ML20198P056

NOV from Insp Completed on 971113.Violation Noted:Licensee Failed to Promptly Correct Condition Adverse to Quality Re Unit 1 High Drywell Temp Condition

ML20198P056
Person / Time
Site:	Brunswick
Issue date:	12/23/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198P028	List: ML20198P023 ML20198P056
References
50-325-97-12, EA-97-520, NUDOCS 9801210317
Download: ML20198P056 (2)

Text

NOTICE OF VIOLATION Carolina Power and Light Company Docket No. 50 325 Brunswick Nuclear Plant License No. DPR 71 Unit 1 EA 97 520 As a result of an NRC inspection completed on November 13, 1997, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. >

Contrary to the above, between June 1997 and September 1997, the licensee failed to promptly correct a condition adverse to quality, i.e., a Unit I high drywell temperature condition. The Unit I drywell temperature exceeded 221.7 degrees Farenheit (*F), a temperature limit which had been established by the licensee in an engineering analysis to justify operation with drywell temperature above the Final Safety Analysis Report limit of 200*F. As a result of the higher temperature, seven out of ten snubbers on the reactor head vent line were declared inoperable because they exceeded their seal life, (01014)

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Carolina Power & Light Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk Washington, D.C. 20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the Brunswick facility, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555 001.

Enclosure 1

^ ^

^ 99012103'17 971223 PDR ADOCK 05000324 G PDR

Notice of Violation :2  !

Because your res)onse will be placed in the NRC Public' Document Room (PDR), to the extent possi)le.. it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PR without redaction. If-  :

-personal privacy or proprietary information is necessary to provide an acceptable

. response, then please )rovide a bracketed copy of your. response that identifies-  ;

the information that s1ould be protected and a redacted copy of your response. j that deletes such information. If you request withholding of such material.- you  :

Bud; specifically identify the portions of your res'ponse that you seek to have  !

withheld and >rovide in detail the bases for your. claim of. withholding (e.g., t explain why tie disclosure of information will create an unwarranted invasion of '

personal privacy or provide the information required by 10 CFR 2.790(b) to -;

support a request for withholding confidential comercial or financial ,

information). If safeguards information is necessary'to provide an acceptable  :

response, please provide the -level of protection described-in 10 CFR 73.21.  !

. Dated at Atlant'a, GA l Lthis 23th day of December 1997' i

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LIST OF PREDECISIONAL ENFORCEMENT CONFERENCE ATTENDEES December 19, 1997 Carolina Power & Liaht Comoany C,lHinnant, Vice President Brunswick Steam Electric Plant-J. Lyash, Plant General Manager W. Dorman, Licensing Supervisor Support Section G, Miller, Manager, D. Benyak, Supervisor,Brunswick Engineering / Operating Experience Corrective Actions Nuclear Reaulatory Commission

.L. Reyes, Regional Administrator, Region II (RII)

J,'Jaudon, Director, Division of Reactor Safety (DRS), RII L.-P11sco, Deputy Director, Division of Reactor Projects (DRP), RII A. Boland, Director Enforcement and Investigation Coordination Staff (EICS), RII H. Shymlock, Chief, Reactor Projects Branch 4 (RPB4), DRP, RII C Evans, Regional Counsel, RII R Bernhard, Senior Reactor Analyst, RII C, Patterson, Senior Resident Inspector, Brunswick G MacDonald, Senior Project Engineer, RPB4, DRP, RII

• J. Lyons Acting Director, Project Directorate 111, Office of Nuclear Reactor.

Regusation (NRR)

• D. Trimble, Project Manager,- NRR

• D, Nelson, Enforcement Coordinator, Office of Enforcement L L. Watson, Enforcement Specialist, EICS, RII R. Telson, Resident Inspector, Sequoyah, RII G. Warnick, Resident Inspector Development Program, RPB4, RII H. King, Resident Inspector Development Program, RPBS, RII

• By phone Enclosure 2

NOTICE OF VIOLATION Carolina Power and Light Company Docket No. 50 325 Brunswick Nuclear Plant License No. DPR 71 Unit 1 EA 97 520 As a result of an NRC inspection completed on November 13. 1997, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

10 CFR 50, Appendix B, Criterion XVI Corrective Action, requires that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, between June 1997 and September 1997, the licensee failed to promptly correct a condition adverse to quality, i.e., a Unit I high drywell temperature condition. The Unit I drywell temperature exceeded 221.7 degrees Farenheit ('F), a temperature limit which had been established by the licensee in an engineering analysis to justify operation with drywell temperature above the Final Safety Analysis Report limit of 200*F. As a result of the higher temperature, seven out of ten snubbers on

- the reactor head vent line were declared inoperable because they exceeded their seal life. (01014)

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Carolina Power & Light Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk. Washington, D.C. 20555 with a copy to the Regional Administrator, Region 11. and a copy to the NRC Resident Inspector at the Brunswick facility, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation. (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director Office of Enforcement, United States Nuclear Regulatory 1 Commission, Washington, DC 20555 001.

Enclosure 1 l

Notice of Violation 2 [

Because your res)onse will te placed in the NRC Public Document Room (PDR), to  !

the extent possi)1e, it shou',d not include any personal arivacy, proprietary, or  :

safeguards information so that it can be placed in the P)R witMut redaction. If  !

personal privacy or proprietary information is necessary to provide an acceptable  :

response, then please )rovide a bracketed copy of your response that identifies the information that siould be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you M spcifically identify the portions of your respnse th..: vou seek to have  ;

withheld and )rovide in detail the bases for your claim of withnelding (e.g.,

explain why tie disclosure of information will create an unwarranted invation of personal privacy or provide the information required by 10 CFR 2.790(b) to i support a request for withholding confidential commercial or financial

.information). -If safeguards information is necessary to provide an acceptable response, please provide tha level of protection described in 10 CFR 73.21.

Dated at Atlanta, GA

.this 23th day of December 1997 I

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l LIST OF PREDECISIONAL ENFORCEMENT CONFERENCE ATTENDEES f December 19, 1997 Carolina Power & Licht Comoany l

C, Hinnant 'Vice President Brunswick Steam Electric Plant I J. Lyash, Plant General Manager W Dorman, Licensing Supervisor Support Section G. Miller, Manager, D. Benyak, Supervisor,Brunswick Corrective Engineering Actions / Operating Experience Nuclear Reaulatory Commission L. Reyes, Regional Administrator, Region II (RII)  !

J. Jaudon, Director, Division of Reactor Safety (DRS), RII

-L. P11sco, Deputy Director, Division of Reactor Projects (DRP), RII -

A. Boland, Director, Enforcement and Investigation Coordination Staff (EICS), RII M. Shymlock, Chief, Reactor Projects Branch 4 (RPB4), DRP, RII C. Evans Regional Counsel, RII R. Bernhard, Senior Reactor Analyst, RII C. Patterson, Senior Resident Inspector, Brunswick  ;

G. MacDonald, Senior Project Engineer, RPB4, DRP, RII. t

• J. Lyons Acting Director, Project Directorate 11 1, Office of Nuclear _ Reactor Regulation (NRR)

• D. Trimble, Project Manager, NRR .

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• D. Nelson, Enforcement Coordinator, Office of Enforcement L. Watson, Enforcement Specialist, EICS, RII -

R. Telson, Resident Inspector, Sequoyah, RII G. Warnick, Resident Inspector Development Program. RPB4, RII M. King, Resident Inspector Development Program, RPBS, RII

-*By phone ,

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Enclosure 2- t 1

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Agenda 4

e introduction C. Hinnant

! e Discussion of Apparent Violation G. Miller

+ Drywell Temperature l + Drywell to Torus Bypass I

4 e Corrective Action Effectiveness J.Lyash i

e Summary C. Hinnant sp&L 2

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Introduction l eCommon understandings

! + The impact of increasing drywell temperatures was not initially realized i

uThe timeline related to this issue will be discussed i

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! Introduction i

eThe Inspection Report indicates action was not taken for increased drywell temperatures l and industry reports of potential drywell to l torus bypass concerns

+ Actions were taken related to both issues

e Actions on the torus bypass issue were l appropriate based on the information known eThe corrective action and operational experience (OE} programs are effective CP&L 5

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Apparent Violation

! eFailure to take prompt corrective actions regarding:

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! + Unit 1 drywell temperatures exceeding an existing analysis when a drywell cooler fan '

failed l + A design deficiency where the pressure ,

suppression design function of primary containment could be bypassed under certain operating conditions

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l Drywell Temperature i

! Background i

e1991 I'

+ Updated Final Safety Analysis Report (UFSAR) localized drywell temperature limit was changed to 200 degrees Fahrenheit

eApril 1996

+ Localized Unit 2 drywell temperatures were identified in excess of UFSAR limit I

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Drywell Temperature

Background

eApril 1996 (cont.)

+ Corrective actions mA preliminary evaluation of temperature impact j was performed

, mDrywell cooling system inspection and repair l activities were scheduled CP&L 9

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Drywell Temperature

Background i

eDecember 1996 l; l + Detailed temperature evaluation was l completed l + An existing error in snubber seal life l calculation methodology was not recognized l

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I Drywell Temperature l Background L

eJune 1997

+ Drywell cooling fan 1D1 failed

+ Operations identified temperature concern to l Engineering l + Unit 1 drywell temperatures were evaluated i

against previous temperature analysis

! mEvaluation was not documented l i j .uAnalysis was not revised for higher temperatures (issue was not pursued by Operations on a l priority basis due to Engineering conclusions l Sf.ag:

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! Drywell Temperature

Background

eSeptember 1997 L + An evaluation was being prepared to support j next cycle operation ,

l mElevated Unit 1 drywell temperatures were recognized i

mDiscipline review identified Units 1 and 2 drywell l snubber operability concern due to calculation l

methodology error

+ Affected reactor head vent snubbers were declared inoperable CP&L 12

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Drywell Temperature

Background

eSeptember 1997 (cont.)

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+ Snubber evaluation was conducted  ;

i mOperability of piping was established without snubbers

! mUnit 2 snubbers were removed l mPast operability of snubbers was demonstrated i .

- 7 visually inspected

! 3 functionally tested CP&L 13 ,

Drywell Temperature Cause Analysis l

e" Owner's Review" of vendor temperature i

analysis was not adequate l eVendor snubber seal life analysis contained l

i flawed calculation methodology j

e December 1996 drywell temperature evaluation carried error forward l e Anticipated temperature increases were not

{ appropriately evaluated / documented in i.

i June 1997-l CP&L 14

Drywell Temperature Immediate Actions Taken elmpact on other plant equipment was evaluated eOperability evaluation was performed CP&L 15

i l Drywell Temperature i

Corrective Actions j eAnalysis of higher drywell temperatures l was performed ~

i eProcedure was developed to monitor and l evaluate drywell temperatures l eRigor of " Owner's Review" has been increased eEfforts to improve drywell cooling performance continue qp&L 16

_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ . - - - - . - - - - . - . - - . . = - . . - - . . - - .

i Drywell Temperature

, t Corrective Actions I .

eSnubber seal life calculation '

methodology was revised l

eSnubber program will be re-evaluated

eVisibility and disposition of abnormal conditions will be enhanced i

CP&L 17

Drywell Temperature Safety Significance eLow safety significance i

+ Snubber operability was demonstrated

+ Piping analysis demonstrated that snubbers l were not necessary

! + Other plant equipment was not adversely

impacted i

CP&L 18

... - - . - _ - - ~ , . - . _ - _ _ . - . . _ _ . _ _ - -

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l Drywell Temperature Issue Summary i -_

eActions were taken when concerns were identified i eFlawed vendor snubber seal life analysis j was not detected and was carried forward eSnubbers were determined to be operable /not required b

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Drywell to Torus Bypass

Background

! eContainment Atmosphere Control system 4

nitrogen inlet valves

+ Share a common header

+ Util_ze i Division 1 logic eLine-up used during power operations for inerting/ purging /de-inerting 21 L .

1 Drywell to Torus Bypass Background  ;

eApril 1997 .

& institute of Nuclear Power Operations {lNPOf OE report was issued regarding LaSalle

! concerns.

mPotential to over-pressurize Standby Gas Treatment (SBGT;i system during venting mPotential to bypass pressure suppression pool function during a loss of coolant accident (LOCA;i l:

i mPotential to bypass pressure suppression pool function during Hydrogen Recombiner system surveillance testing cpap, 22 ,

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Drywell to Torus Bypass

Background

eApril 1997 (cont.)

! + Evaluation was completed within 10 days of issuance by lNPO mSBGT over-pressurization concern had been previously resolved mCredit was taken for LOCA isolation signal to '

resolve drywell to torus bypass concern mHydrogen Recombiner system testing was not of l concern due to different system design i

i CP&L 23-

Drywell to Torus Bypass

Background eMay 1997

+ Dresden made 10CFR50.72 report due to drywell to torus bypass concern i aConcern existed during simultaneous opening of  ;

torus and drywell purge valves

+ Operations evaluated 10CFR50.72 report

within 27 days l

mCredit was taken for LOCA isolation signal

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i Drywell to Torus Bypass

Background

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aAugust 1997

+ Browns Ferry made 10CFR50.72 report due to

! drywell to torus bypass concern i mNRC resident questioned applicability of the issue at Brunswick CP&L i

25 E..-_--____________ _ _ _ . . _ ._ -- _ !

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Drywell to Torus Bypass l Background r

i eAugust to September 1997

+ Multi-discipline review of concern was l

performed l

mDiscussion with Browns Ferry personnel was necessary to fully understand the issue mValve closure and divisional separation concern

. was identified l aConfiguration controls were implemented mNRC wa.s notified via 10CFR50.72 report

, CP&L 26

Drywell to Torus Bypass ,

Background

! eOctober 1997

+ General Electric (GE? issued a related l potential 10CFR21 notification l eNine additional plants reported similar concerns in October through December 1997 primarily based on 10CFR21 reviews E 27

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Drywell to Torus Bypass Actions Taken eConfiguration controls were implemented eDesign bases review was performed to determine issue applicability e10CFR50.72 report was made eProcedures and UFSAR were revised .

prior to performing evolutions 1

eOther potential bypass pathways were evaluated for similar concerns SPL1 28

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li Drywell to Torus Bypass Safety Significance eLow safety significance

+ Valves are opened only for short periods of time

+ Scenario conditions:

mValves open ,

mSmall break LOCA mDivision 1 single failure

+ Emergency Operating Procedures direct immediate operator action to ensure valves are closed Cp&L 29 i_ _m. _ _ _ _ _ _ _

6 i i Drywell to Torus Bypass

[ Issue Summary 1

eDepth of analyses performed was reasonable e Corrective actions were thorough and timely

e Long-standing industry design issue would have been identified during GE 10CFR21 evaluation eldentification by Nuclear Assessment Section assessments was unlikely g

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Corrective Action Effectiveness o Self-identifying and correcting our issues is a fundamental philosophy e Identification of issues at a low threshold continues to be emphasized

e Management is committed to performing thorough root cause analyses e Corrective action execution and effectiveness

continue to be improved e The corrective action program has contributed to improving performance

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L Summary l

eDrywell temperature

! + The earliest opportunity to identify the snubber qualified life concern was missed

+ The review of the effect of a drywell cooler failure did not meet standards

+ The issue was self-identified

! eDrywell to torus bypass

+ Reasonable and timely evaluations were

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conducted based on the information available

! CP&L 4

l Summary i

eBoth issues were of low safety significance .

l ewe are identifying and resolving our l

IsSUBS .

i + Over 2700 condition reports have been written this year l

+ Timeliness of evaluations and L investigations is improving

+ Average age of action items is declining

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PREDECISIONAL ENFORCEEKT CONFERENCE Ar/NDA BRUNSWICK NUCLEAR PLANT DECEMER 19, 1997. AT 10:00 A.N.

NRC REGION II 0FFICE, ATIMA GEORGIA

1. OPENING RENARKS AND INTRODUCTIONS L. Reyes, Regional h inistrator II. NRC ENFORCEENT POLICY A. BOUWO, Director Enforcement and Investigation Coordination Staff III. SUMARY OF THE ISSUES L. Reyes, Regional h inistrator IV. STATENENT OF CONCERNS / APPARENT VIOLATION L. P11sco, Deputy Director, Division of Reactor Projects V. LICENSEE PRESENTATION VI. BREAK / EC CAUCUS VII. NRC FOLLOWUP QUESTIONS VIII. CLOSING RENARKS L. Reyes, Regional h inistrator Enclosure 4

-ISSUES TO BE DISCUSSED-  :

j.'

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures _to assure that conditions adverse.to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances-are promptly identified and corrected.

Two. examples of failure to identify and correct conditions adverse to quality were ,

identified as follows:

First, the licensee failed to promptly identify and correct a high drywell temperature condition outside an engineering analysis limit of 221.7 *F, established for operation above the UFSAR limit of 200 F. On June 6. 1997, after the Unit 1,101 drywell cooling fan failed, temperatures increased above 221.7 'F. No action was taken for this condition until. September 19, 1997.

Engineering evaluations determined that seven out of ten snubbers on the reactor .

t.aad vent line were inoperable due to exceeding their seal life.

Second, cne licensee failed to promptly identify and correct a deficiency which had existed since 1974 where the pressure suppression design function of primary containment-could be bypassed under certain operating conditions.

NOTE: THE APPARENT VIOLATION DISCUSSED IN THIS PREDECISIONAL ENFORCEMENT CONFERENCE IS SUBJECT TO FURTHER REVIEW AND SUBJECT TO CHANGE PRIOR TO ANY RESULTING ENFORCEMENT ACTION.

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