ML20235L744
| 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: |
| References | |
| 50-324-87-30, 50-325-87-30, IEB-83-07, IEB-83-7, NUDOCS 8710050584 | |
| Download: ML20235L744 (9) | |
See also: IR 05000324/1987030
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UNITED STAT ES '
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NUCLEAR REGbLATORY COMMISSION
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101 MARIETTA STREET,N.W.
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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.:
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Facility Name:
Brunswick 1 and 2
Inspection Coadt,ct d: August ~31 - September 4, 1987
9/##/97
Inspector:
ew
. [ J. L. Cole
Date signed
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Approved,by: A em
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J. JT Bigfd, Section Chief'
Da'te Signed
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Engineering Branch
Division of Reactor Safety
SUMMARY
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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 "
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
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- L. W. Garner, Resident Inspector
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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,
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with those persons indicated in paragraph 1 above.
The inspector
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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
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Report on Licensee Identified Code Discrepancy.
(This is a repeat
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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
intervals. These ten year intervals are calculated from the start date of
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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-
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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
through summer 1978.
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a.
. Review of Program
The licensee's' program for hydrostatic testing .is conducted in
accordance with Section VII of the Brunswick Steam Electric Plant
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' Engineering Procedure ENP-16. This procedure delineates the program
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and ' specifies the type of test, frequency and ' test procedure
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applicable to.the system or portions of a. system that will be tested.
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- 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
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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)
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(6)
PT-24.3.5,
(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
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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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(b)- (Item ' 7) PT-24.3.6, Service Water System, includes PMs83-148,.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
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(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 PMs83-090, 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
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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
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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
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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
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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-
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4.0.5.a.2.
This item was reported as violation
50-324/87-30-01, and the licensee ' was requested to'-
provide justification for continued operation (JCO).
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The JC0 was completed on September 5,
1987, and
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approved by the Plant Nuclear Safety Committee on the
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same day.
2)
Items (b) and (c.1) dealt with the licensee's failure
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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
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write a nonconformance report on their failure to meet
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ASME,
Section XI,
period
requirements
for
the
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examination of Class 2 components.
In addition to the-
inspector's items, the resident inspectors have also
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identified a similar violation in NRC Inspection
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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
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.
CP&L'siletters of response to IEB-83-07 dated-March'23, 1984,. June 1, 1984
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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
Ray Miller, Inc. The inspector's sample review of Brown and Root purchase
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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
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this Bulletin is satisfactory and this matter is' considered closed.
Within the area examined, no violation or deviation was identified.
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