attochment A to

j Engineering Evaluation Report (EER) number 92 0266, titled MCC Anchorage

j Evaluation Summary. The corrective actions for 5 MCCs, numbers 2XA,

i 2XA2, 2XB, 2XB2, and 2XM were specified on field Revision 2 to Plant

Modification 91-041, lhe inspector reviewed the QC verified drawings

which indicate these MCCs had been modified. Action item 92 0266-01 was

! issued to repair MCCs 2XE, 2XF, 2XG, and 2XH, although these MCCs were

determined to be short term qualified in their as built conditions.

i Action item 92 026602 was issued to tighten the bolts / nuts on MCCs IXG

l and IXDB. The inspector was unable to determine the status of the

corrective action for these two action items during the current

l inspection. The summary in Attachment A to EER 92-0266 also listed

1 numerous " Enhancements" to the various MCC anchorage. The inspector was

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also not able to determine the status of the " Enhancements " Review of

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the above documentation regarding the MCC anchorage problem resulted in

the following questions:

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Why was inspection of MCC anchorage limited to Eievation 20 of the

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Unit I reactor building when the problem was discovered in 19897

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What is justification for considering the 1/4 inch diameter

j " shipping" bolts as part of MCC anchorage and taking credit for

these bolts in calculation 1-01534A-1287

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What is status of repairs specified in action item numbers

92-0266 001 and 002?

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What is status of Enhancements listed in Attachment A to EER

92-02667

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The licensee's actions to investigate and resolve the MCC anchorage

problems appear to be indicative of inadequate corrective action.

Pending further review of the information requested from the licensee in

the above questions, the problem was identified as Unresolved item 325,

324/92 33-02, Adequacy of Licensee's Corrective Actions to Resolve MCC

q Anchorage Problems.

As a result of the problem identified with anchorage of the MCC

cabinets, the licensee retained EQE Engineering Consultants to

perform a review of the anchorage and load path fer floor mounted

i safety related electrical equipment at Brunswick. This review

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involved inspection of the electrical cabinets, comparison of the

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as-built anchorage to construction drawing requirements,

documentation of any deviation from the drawing requirement, and

evaluation of the deviations. The results of the EQE study is

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documented in EQE Report titled Electrical Equipment Anchorage

Review, dated July 24, 1992. The inspector reviewed the report

which consisted of the inspection procedure, field inspection data

sheets, EQE calculation 52171-0-003, and the results-and conclusions

of the EQE study. The EQE engineers determined that although many

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of the cabinets had anchorage deviations, all the cabinets were

operable. The EQE report recommended modifications to eight

cabinets.

The inspector randomly selected and walked down numerous electrical

cabinets on elevation 49 of the Units 1 and 2 Control Building. The

ins 3ector compared the as-built anchorage of the cabinets with the

anc1orage inspection data documented on the EQE field data sheets.

Cabinets examined were as follows: Unit 1 XU 14, XU 39, P616, P618. -

621, AND P627, Unit 2 XV-14, XV 16, XV-21, XU-22, XU 23, XV 25, XU 53,

XV 57, P 604, P-607, P614, P617, P618, P621, P623, and P627. The

inspector noted some variances in the weld sizes anchoring cabinet number

XV 14 in Unit 1 and P618 and 623 in Unit 2. The actual weld sizes were

smaller than those indicated on the EQE field inspection data sheets.

However these were minor and did not effect the overall conclusions of

the study. Also the data sheet was missing from the report for Unit I

cabinet P627. The inspector concluded that the results of the EQE study

were acceptable and that the cabinets inspected met anchorage

requirements for seismic design conditions.

During the walkdown inspection of the cabinets the inspector identified

numerous housekeeping / material condition deficiencies in some Unit I

cabinets. These included the following: XV-25, missing or loose

bolts / nuts; P604, unattached cover plate resting against bottom inside

side of cabinet; P614, loose wiring harness; and P617, loose plastic

strips in cabinet, unused hardware (bolts and nuts) lying in cabinet,

light burned out. The inspector walked down the area with the OM&M

manager and point out the deficiencies which require some corrective

action. These items will be reviewed as part of Unresolved item 325,

324/92-14-03.

Violations or deviations were not identified.

4. Action on Previous Inspection Findings (92701)

(0 pen) Unresolved item (324/92-27-03), Potentially Overspanned Conduits.

The inspector met with licensee engineers and engineers from EQE

Engineering Consultants and discussed the licenwee's criteria for

inspecting conduits and identifying cases where the span lengths between

conduit supports exceed those specified in specification 048-010,

Specification for Installation of Seismic Conduit Supports. The licensee

plans to use criteria in the Generic Implementing Procedure (GIP) for

Seismic Verification of Nuclear Plant Equipment. The inspector reviewed

Section 8 of GIP, Cable and Conduit Raceway Review. Discussions with the

EQE engineers disclosed that they had identified several " outliers" in

the Unit 2 drywell, per definition of Section 8 of the GIP, and-that the

outliers would be evaluated per criteria specified in the GIP. The

licensee plans to perform further conduit inspection, and review any

outliers per the GIP criteria. This unresolved item remains open pending

further review by NRC.

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j 5. Exit Interview

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! The inspection scope and results were summarized on October 9 and 23,

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1992, with those persons indicated in paragraph 1. The violation was ,

j also discussed by the inspector with J. Leininger and S. Vann in a !

telephone conversation on October 28, 1992. The inspector described the ,

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areas inspected and discussed in detail the inspection results listed i

below. Proprietary information is not contained in this report. l

Dissenting comments were not received frm the licensee. j

l Violation 325, 324/92-33 01, Failure to Take Prompt Corrective Action to

] Revise Inadequate Weld Inspection Procedure

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Unresolved item 325, 324/92 33 02, Adequacy of Licensee's Corrective

Actions to Resolve MCC Anchorage Problems ;

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ML20126D868

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