View source for BSEP-88-0006, Responds to Violations Noted in Insp Repts 50-324/87-39 & 50-325/87-38.Corrective Actions:Periodic Test Procedure 08.2.2b Revised & Approved & Appropriate Plant Administrative Procedure Will Be Implemented

{{Adams
| number = ML20195H632
| issue date = 01/08/1988
| title = Responds to Violations Noted in Insp Repts 50-324/87-39 & 50-325/87-38.Corrective Actions:Periodic Test Procedure 08.2.2b Revised & Approved & Appropriate Plant Administrative Procedure Will Be Implemented
| author name = Dietz C
| author affiliation = CAROLINA POWER &amp; LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000324, 05000325
| license number = 
| contact person = 
| document report number = BSEP-88-0006, BSEP-88-6, NUDOCS 8801200285
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

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Carolina Power & Light Company Brunswick Steam Electric Plant P. O. Box 10429                               .
Southport. SC 28 'e 61 -0429 January 8, 1988 i
FILE: B09-135'0C                                                       10CTR2.201                            l SERIAL: BSEP/88-0006 i
NRC Document Control Desk                                                                                    j U.S. Nuclear Regulatory Commission                                                                           l Washington, DC 20555                                                                                         l BRUNSWICK STEAM ELECTRIC PLAST UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO INTRACTIONS OF NRC REQUIREMENTS Gentlemen:
The Brunr. wick Steam Electric Plant (BSEP) has received I&E Inspection Report 50-325/87-38 and 50-324/87-39 and finds that it does not contain information of a proprietary nature.
This report identified one item that appeared to be in noncompliance with NRC requirements. Enclosed ple.ase find Carolina Power & Light Company's response to that violation.
Very truly yours,                                             !
dtG C. R. Dietz, General Manager Brunswick Steam Electric Plant MJP/ah Enclosure cc:   Dr. J. N. Grace 1
Mr. E. D. Sylvester
!.                BSEP NRC Resident Office l
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I l                  8801200205 800100                                                                                    I PDR    ADOCK 05000324                                                                                !
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VIOLATION Technical Specification 4.0,5.a.2 requires that in-service testing of ASME Code Class 1, 2, and 3 pumps shall be performed in accordance with Section XI of th; ASK3 Boiler and Prsssure Vessel Code and applicable Addenda as required by           '
10CFR50, Section 5].55a(g), except where specific written relief has been
     ~ granted by the Cemmission pursuant to 10CFR50, Section 50.55a(g) (6) (1).
The Sectica XI Addenda applicable to the facility require that the gauge. for the pump tests have ranges that are three times the reference measureme.t values er less.
Contrary to the above, at least until August 1987, the licensee performed specified pump tests with gauges that did not conform to the Section XI range requirements. For example, the discharge pressure gauges used in a August 7, 1987, tent of Residual Heat Removal System pumps had gauges with ranges over 4-1/2 times the reference values.      The licensee did not request relief from the Commission relative to the requirement or even prepare a written justification for such a request. The licensee identified the gauge range deficiency in 2:tcoer 1985.
This is a Severity Level IV violation (Supplement I).

===RESPONSE===
I. Admission or Denial of the Alleged Violation Carolina Power & Light Company acknowledges the violation occurred as sta+    .
II. Reason for the Violation The pump testing program at Brunswick was originally intended to use installed plant instrumentation where possible to minimize cost and the setup effort required to obtain the necessary data. While the installed instrumentation met code range requirements in most instances, exceptions existed that went undetected as a result of inadequate attention to detail during initial procedure preparation. These exceptions were identified by CP&L in June 1986 with the completion of a full review of ISI pump testing instrumentation which resulted from the Quality Assurance concerns documented in Quality Assurance Surveillance Report (QASR) 85-068 of October 7, 1985.
A relief request was not prepared because it was CP&L's intention to install test gaugns and therefore comply with the code requircraents. The procedure revisions necessary to achieve compliance for pressure gange range and accuracy were completed in November 1987.

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b CP&L did'not recognize that use of gauges with ranges in excess of code requirements constittded.a situation warranting a relief request, particularly _since the intent at the time was .to proceed with installation of code compliant gauges. CP&L did not consider that the installed gauge ranges would adversely affect the test results;
                                         ~
               .therefore, resolution of the test instrumentation issue hva pursued as a routine rather than priority manner. CP&L shares the inspe. tor's          !
concerns for timely action.       Increased sensitivity to timelf relief request submiss'ons together with additianal programmatic improvements planned (see Section IV below) will effectively preclude recurrence of
              .the problem.
        .III. The Corrective Stips Which Have Been Taken and the Results Achieved Periodic test procedure 08.2.2b (LPCI/RHR System Operability Test      -
Loop B) was revised and approved on November 24, 1987. This revision implemenced the use of pressure gauges that are within the accuracy and ranges of the Code. As this was the last identified deficiency, Brunswick pump test instrumentation is now in Code compliance.
IV. The Corrective Steps Which Will be Taken to Avoid Further Violations and Date for Full Compliance An appropriate plant administrative procedure will be implemented to provide specific guidelines as to corr ctive actions to be taken when ISI i
inspection / testing deficiencies are discovered. This procedure will require documentation of the deficiency and evaluation as to corrective action required. In addition, this procedure will provide for tracking and periodic reviews of outstanding deficiencies. Through use of this procedure, ap, topriate management atter. tion can be applied to the correction of long-term items. Guidance will also be provided ' sed upon the current NRC position on when relief requests are appropriate. This procedure will be completed by March 31, 1988.
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