View source for BSEP-99-0050, Informs NRC That Certain Category C,D & E Piping Welds in Units 1 & 2 Have Not Been Inspected in Accordance with Frequencies Provided by NRC GL 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping,

{{Adams
| number = ML20205K857
| issue date = 04/06/1999
| title = Informs NRC That Certain Category C,D & E Piping Welds in Units 1 & 2 Have Not Been Inspected in Accordance with Frequencies Provided by NRC GL 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping,
| author name = Jury K
| 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 = 
| case reference number = RTR-NUREG-0313, RTR-NUREG-313
| document report number = BSEP-99-0050, BSEP-99-50, GL-88-01, GL-88-1, NUDOCS 9904140034
| title reference date = 01-25-1988
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 4
}}

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4 CP&L Carolina Power & Ught Company P.o. Box 10429 Southport, NC 28461-o429 APR 0 61999 SERIAL BSEP99-0050 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 NOTIFICATION OF MISSED AUGMENTED INSPECTIONS OF WELDS SUSCEPTIBLE TO                                        l INTERGRANULAR STRESS CORROSION CRACKING                                                                     l Gentlemen:
This purpose of this letter is to inform the NRC that certain Categcry C, D, and E piping welds in the Brunswick Steam Electric Plant (BSEP), Unit Nos. I and 2, have not been inspected in accordance with the frequencies provided by NRC Generic Letter 88-01, "NRC Position On IGSCC In BWR Austenitic Stainless Steel Piping," dated January 25,1988, and its associated technical basis, NUREG-0313, Revision 2, " Technical Report On Material Selection and Processing Guidelines For BWR Coolant Pressure Boundary Piping." The circumstances associated with these missed inspections are summarized below, and are more fully described in
       ' the enclosed BSEP Licensee Event Report (LER) 1-1999-001-0, which was previously submitted to the NRC byletter dated Febmary 19.1999 (Serial: BSEP 99-0022).
In response to NRC Generic Letter 88-01, Carolina Power & Light (CP&L) Company committed to inspect piping welds containing austenitic stainless steel that are susceptible to intergranular stress corrosion cracking (IGSCC). Generic Letter 88-01 adopted the guidance contained in NUREG-0313 Revision 2. NUREG-0313 defines seven categories of welds, A through G, based on their degree of susceptibility to IGSCC. Inspection frequencies are established for each lj    ,
j
                                                                                                                ,f
                                                                                                                   / '
category of weld. Category C welds are comprised of IGSCC non-resistant materials that have undergone stress improvement (SI) after two years of operation.: Category C welds require inspection within two refueling cycles following SI, after which they must be inspected every
        - 10 years._ Category D welds are comprised of nonresistant materials that have not undergone SI.
Category D welds require inspection every two refueling cycles. Category E welds have               ,0  ! {
identified cracks which were either reinforced by weld overlay or were mitigated by St.                     )
Category E welds require an initial inspection, after which they must be inspected every two refueling cycles. These inspection requirements were incorporated as augmented inspections in the Inservice Inspection Program for BSEP, Units 1 and 2.
9904140034 990406 ~
PDR     ADOCK 05000324 P                      PDR gg                                                                           ;
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l Document Control Desk BSEP 99-0050 / Page 2                                                                              f In 1997, a revised inspection schedule was implemented to perform the weld inspections on a single recirculation loop in each refueling outage rather than inspections on bc,th recirculation loops in each outage. This change was made to optimize setup and demobilization activities, dose, and manpower expenditures. The missed weld inspections occurred during the transition to the revised examination schedule. Until the transition period, the augmented weld inspections were performed at the appropriate frequency.
l l
Upon discovery of the missed weld inspections, evaluations were performed which demonstrated that the structural integrity of the affected systems was not adversely impacted by the missed weld inspections. One BSEP, Unit 2 Category D weld was inspected on January 23,1999; the weld was found acceptable with no recordabic indications. The remaining missed inspections will be completed during each unit's next refueling outage (i.e., B214R1 for BSEP, Unit 2,         j scheduled to begin April 1999, and B113R1 for BSEP, Unit 1, scheduled to begin in February 2000).
1 On May 1,1997 (Scrial: BSEP 97-0104), CP&L requested NRC conemTence with a plan to                 !
discontinue the augmented weld inspections for certain Category E welds and resume the             I inspection frequency of the ASME Code, Section XI. However, based on the discovery of the missed weld inspections, as well as an ongoing Boiling Water Reactor Owners' Group initiative      1 l
to revise the weld inspection frequencies, CP&L is withdrawing its May 1,1997, request.
There are no regulatory commitments being made in this submittai. Please refer any questions       j regarding this submittal to Mr. Warren J. Dorman, Supervisor - Licensing, at (910) 457-2068.
l Sincerely,                                       I
                                                              '            ~
Keith R. Jury Manager - Regulatory Affairs                     l Brunswick Steam Electric Plant WRM/wnn

==Enclosure:==
Licensee Event Report 1-1999-001-0 I
i

4 i
Document Control Desk BSEP 99-0050 / Page 3                                                         1 cc:     U. S. Nuclear Regulate y Commission, Regien 11 ATTN: Mr. Luis A. Reyes, Regional Administrator Atlanta Federal Center                                                   ,
               . 61 Forsph Street, SW, Suite '23T85
                                                                                       -l Atlanta,GA 30303                                                       !
U. S. Nuclear Regulatory Commission
                 . ATTN: Mr. Theodore A. Eastick, NRC Senior Resident Inspector 8470 River Road
               . Southport, NC 28461-8869 l
U. S. Nuclear Regulatory Commission                                    i A'ITN: Mr. Allen G. Hansen (_ Mail Stop OWFN 13E2'l) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission F.O. Box 29510 Raleigh, NC . 27626-0510 Division of Boiler and Pressure Vessel North Carolina Department ofI2bor ATTN: Mr. Jack Given, Assistant Director of Boiler & Pressure Vessels
               ' 4 West Edenton Street Raleigh, NC 27601-1092 l
l l
I I

d
        .     .                         ENCLOSURE
                                                                                )
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 NOTIFICATION OF MISSED AUGMENTED INSPECTIONS OF WELDS SUSCEPTIBLE TO INTERGRANULAR STRESS CORROSION CRACKING i
i LICENSEE EVENT REPORT l-1999-001-0 l
l I

CP&L Carolina Power & Ught Company P.o. Box 10429 Southport, NC 28461-0429 February 19,1999 10 CFR 50.73 SERIAL: BSEP 99-0022 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. I DOCKET NO. 50-325/ LICENSE NO. DPR-71 LICENSEE EVENT REPORT l-1999-001-00 Gentlemen:
In accordance with the Code of Federal Regulations, Title 10, Part 50.73, Carolina Power &
Light (CP&L) Company submits the enclosed Licensee Event Report. This report fulfills the requirement for a written report within thirty (30) days of the discovery of a reportable occurrence.
Please refer any questions regarding this submittal to Mr. Keith R. Jury, Manager - Regulatory Affairs, at (910) 457-2783.
Sincerely, J r > . Lyash la it General Manager Bmnswick Steam Electric Plant MAT / mat i

==Enclosure:==
Licensee Event Report g 3, g ,7 1
                          -   g g 4 7-4/ 'h'

  ,~   , . .
Document Control Desk BSEP 99-0022 / Page 2 cc (with enclosure):
U. S. Nuclear Regulatory Commission, Region 11 ATTN: Mr. Luis A. Reyes, Regional Administrator Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-3415 U. S. Nuclear Regulatory Commission A1TN: Mr. Theodore A. Easlick, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Mr. David C. Trimble, Jr. (Mail Stop OWFN 14H22) 11555 Rockville Pike l                 Rockville, MD 20852-2738 l                 Ms. Jo A. Sanford l                 Chair - North Carolina Utilities Commission P.O. Box 29510 i
Raleigh, NC 27626-0510 l
l i

NRC FORM 366          U.S. NUCLEAR REGULATORY COMMISSION (6 1998)                                                                                                                                   APPROVED BY OMB NO. 3150-0104 EXPlRES 06/30/2001 E stimated burden per response to comply with this mandatory entormation collection request: 50 hrs. Reported lessons learned a*e LICENSEE EVENT REPORT (LER)                                                                                                                '=,'l'*d c           ,,                                    ,
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digits /characte'rs for each bioch                                                                                                          0*c' a' M*"*0*"ient and Budget, washington. oc 20503. it an information collection does not desplay a currently vahd OMB control number. the NRC may not conduct or sponsor, and a person is not requered to respond to, the enformation collection F ACluTY NAMt (1)
'                                                                                                                                             DOCKET NUM8ER (2)                              PAGE (3)
Brunswick Steam Electric Plant (BSEP), Unit No.1                                                                                                   05000325                                              OF 1                 7 i  TITLE tel                                                                                                                                                                               l Missed Augmented Inservice Weld Inspections EVENT DATE -(5)                  LER NUMBER (G)                                                   REPORT DATE (7)
MONTH      DAY     YEAR       YEAR OTHER FACILITIES INVOLVED (81 SEQUENHAL            RE VISION                     MONTH                      DAY          YEAR         F ACIUTV NAME                          DOCKE1 NUMBER NUMBER         NUMBER RSEP, Unit No. 2                            05000324 F ACil'IY NAME                         DOCKET NUM8f R 01      20     1999       1999        -- 001 -                    00                          02                       19        1999 OPERATING           j MODE 19)                          THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFRt: (Check one or more) (11) 20.2201(b)                                               20.2203(a)(2Hv)                                        X    50.73(aH2Hi)                           50.73(aH2)(vm)
      - POWER          jQQ            20.2203(aH1)                                             20.2203(aH3)l)                                              50.73(aH2Hu)                           50.73(a)(2Hx)
LEVEL 00)                       20.2203(aH2)6)                                           20.2203(aH3Hu)                                              50.73(aH2Hm)                           73.71 yg 4,.                  -
20.2203(aH2Hii)                                          20.2203(eH4)                                                50.73(aH2)(iv)                        OTHER
  ;} gj;)                , ,.         20.22031aH2Hin)                                         50.36(cH1)                                                   50.73(aH 2Hv)                     speciev m Abstract beio. o, in l
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20.2203(aH2Hsv)                                         50.36(cH2)                                                   50.73(aH2Hvn)                     NRC Form 366A LICENSEE CONTACT FOR THIS LER (12)
NAME TELEPHONF NUMetR fanciuos Area Coas) l Mark A. rurkal, Project Engineer - Regulatory Affairs                                                                                                                   (910)457-3066 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)
REPORTABLE CAUSE         SYSTEM     COMPONENT            MANUFACTURER                             TO Epix                                 '                                                                      REPORTABLE CAUSE           SYSTEM       COMPONENT       MANUFACTURER              TO EPIX SUPPLEMENTAL REPORT EXPECTED (14)                                                                                                 EXPECTED             MONTH       DAY            Y t.AR YES                                                                                                                                                 SUBMISSION i         Uf yes, complete EXPECTED SUBMISSION DATE).                                                                X           NO                             DATE 115)
ADSTRACT (Limit to 1400 spaces,i.e., approximately 15 single-spaced typewntten lines)116)
On January 20,1999, with Units I and 2 both at 100 percent of rated thermal power, Carolina Power & Light (CP&L) Company determined that certain Category E welds on Units 1 and 2 had not been inspected per the schedule provided in Generic Letter 88-01,"NRC Position On IGSCC In BWR Austenitic Stainless Steel Piping," dated January 25,1988. Subsequently, on January 21,1999, and January 27,1999, CP&L determined that the required inspection frequency for certain Category D and C welds had also not been properly implemented. These inspections are augmented inspection requirements of the Brunswick Steam Electric                                                                                                                    >
Plant's Inservice Inspection (ISI) Program and, at the time the inspections were missed, a requirement of Technical Specification 4.0.5.f for both Units I and 2. As such, this condition is being reported, in accordance with 10 CFR 50.73(a)(2)(i)(B), as a condition prohibited by the plant's Technical Specifications.
The root cause of this condition is personnel error; the ISI Program Manager inappropriately revised the inspection schedule for the affected welds. Corrective actions include performance of Engineering evaluations which demonstrated that the structural integrity of the affected systems was not adversely impacted by the missed weld inspections. ISI Program enhancements, and the scheduling of inspections of the missed welds during upcoming refueling outages on each unit.
1 NHC f OHM .46161We8

NRC FQRM 366A               U.S. NUCLEAR REGULATORY CoMMISSloN (6-1998)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FAettlTY NAME (1)                                   ft t i         LER NUMBER (6)          PAGE (3)
                                                                                                    ", UMP        !
                                                                                                               ",0,' O Brunswick Steam El i *.ric Plant, Unit No.1                                                    -- 001 05000325       1999               -
00   2 OF 7 TEXT filmore space is required, use additional copies of NRC Form 366A) t17)
TITLE Missed Augmented Inservice Weld Inspections INITIAL CONDITIONS On January 20,1999, the Brunswick Steam Electric Plant (BSEP), Unit Nos. I and 2 were both operating at                    ,
100 percent of rated thermal power.                                                                                        j EVENT NARRATIVE On January 20,1999, Carolina Power & Light (CP&L) Company determined that certain Category E welds on Units 1 and 2 had not been inspected in accordance with the schedule provided in Generic Letter 88-01,                  l "NRC Position On IGSCC In BWR Austenitic Stainless Steel Piping," dated January 25,1988.
Subsequently, on January 21,1999, and January 27,1999, it was determined that the required inspection frequency for certain Category D and C welds had also not been properly implemented. The welds in question are listed in the following tables.
Category C Welds Weld Identification                         System IB32RECIRC-22-AM-4                          Recirculation [AD]
1B32RECIRC-22-BM-1                          Recirculation 1B32RECIRC-22-BM-5                          Recirculation 1B32RECIRC-28-A-2                           Recirculation 1B32RECIRC-28-A-5                           Recirculation 1B32RECIRC-28-A-13                          Recirculation 1B32RECIRC-28-B-2                          Recirculation 1B32RECIRC-28-B-3                           Recirculation 1B32RECIRC-28-B-9                           Recirculation 1B32RECIRC-28-B-16                         Recirculation 1B32RS2B2-10-FWB39                          Residual lieat Removal [BO]
Category D Welds Weld Identification                        System 12B211N88-JPI-FWRI22-2                     Jet Pump Instrumentation 1B21N4C-6-FWN4C225-3                       Feedwater [SJ) i NRC FORM 366A (6-1998)

NRC FORM 366A                             U S. NJCLEAR REGULATORY CoMMJSSION (6-1998)'
UCENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)                       Nu B e1       L ER NUMBER (6)          PAGE (3)
NE          "dvsda" l
Brunswick Steam Electric Plant, Unit No.1                                      05000325           - 001     - 00       3 OF 7 l1999 TEXT III more space is required. use additional copies of NRC Form 366A) t17}
* B21MD-5-FWN4D315-3                Feedwater IB21N4C-6-SW l-2                    Feedwater 1B21N4C-6-SW2-3                      Feedwater 1B21N4D-5-SW1-2                       Feedwater iB32RECIRC-28-B-6                     Recirculation 1B32RECIRC-28-B-7                     Recirculation IB32RECIRC-28-B-9BC                    Recirculation IB32RECIRC-28-B-12BC                    Recirculation IB32RECIRC-28-B-15BC                     Recirculation 2B32RECIRC-28-B-9BC                           Recirculation 2G3114-1-14-FW1960                             Reactor Water Cleanup [CE]
Category E Welds Weld Identification                               System 1B32RECIRC-4-B-1                              Recirculation 2B32RECIRC-4-B-1                                   Recirculation 2B32RECIRC-28-B-10                                  Recirculation 2B32RECIRC-28-B-11                                 Recirculation These inservice inspections of the above welds are augmented inspection requirements of BSEP's Inservice Inspection (ISI) Program. In response to Generic Letter 88-01, CP&L committed to inspect welds containing austenitic stainless steel susceptible to intergranular stress ccrrosion cracking (IGSCC). This commitment was incorporated into the Technical Specifications (TSs) for both Unit I and 2 as TS 4.0.5.f, which stated:
The Inservice Inspection Program for piping identified in NRC Generic Letter 88-01 shall be performed in accordance with the staff positions on schedule, methods and personnel and sample expansion included in this letter.
On July 25,1998, CP&L implemented the Improved Techneial Specifications (ITS) at BSEP. With implementation of ITS, the requirements of TS 4.0.5.f were relocated to Section 5.2.3.4.2.4 of the BSEP Updated Final Safety Analysis Report (UFSAR). Ilowever, at the time the inspections were missed, TS 4.0.5.f was still in effect. As such, this condition is being reported, in accordance with 10 CFR 50.73(a)(2)(i)(B), as a condition prohibited by the plant's Technical Specifications.
NRC FORM 366A (6-1998)

(-    .. .
                                                                   ~
NI.C FORM 366A                        U.S. NUCLEAR REGULATORY COMMISSION (6 1998)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION
                                                                 ~
* DoGKET 12)
FACILITY NAME (1)                   lJUMBER f 2)       LER NUMBER (6)       PAGE (3)
                                                                                            *"     ",U@        "Jf3 Bmnswick Steam Ele +                       Plant, Unit No.1              05000325     1999   - 001 - 00        4 OF 7 TEXT Vimore space is required. use additional copies of NRC Form 366A) (17)
EVENT CAUSE The root cause of this condition is personnel error. The ISI Program Manager inappropriately revised the mspection schedule for the affected welds. Additionally, programmatic weaknesses allowed this error to go undetected.
In response to Ge .eric Letter 88-01, CP&L committed to inspect welds containing austenitic stainless steel susceptible to IGSCC. Generic Letter 88-01,in turn, adopts the guidance contained in NUREG-0313, Revision 2, " Technical Report On Material Selection And Processing Guidelines For BWR Coolant Pressure Boundary Piping." NUREG-0313 describes seven categories of welds (i.e., A through G) based on their degree of susceptibility to IGSCC. Inspection frequencies are then established for each category of welds.
Category C welds are welds on IGSCC nonresistant materials that have undergone Stress Improvement (SI) after two years cf operation. Category C welds require inspection within two refueling cycles following the SI, after which they must be inspected every 10 years. Category D welds are welds on nonresistant materials that have not undergone St. Category D welds require inspection every two refueling cycles. Category E welds are welds that have identified cracks, which were either reinforced by weld overlay, or were mitigated by SI. Category E welds require an initial inspection, after which they must be inspected every 2 refueling cycles, similar to the Category D welds.
As required by NUREG-0313, the original inspection schedule for the BSEP Category E welds was based upon the original performance of SI or weld overlay. Thesc activities were completed for both A and B recirculation loops during the same outage on each unit. Thus, each subsequent refueling outage required examinations of approximately half of the A loop welds and half of the B loop welds with the remaining welds to be inspected in the following outage. Similarly,initialinspections of Category D welds on both A and B recirculation loops were completed during the same outage on each unit.
Performing the weld inspections on both loops in a single outage is not efficient with respect to dose and manpower expenditures. By limiting setup and demobilization activities to a single recirculation loop in each outage, a significant dose savings is realized. In ord ;o achieve this, the ISI Program Manager                             i inappropriately implemented a mvised examination schedule in mid 1997. The missed weld inspections                          '
occurred during the transition to the revised examination schedule. Until this transition period, the augmented weld inspections were performed at the appropriate frequency.
The ISI Program Manager incorrectly believed that, similar to American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI required inspections, the only requirement was to ensure that each Category D and E weld is inspected at least once in the two refueling cycle period.
Hence, a given weld could be inspected during the first refueling cycle of a given two cycle period and the second refueling cycle of the next two cycle period. This concept was the bases of the schedule revision to divisionalize the Category D and E weld inspections.
b NRC FOMA 306A (61998)

 .           ,~
NRC FORM 366A               U.S. NUCLEAR REGULATORY CoMMISSloN to-1C98)
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)                                                   Nu    ti      LER NUMBER 161      PAGE 13)
                                                                                                                   "MP        3*$
Brunswick Steam Electric Plant, Unit ho.1 05000325   1999    - 001     -- 00 5 OF 7 TEXT lit more space is required. use additional copies of NRC Form 366A) (17)
A similar thought process was applied to the revised inspection schedule for Category C welds. That is, the examinations of individual welds could be performed at any time within the ten year examination period.
This meant that the frequency between weld inspections for any given weld did not have to be regular: for instance, a Category C weld could be inspected at the beginning of the first ten-year period, and again at the end of the second ten year period.
However, NUREG-0313 requires that there be no more that two refueling cycles between inspections of a given Category D or E weld and no more that 10 years Ltween inspections of a given Category C weld. As a result, the inspection frequency, previously required by TS 4.0.5.f. was not maintained for the affected Category C, D, and E welds when transitioning to the revised inspection schedule.
A contributing factor of this condition is a programmatic weakness in the ISI Program. Specifically, there are no proceoural requirements for independent reviews or management approvals of changes to the augmented program weld inspection schedule.
CORRECTIVE ACTIONS Upon discovery of the missed weld inspections, Engineering evaluations were initiated in accordance with the requirements of Required Compensatory Measure A.] of Section 3.14, "Stmetural Integrity." of the Technical Requirements Manual. These evaluations demonstrated that the structural integrity of the affected systems was not adversely impacted by the missed weld inspections and that continued operation until the next refueling outage on each unit is acceptable.
On January 23,1999, the Unit 2 Category D weld (i.e.,2G3114-1-14-FW1960) on the Reactor Water Cleanup system was inspected. The weld was found to be acceptable with no recordable indications. The remaining missed inspections will be completed during each unit's next refueling outage (i.e., B214R1 for Unit 2, scheduled to start in April 1999, ;ind B113R1 for Unit 1, scheduled to start in Febmary 2000).
CP&L reviewed the remaining IGSCC weld inspection records to ensure there were no other missed weld inspections.
CP&L will revise the governing procedures for the ISI Program (i.e., OENP 16, " Procedure' for Administrative 3
Control of Inservice Inspection Activities" and/or OENP-16.2, " Administrative Control of ASME Section XI                                I Non-Destructive Examination Program")(1) to require independent reviews for fumre changes to regulatory-critical information such as the inspection schedule and (2) to require that the augmented ISI weld programs (e.g., IGSCC) be subject to the same auditing requirements imposed upon code weld programs.
CP&L will review other programs, including reguhtory augmented programs, to confirm sufficient review controls for revisions are preser NRC f ORM 366A (61998)

                                  .                                                                                                                    l NRC FORM 1366A                             U.S. NUCLEAR REGULATORY COMMISSION (6-1998n LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION                          ,
DOCKET (2)
FACILITY NA'ME (1)                                                  NUMBER f2)      LER NUMBER (6)     PAGE (3)
                                                                                                                               "E W       CE Brunswick Steam Electric Plant, Unit No.1                                                               05000325     1999    -- 001    2 00 6 OF 7 TEXT (lt more space is requ                      d. use additional copies of N9C Form 366A) l11)
SAFETY ASSESSMENT The safety significance of this occurrence is minimal. Upon discovery ot the missed weld inspections, Engineering evaluations were initiated in accordance with the requirements of Required compensatory Measure A.1 of Section 3.14, "Stmetural Integrity," of the Technical Requirements Manual. These evaluations demonstrated that the structural integrity of the affected systems was not adversely impacted by the missed weld inspections and that continued operation until the next refueling outage for each unit is acceptable.
PREVIOUS SIMILAR EVENTS CP&L has reviewed Licensee Event Reports (LERs) frc,m 1996,1997, and 1998 and identiDed the following repons associated with missed surveillance intervals:
: 1. LER l-97-012, " Standby Gas Treatment System Fire Protection System Deluge Valve Surveillance Interval Exceeded," dated October 8,1997. The apparent root cause of this condition was the lack of an adequate definition for testable versus non-testable valves.
: 2. LER l-97-009, " Missed Increased Frequency Inservice Testing Requirement," dated August 13,1997.
This condition involved the failure to pioperly increase the test frequency for a valve based on degradation in the measured stroke time. The root cause of the event was lack ofInservice Testing Program controls necessary to ensure that completed valve stroke time tests were trended in a timely manner.
: 3. LER l-97-008, " Main Stack Radiation Monitor Surveillance Interval Exceeded," dated September 18,1997. The root cause of this condition was an inadequate review of the UFSAR change associated with removal of the Main Stack Radiation Monitor response time test requirements from the TSs.
: 4. LER l-97-003," Response Time Elimination," dated April 4,1997, as supplemented April 1,1998. The root cause of this condition was an inadequate review of the UFSAP. change associated with removal of the response time testing requirements for the Reactor Protection system and Isolation Actuation system instrumentation from the TSs.
: 5. LER 2-96-004, " Jet Pump Surveillance Not Performed Prior To Exceeding 25% Reactor Power," dated October 11,1996. The root cause of this condition was human performance problems.
: 6. LER l-96-001, " Technical SpeciDeation Required Surveillance Not Performed Within Allotted Time,"
dated February 14,1996. This LER reponed a missed monthly Reactor Building Vent tritium sample surveillan'ce. The root cause of this condition was a process inadequacy in the scheduling of the monthly surveillances.
NRC FORM 366A (61998)

,        NRC FORM 366A             U.S. NUCLEAR REGULATORY COMMISSION l        (6 19987 LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME 11)                               Nt B f                 LER NUMBER (6)                    PAGE (3)
                                                                                                     "^"
l "EE         ",17%n" Brunswick Steam Electric Plant, Unit No.1                             05000325           1999     - 001 - 00               7 OF 7 TEXT (11more space is required. use additionalcopies of NRC Form 366A) (17)
Although there have been several instances of missed surveillances over the past three years, corrective actions for the root causes of these events would not have reasonably been expected to have prevented the situation reported in this LER (i.e., LER l-99-001).
COMMITMENTS Those actions committed to by CP&L Company in this document are identified below. Any other actions discussed in the submittal represent intended or planned actions by CP&L. They are described for the NRC's info mation and are not regulatory commitments. Please notify the Manager - Regulatory Affairs of any questions regarding this document or any associated regulatory commitments.
: 1. Inspections of the affected IGSCC susceptible welds will be compkted during each unit's next refueling outage (i.e., B214R1 for Unit 2, scheduled to start in April 1999, and Bl13R1 for Unit 1, scheduled to start in February 2000).
l          2. CP&L will revise the governing procedures for the ISI Program (i.e., OENP 16, " Procedure for Administrative Control of Inservice Inspection Activities" and/or OENP-16.2, " Administrative Control of ASME Section XI Non-Destnictive Examination Program") (1) to require independent reviews for future changes to regulatory-critical information such as the inspection schedule and (2) to require that the augmented ISI weld programs (e.g., IGSCC) be subject to the same auditing requirements imposed upon l
code weld programs. The required procedure changes will be implemented by October 8,1999.
: 3. CP&L will review other programs, including regulatory augmented programs, to confirm sufficient review controls for revisions are present. This review will be completed by September 10,1999.
Energy Industry Identification System (EIIS) codes are identified in the text as [xx].
i NRC FORM 366A 161998) m_.                                 .      .
                                                                . .                      . . . . . .                          . . .  . . _ . . . _}}