View source for BSEP-92-0008, Responds to Violations Noted in Insp Repts 50-317/92-19 & 50-318/92-19 on 920605-0703.Corrective Actions:Evaluation Written to Justify Temporary Repair & Operability of Svc Water/Tube Water Line & Permanent Repair Installed

{{Adams
| number = ML20099K195
| issue date = 08/21/1992
| title = Responds to Violations Noted in Insp Repts 50-317/92-19 & 50-318/92-19 on 920605-0703.Corrective Actions:Evaluation Written to Justify Temporary Repair & Operability of Svc Water/Tube Water Line & Permanent Repair Installed
| author name = Spencer J
| author affiliation = CAROLINA POWER &amp; LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000324, 05000325
| license number = 
| contact person = 
| document report number = BSEP-92-0008, BSEP-92-8, NUDOCS 9208250202
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 3
}}

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                                                                        $A Carolina Power & Light Company sw=nemum awxuruswca Drunswick Nuclear Project P. O. Box 10429 Southpctt, NC 28461-0429 AUG 211992 File: D0913is100                                                                                  10CFR 2.201 Serial: BSEP 92-0008 Unitod States Nuclear Pogulatory Commission ATTENTION: Document Control Desk Washington DC 20555 DRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50 325 & 50-324/ LICENSE NOS. DPR 71 & DPR42 REPLY TO NOTICE OF VIOLATION 921941 Gontlemon:
The Brunswick Stoam Electric Plant has receivod NRC Inspection Report 50-325/92-19 and 50-324/9219 and finds that it doos not contain information of a proprietary nature. This report included Notico of Violation 921941.
Enclosed is Carolina Power & Light Company's response to that Notico of Violation.
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                                                                                          . Spencer, GenAravManager p-Bru swick Nuclear Project JWS/npt Enclosure cc:     Mr. S. D, Ebneter Mr. R. H. Lo BSEP NRC Resident Office 9200250202 920021                                                                                                (74 PDR      ADOCK 05000324                                                                                            -
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ENCLOSURE BRUNSWICK STEAM ELECTRIC Pl. ANT, UNITS 1 AND 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING UCENSE NC3. DPR 71 & DPR42 REPLY TO NOTICE OF VIOL.ATION 921941 VIOLATIOR During an NRC inspection conducted on June 5 July 3.1992, a violation of NRC requirements was identified, in accordance with the 'Goneral Statament of Policy and Procedure for NRC Enforcement Action.* 10 CFR Part 2, Appendix C, (1992), the Violation is listed below:
10 CFR 50 Appendlx B, Criterion V requires that actMiles affecting quality shall be accomplished in accordanco with documented proccdures.
Engincoring Proceduro ENP-12, Engineering Evaluation Procedure, Revision 029 Section 2.2.1, requires that an Engineering Evaluation Report (EER) be prepared to evaluato and approve all temporary repairs to power plant systems or equipment. Section 4 9 of ENP 12 defines a temporary repair as a temporary change associated with correctL'o maintenance.
Contrary to the above, on Janaary 24,1992 a temporary non-codo repair was mado to a Servico Water Lubo Water (SWLW) line without obtaining a relief request via an Engineering Evaluation in accordanco with plant procodures.
RESPONSE TO VIOLATION:
Adminlon or Denial of Vio ation:
Carolina Power & Ught Company admits to this violation.
Reason for the Violation On 1/24/92 a through wall pin-hole leak was discoveied on line 1-SW-233-3/417A. This is the lubo water supply lino to the 18 Nucleu Servico Water Pump and is an ASME Class ill moderate enor(,y line. Several days prior to the discovery of the leak, the lube water supply cyclone r,eparator had failed with leakago occurring. In order to expedito replacement, a portaband was used to cut the bolts off the cyclono separator and pipe flange. The portaband slipped and nicked the 3/4" pipe near the flange, subsoquently causing the through wall leak to appear several days later. Work Request / Job Order (WR/JO) 92-ABSK1 was written (by Operations) to repair the leak, it was decidod by Maintenance personnel to expedtte a permanent code repair to the pipe. Toch Support and Operations were aware of this plan. Work was initiated immediately to fabricate a replacement flange and nipple. While the fabrication was being dono it was decided to place a ' spray de'' actor" on the pipe to mitigate the effects of the loak. MMM.003, Corrective Maintenance Procedure, Section 4.9.3 addresses the insta!!ation of spray deflectors which may be used No slow the flow of water or to prevent water spray damago." 11 further states, 'The spray deflector is nR1 considered to be a temparary repair in this context
* A rubber patch with a hose clamp is given as an example of a spray

doflector. Bocause the permanent repair was being pursutd expeditiously, no tracking LCO was placed on the pipe loak. 01-4 (LCO Evaluation and Follow up) requires a tracking LCO be initiated if onerability is unclear. In this instanco no LCO was inhiatod.
The flango and nipple were fabricated and Maintenanco requestod, through the She Work Force Control Group (SWFCG), a v..ndow to perform the repair. Because lubo water would nood to be isolated to make the repair, a clearance would be requirod on the pump. Since the patch was not identiflod as a temporary repair and no tracking LCO existod, it was not recognized by Scheduling that tho work was essential to fulfill code requirements. Thorofore other Service Water work was given greator priority, no window was made available and the pormanont repair was deferrod. Also, due to an administrativo error, the WR/JO was incorrectly classified as *Flold Completo* In AMMS. (This has subsequently boon correctod). Apparently while updating the database, a transposition of numbers occurrod. Based on the volume of WR/JOs processed this is not considored significant. Since a tracking LCO was not generated EngIncoring was not contacted for an evaluation.
During an ISI inspection on 0/18/92, the patch was identified. A tracking LCO was placod on the pump (TI 924001) and operability of the pump was addressed by EER 91-199 The pump was dolormlned to be operable with the spray deflector in placo.
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Summary and Conclusions The spray deflector placed on the pipo by Maintenance was allowed by and in accordance with MMM403. Because an expeditious permanent repair was being pursued and no tracking LCO establishod,' Engineering was not contacted to perform an evaluation. When the permanent repair was deferrod, no mechanism was in place to require evaluation of the leak and patch.
The violation occurred for the following reasons:
: 1.                There was a rollanco on personnel rather than process to implemont and track a required code repair.
: 2.                 014 d!d not automatically require the initlation of a tracking LCO.
                           - Correctivo Steos Which Havo Been Taken and Results Achieved
: 1.                An evaluation was writton (EER 924199) providing justification for the temporary topair and demonstrating operability of the lino.
j                                      2.                 01-4 has boon revised, requiring an LCO for a through wall leak within the ISI boundary.
!                           Conectivo Actions That Will Bo Taken to Avoid Further Violation l
l                                      1.                 Implomont a permanent code repair to line 1-SW 233-3/417A (WR/JO 92 ABSK1) prior to Unit I restart.
Dato When Fut! Comofiance Will Be Achieved:
Following completion of WR/JO 92 ABSK1, prior to Unit 1 restart.
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