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Insp Repts 50-324/87-30 & 50-325/87-30 on 870831-0904. Violations Noted.Major Areas Inspected:Ie Bulletin 83-07, Review of First 10 Yr Insp Interval Hydrostatic Testing Program & Review of Hydrostatic Test Procedures
	ML20235L744
Person / Time
Site:	Brunswick
Issue date:	09/25/1987
From:	Blake J, Coley J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20235L732	List: ML20235L729; ML20235L739; ML20235L744;
References
	50-324-87-30, 50-325-87-30, IEB-83-07, IEB-83-7, NUDOCS 8710050584
	Download: ML20235L744 (9)
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Report Nos.: 50-325/87-30 and 50-324/87-30

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Licensee: Carolina Power and Light Company

P. 0. Box'1551

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Raleigh, NC -27602

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

l. Facility Name: Brunswick 1 and 2

Inspection Coadt,ct d: August ~31 - September 4, 1987

Inspector: ew "

9/##/97

Date signed

. [ J. L. Cole

Approved,by: A em MIb -

had7

f- J. JT Bigfd, Section Chief'

Engineering Branch

Da'te Signed

Division of Reactor Safety

. SUMMARY

Scope: This routine, unannounced inspection was in the areas of inservice

inspection - review of 1st inspection iriterval (10 year) hydrostatic testing

program, review of hydrostatic test procedurcs, review of hydrostatic test

records, and IE Bulletin 83-07.

Results: Three violations were identified: (1) Failure to adequately complete

1st inspection interval hydrostatic testing required by Section 4.05 of the

Brunswick Technical Specification, (2) Failure to. issue nonconformance report

on licensee identified code discrepancy, and; (3) Inadequate hydrostatic test

, procedures.

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8710050584 870930 "

PDR ADOCK 05000324

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

P. W. Howe, Vice President, Brunswick Nuclear Plant (BNP)

C. R. Dietz, General Manager, BNP

K. E. Enzor, Director, Regulatory Compliance, BNP

S. H. Callis, On-site Licensing

L. E. Jones, Director, QA/QC

R. E. Helms, Director, On-site Nuclear Safety

L. W. Wheatly. Inservice Inspection (ISI), Project Engineer

Other licensee employees contacted included construction, engineers, and

office personnel.

Other Organization

B. Stanley, ISI Hydrostatic Test Engineer, Cataract Inc.

NRC Resident Inspectors

W. H. Ruland, Senior Resident Inspector l

L. W. Garner, Resident Inspector f

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Attended exit interview

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2. Exit Interview

The inspection scope and findings were summarized on September 4, 1987, !

with those persons indicated in paragraph 1 above. The inspector i

described the areas inspected and discussed in detail the inspection

findings. No dissenting comments were received from the licensee. The

following new items were identified during this inspection:

(0 pen) Violation 50-324/87-30-01, Failure to Adequately Complete 1st

Inspection Interval Hydrostatic Testing as Required by Section 4.0.5

of the Brunswick Technical Specification: The licensee committed to

provide justification for continued operation on this reported

finding, paragraph 5.b.1.

(0 pen) Violation 50-324/87-30-02, Failure to Issue Nonconformance l

Report on Licensee Identified Code Discrepancy. (This is a repeat '

i violation): The licensee committed to perform a complete audit of

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the Unit 2 hydrostatic test procedures, paragraph 5.b.2.

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.(0 pen)' Violation 5-324/87-30-03 and' 50-325/87-30-01, Inadequate

Hydrostatic . Test Proceduresi The licensee committed to conduct a

complete _ review of the difference noted.in system requirements of.the

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design' base documents applicable when the l reactor. building closed

cooling water was hydrostatic listed in 1984 and the present design

base document. In addition, .the licensee will evaluate .these

differences and their effect on other materials, components and

systems, paragraph 5.b'.3.

The. licensee did not identify as proprietary any of the materials provided

to orL reviewed by .the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

This subject was not~ addressed in the inspection.

.4. Unresolved Items

Unresolved items were not discussed during this inspection.

5. ISI 1st Inspection ' Interval Hydrostatic Test Program - Unit 2 (73051,

73052, and 73755)-

The ' Carolina Power and Light (CP&L) Company ISI program for Brunswick

Units.1 and' 2 is conducted in accordance with the requirements of.

Section 4.0.5.a.2 of the Technical Specifications, which in turn invokes

the' requirements 10 CFR 50.55a(g). 10 CFR 50.55a(g) requires that piping

and components of boiling and pressurized water reactor plants be examined

and pressure tested to the requirements of.Section XI of the ASME Code and

that the examinations and tests be completed during each of four ten year

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intervals. These ten year intervals are calculated from the start date of

commercial operation of the facility.

By letter dated May 20 1985, CP&L requested approval from NRC to begin the

second inspection interval for each unit on a common date. This would

allow the licensee to use the same code edition and addenda as the basis

for the ; inservice inspection program for both units and since the' units

are similar in design, only one ISI program would have to be written. The

date would correspond to the date midway between the first interval-

expiration dates for the two units. July 10, 1986 was chosen as the

common date - based on the first interval expiration dates of March 17,

.1987, and November 2, 1985, for Units 1 and 2, respectively. First

interval inspections for both units were to be completed within the time

specified by the ASME Code.

By letter dated July 1,1985, NRC approved CP&L's request for a common 2nd

interval start date for both units.

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As1 described above,, Unit 2 has ' presently ' exceeded the first interval-

expiration date and..the' extension period allowed by paragraph IWA-2400(C)

Jof Section XI of the ASME Code. Therefore,'the inspector selected the

Unit 2 hydrostatic. test program to review for adequacy and completion.

TheLapplicable ASME code for the review was the 1977 edition with addendum

r through summer 1978.

a. . Review of Program

The licensee's' program for hydrostatic testing .is conducted in

accordance with Section VII of the Brunswick Steam Electric Plant ,

' Engineering Procedure ENP-16. This procedure delineates the program i

and ' specifies the type of test, frequency and ' test procedure !

applicable to.the system or portions of a. system that will be tested. 1

The actual testing is performed and documented in accordance with a

Periodic Test (PT) procedure or Plant Modification (PM) instruction.

The inspector reviewed t' he ISI program for hydrostatic testing to

determine: if the program was in conformance with the ASME Code

(77S78)'and code. cases proposed for use as part of the 10 year plan;

to verify that relief from code requirements had been approved by

NRR; the services of an authorized Nuclear Inservice Inspector (ANII)

had been procured . and; the ISI plan had been reviewed by the

licensee's ' site nuclear safety review committee or equivalent and,

approval had been documented.

The inspector- also reviewed the program for identification of all

licensee commitments and regulatory requirements pertinent to ISI

testing and to ensure site administrative procedures were in place to

define the authority and responsibilities of the persons or

organizations involved with the final evaluation and acceptance of

ISI results for the licensee.

b. Review of Procedures, and Completed Hydrostatic Test Records

As stated in 5.a. above, hydrostatic testing for each system or

portion of a system was performed in accordance with a specific PT or

PM. In order to determine completion of the program as delineated in

ENP-16, the inspector reviewed the following completed Unit 2,

Class 3 piping, hydrostatic test records, associated with the PT's

or PM's listed below:

(1) PT-24.3.1, Service Water System (Nuclear Header, Nuclear Pumps A ;

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& B Discharge Piping Lubricating Water Pump Supply Piping /

Jacket Water Cooler 1, 2, 3, and 4 Suction) and PM-SK-85-063 j

M-013 Rev. A, from Blind Flange at Valve 2-SW-V97 through Spool

PC and Valve 2-SW-V200, V201 to Blind Flange

(2) PT-24.3.2C, Service Water (Diesel No. 3 Jacket Supply)

(3) PT-24.3.2D, Service Water (Diesel No. 4 Jacket Supply)

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(4) PT-24.3.3, Service Water (Conventional Header, Conventional

Pumps A, B and C Discharge Piping)

(5) PT-24.3.4, Service Water (A Vital Header Hydrostatic Test) ,

(6) PT-24.3.5, Service Water (Surveillance Test Completion /

Exception),.PM-82-218Y and 82-218Z

(7) .PT-24.3.6, . Service Water System, PM-83-148, PM-82-2181 and

82-218J; Test covers RHR service Water Booster Pumps 2A and. 2C

Discharge Piping Hydrostatic Test.

(8) PT-24.3.7, Service Water System, PM 83-090, PM 82-2180 and PM

83-149; Test covers RHR Service Water Booster Pumps 2B and 20

Discharge Piping Hydrostatic Test

(9) PT-24.3.8, RHR Service Water Pumps A and C Suction Piping

Hydrostatic Test

(10) PT-24.3.9, RHR Service Water Pumps B & D Suction Piping

Hydrostatic Test

(11) PT-24.6.1, Fuel Pool Cooling and' Filtering Hydro

(12) PT-09.2.2, High. Pressure Coolant Injection Hydro

The above review represented 100% of the hydrostatic tests

required for class 3 piping systems on Unit 2. In addition, to

the inspector's review of class 3 systems on Unit 2 the

following class 2 system hydrostatic test was reviewed for

units 1 and 2:

(13) PT 22.2.2, Reactor Building Closed Cooling Water

During the inspectors review of the above documentation, the

following tests findings were identified:

(a) (Items 1 and 2 above) PT-24.3.2.C, Service Water (Diesel

No. 3 Jacket Supply) and PT-24.3.20, Service Water (Diesel l

No. 4 Jacket Supply).

Finding: In-line check valves 274 and 275 for the

respective test procedures above, would have limited the

scope of the hydrostatic test covered by the procedure.

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In order to perform the hydros as delineated in the pts the

two check valves would have to be turned around in the

system. The test procedures did not provide instructions

for system re-alignment. Therefore, one spool in each

test would not have been hydroed. A review of all

documentation associated with the above tests failed to

indicate that the check valves were aligned for the test.

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i? (b)- (Item ' 7) PT-24.3.6, Service Water System, includes PMs 83-148,.82-2181 and 82-218J; Test covers RHR Service Water

Booster. Pumps .2A 'and 2C . Discharge : piping hydrostatic

test.

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< Fin' d'i ng: Records do not. indicate that the spool pieces

(pcs) from the.RHR Service Water Booster Pumps 2A and 2C.to

check valves'F005A and C, respectively,had been hy'drostatic

tested.

(c) (Item 8) PT-24.3.7 Service Water ' System, includes PMs 83-090, 82-218Q and 83-149;. Test Covers RHR Service Water

Booster Pumps 2B and 2D Discharge Piping Hydrostatic test

Findings: (1) Records do not indicate that the spool . pcs

from the RHR Service Water Booster Pumps-2B

and 2D to . check valves F005B and D,

respectively, had been hydrostatic tested.

(2) PM 83-090, Class 3 test boundary butterfly

valve F073, was not listed on the valve

lineup sheet. ~The Class 3 portion of the

RHR Service Water System that was required

to be tested is a l salt water system.

However, under hydrostatic pressure test

conditions salt water from the service water

system could enter the reactor coolant side

of the RHR system .if valves F073 and F075

were not aligned. properly for the test.

Valve position during the hydrostatic test

could not be determined by test records.

(d) (Item 13) PT-22.2.2, Reactor Building Closed Cooling Water

(RBCCW), Class 2 piping, Units 1 and 2 i

Finding: The inspector's review of this test procedure

revealed that portions of the test procedure's instructions

and sign-off verifications were missing. Included in the

missing documentation for a hydrostatic test was the system

valve alignment sheet for the test. From the documentation

available the inspector concluded that a functional type

test had been performed at operating pressure in lieu of

the code required hydrostatic test pressure. Due to the

inconsistency noted, the inspector reviewed the design base

document for the system and found that the system operating

pressure of 70 psig was the pressure used by the test

personnel for the hydrostatic test. The licensee was

questioned concerning this discrepancy and the inspector !

was subsequently provided with the design specification

that was applicable during the time period when the

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hydrostatic test was, per' formed. This document listed the

normal operating < pressure. as 50 psig and was obviously

incorrect because ' the inspector hadi noted . in. the design

base that the 3rd RBCCW pump ldid not operate until the

system. reached 65 psig.

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As. a result .of the above findings, the licensee -was :

notified that the following violations would be reported as

-described.below:

1) Items (a), (b), (c) and (d) -are examples of the 1

licensee's fai_ lure to adequately complete .the 1st

inspection interval-hydrostatic testing as required by

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the Brunswick Technical . Specification, paragraph-

4.0.5.a.2. This item was reported as violation

50-324/87-30-01, and the licensee ' was requested to'-

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provide justification for continued operation (JCO).

l The JC0 was completed on September 5, 1987, and

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approved by the Plant Nuclear Safety Committee on the

same day.

2) Items (b) and (c.1) dealt with the licensee's failure

i to hydrostatically test a spool pc on each of the four

RHR Service Water pumps on Unit 2. However, in-

additi.on to the missed hydrostatic test, the inspector

ascertained that the licensee had discovered the

discrepancy in January 1987, and 'had factored the

missed tests into the first outage of the 2nd interval

without writing a nonconformance report on the item.

Failure to write a nonconformance report meant that

management did not review the safety implications of

the missed tests ~ and that the extent of the

discrepancy was not determined for other systems. The

licensee's Director of Regulatory Compliance was

questioned concerning what level would have been

assigned the nonconformance had it been written. The

licensee confirmed that the 'nonconformance would have

been designated as a significant nonconformance which

would have required ' the licensee to conduct a review-

of other systems for completeness.

As reported in 1 above, other systems were found by

the inspector to be incomplete. The licensee

committed to perform- a complete review of the

hyrostatic' test program to determine the full extent

of incomplete testing for Unit 2.

Failure to issue a nonconformance report on

significant findings is a repeat violation. The

inspector reported a similar violation in NRC

Inspection Reports 50-324/86-10 and 50-325/86-09,

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dated April 29, 1986, when the licensee failed to )

write a nonconformance report on their failure to meet j

ASME, Section XI, period requirements for the I

examination of Class 2 components. In addition to the-

inspector's items, the resident inspectors have also 3

identified a similar violation in NRC Inspection )

Report Nos. 50-325/86-15 and 50-324/86-16 dated

July 15, 1986.

The licensee was informed that failure to issue a

nonconformance on licensee identified items

significant to safety was in violation of NRC

requirements and would be reported as item

50-324/87-30-02.

3) Items (a) (C.2) and (d) above identified inadequate

test procedures / instructions. In' addition to the

inadequacies found in the hydrostatic test

procedures / instructions, the inspector also found

errors in the design base documents for the applicable

piping systems. The licensee committed to review the

differences in design base criteria to determine what

other materials, components and systems may be

affected by the difference noted in the design base-

documents. The procedure discrepancies noted in these

items were identified to the licensee as Violation

50-324/87-30-03 and 50-325/87-30-01.

Within the areas examined, no violations or deviations were identified'by

the inspector except as noted by 5.b.1), 5.b.2) and 5.b.3) above.

6. IE Bulletins (IEB) - Unit 1 and 2 (92703)

(Closed) IE Bulletin 83-07, Apparently Fraudulent Products Sold by Ray

Miller, Inc.

Power reactor facilities were informed in January 1983 by Information

Notice 83-01 that fraudulent products may have been sold to nuclear

industry companies by Ray Miller, Inc. An updated and comprehensive list

of Ray Miller, Inc. customers for the years 1975-1979 was provided to

power reactor licensees and to selected fuel cycle and Category B,

Priority I material licensees in Supplement 1 to IN 83-01 that was issued

on April- 15', 1983. Information became available regarding specific

purchase orders for which materials were apparently substituted, licensees

were requested to determine where suspect material had been installed in

plants, evaluate its safety significance, and tag or dispose of the

suspect material'not installed.

The specific information on apparently fraudulent material covered a five

year period and pertained to orders filled by the Charleston office only.

Although the Charleston office was apparently the major offender, the

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other Ray Miller, .Inc. branch offices may have also supplied fraudulent

materials. .in some' cases. However, .the NRC was.' unable .to locate any

' records for review from these other branch offices. In an effort-to aid

in ' determining the' scope of the fraudulent materials problem,. licensees

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were requested toS examine and test materials from other Ray Miller, Inc.

branch offices that they have been able to identify,'but were not included

.in the NRC-identified list of, apparently fraudulent materials.

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CP&L'siletters of response to IEB-83-07 dated-March'23, 1984,. June 1, 1984

and November 9, 1985, were reviewed by the inspector. In addition,'other

CP&L and vendor correspondence dealing with 'this . issue were . reviewed.

CP&L'~ concluded that they had not received any fraudulent ' materials from

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Ray Miller, Inc. The inspector's sample review of Brown and Root purchase

orders;for the years - 1975-1979 also did not identify any_ fraudulent

materials from Ray. Miller, 'Inc The lice'nsee's actions with regards to i

this Bulletin is satisfactory and this matter is' considered closed.

Within the area examined, no violation or deviation was identified.

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ML20235L744

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