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{{Adams | |||
| number = ML20198P023 | |||
| issue date = 12/23/1997 | |||
| title = Discusses Insp Repts 50-324/97-12 & 50-325/97-12 Completed on 971113 & Forwards Nov.Enforcement Conference Held on 971219 to Discuss Violations Noted.List of Attendees & Presentation Matls Also Encl | |||
| author name = Reyes L | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) | |||
| addressee name = Hinnant C | |||
| addressee affiliation = CAROLINA POWER & LIGHT CO. | |||
| docket = 05000324, 05000325 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-324-97-12, 50-325-97-12, EA-97-519, EA-97-520, NUDOCS 9801210305 | |||
| package number = ML20198P028 | |||
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE | |||
| page count = 46 | |||
}} | |||
See also: [[see also::IR 05000324/1997012]] | |||
=Text= | |||
{{#Wiki_filter:___ _ .- . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ | |||
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December 23, 1997 . | |||
EA 97 519 | |||
EA 97 520 | |||
, | |||
' | |||
Carolina Power and Light Company | |||
ATTN: Mr. C. S. Hinnant : | |||
Vice President - | |||
' | |||
Brunswick Steam Electric Plant | |||
P. 0. Box 10429- | |||
Southport, North Carolina 28461 . | |||
' | |||
SUBJECT: NOTICE OF VIOLATION | |||
(NRC INTEGRATED INSPECTION REPORT 50 325, 324/97 12) | |||
. Dear Mr. Hinnant: | |||
On November 8,1997, the NRC completed an inspection at your Brunswick facility.' l | |||
The inspection included a review of your corrective actions for failure of a , | |||
Unit I drywell cooler fan and your actions to correct a design deficiency ; | |||
affecting the pressure suppression design function of primary containment. You | |||
were informed of the results of our inspection on November 13, 1997,' and the | |||
inspection report was sent to you by letter dated December 8,1997. An open | |||
predecisional enforcement conference was conducted in the Region II office on | |||
December 19, 1997, with you and members of your staff to discuss the apparent . | |||
violation, the root causes, and your corrective actions to preclude recurrence. * | |||
A list of conference attendees NRC slides, and a copy of Carolina Power and | |||
Light Company's (CP&L) _ presentation materials are enclosed. | |||
Based on the information developed during the inspection and the information you | |||
provided during the conference, the NRC has determined that a violation of NRC | |||
requiremerits occurred. The violation is cited in the enclosed Notice of | |||
< | |||
Violation (ko+W) and the circumstances sarrounding it are described in detail | |||
in the subject inspection resort. The violation involves the failure to take | |||
acsquate corrective action w1en the tem >erature of areas in the Unit I drywell | |||
exceeded the 221.7 degrees Farenheit ( ") temperature value prescribed by | |||
Engineering Lervice Reouest 96 397. Specifically, upon tailure of the 101 | |||
~ drywell cooler in Ane 1997, the effect of the subsequent temperature rise to | |||
230*F on the seal life of snubbers near the reactor vessel head were not | |||
evaluated. As a result, +he calculated life expectancies of seven out of ten | |||
snubbers on the raactor head vent line were exceeded. | |||
. As discussed at the predecisional enforcement conference, the condition was - | |||
, identified by a CP&L engineer evaluating Unit 2 equipment qualification issues | |||
ind the actual and potential safety significance of the inoperable snubbers was - | |||
ty since analyses indicated that the restraints on the head vent lines were | |||
.adeguate without the snubbers.- In addition, testing pe-formed on Unit 2 | |||
snuboers, exposed to similar high temperature conditions, indicated that the | |||
; Unit 1 snubbers probably wouM have performed their design function. Therefore, | |||
' | |||
)the violation has been categorized in accordance with the " General Statement of- 3 | |||
Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG- | |||
1600, as a Severity Level IV violation. However, the NRC was concerned that the | |||
: engineering analysis justifying the deviation from.the Final Safety Analysis | |||
{l | |||
agg g [~ ll lg gll ll | |||
u um | |||
__ | |||
CP&L 2 | |||
Report (FSAR) design limit was not updated when the actual plant conditions | |||
increased above the analyzed value. | |||
The NRC was also concerned with the documentation and handling of the out of- | |||
specification drywell temperature. O rations wrsonnel were documenting the | |||
out of specfication condition on dail logs. T1e entries were routinely marked | |||
with a red pen indicating the res foun value was above the limit. The condition | |||
was accepted by Operations because an engineering analysis had been completed | |||
justifying a value higher than that described in the FSAR and the daily logs, | |||
However, the actual values prescribed by the engineering analysis, which were | |||
different for Unit I and 2, were not annotated on the logs. As a result, when | |||
~ the Unit 1 drywell cooler failed, and drywell temperatures exceeded the analyzed | |||
values for Unit 1, Operations accepted the higher temperatures without a formal | |||
engineering evaluation of the effect on containment equipment. | |||
One example of the apparent violation identified in NRC Inspection Report | |||
=No. 50 325, 324/97 12 included inadequate corrective actions to ensure the ; | |||
pressure suppression function of the torus was-adequate. Based on your | |||
presentation at the predecisional enforcement conference, the NRC concluded that- | |||
your corrective actions did adequately address the torus design issues identified | |||
at other sites and that when the specific design problem affecting Brunswick was | |||
identified, your corrective actions were timely. Therefore, this example of the | |||
apparent violation is withdrawn. As stated at the conference, the NRC is | |||
conducting a review of the generic implications of the torus design deficiency | |||
and will address the resolution of this issue and any associated enforcement | |||
action at a later date. | |||
You are required to respond to this letter and should follow the instructions | |||
specified in the enclosed Notice when preparing your response. In your response, | |||
you should document the specific actions taken and any additional actions you | |||
plan to prevent recurrence of the violations. After reviewing your response to | |||
this Notice, including your proposed corrective actions and the results of future | |||
inspections, the NRC will determine whether further NRC enforcement action is | |||
necessary to ensure compliance with NRC regulatory requirements. ' | |||
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this | |||
letter and its enclosures will be placed in the NRC Public Document Room. | |||
Sincerely. | |||
Original signed by | |||
Luis A. Reyes | |||
Luis A. Reyes | |||
Regional Administrator , | |||
. | |||
* | |||
Docket-Nos.- 50 325, 50 324 | |||
License _Nos. OPR 71 DP M 2 | |||
~ Enclosures: 1. Notice of Violation | |||
2.- List of Attendees- | |||
3. CP&L Presentation Materials | |||
4. . NRC-Presentation Materials | |||
I | |||
.cc w/encls: See page 3' | |||
' | |||
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; | |||
- . - . - . . . .- - . . - - - . --, - -- --- | |||
_ _ _ _ - - _ _ . _ _ _ _ _ - - _ - _ . | |||
. | |||
' | |||
! | |||
,- | |||
CP&L 3 ! | |||
! | |||
cc w/encls: | |||
Director Assistant Attorney General 1 | |||
Site Operations State of North Carolina : | |||
o Brunswick Steam Electric Plant P. O. Box 629 ! | |||
. P. O. Box 10429 -Raleigh, NC 27602 l | |||
Southport, NC 28461 l | |||
Executive Director ! | |||
J. J. Lyash Public Staff NCUC q | |||
Plant Mana9er P. O. Box 29520 - | |||
Brunswick Steam Electric Plant Raleigh, NC 27626 0520 | |||
Carolina Power & Light Company | |||
P. O. Box 10429 Public Service Commission 7 | |||
Southport, NC 28461 State of South Carolina > | |||
P. O. Box 11649 t | |||
< 0. B. Alexander. Manager Columbia, SC 29211 : | |||
' | |||
Performance Evaluation and ! | |||
Regulatory Affairs OHS 7 Chairman | |||
- Carolina Power & Light Company Brunswick County Board of ' | |||
412 S. Wilmington Street Commissioners ; | |||
Raleigh, NC. 27601 | |||
- | |||
P. O. Box 249 ; | |||
Bolvia, NC 28422 | |||
' | |||
K.-R. Jury, Manager | |||
Regulatory Affairs Emergency Management Coordinator : | |||
Carolina Power & Light Company New Hanover County Department of | |||
' | |||
Brunswick Steam Electric Plant Emergency Management ; | |||
' | |||
P. O. Box 10429 P. O. Box 1525 | |||
Southport, NC 28461 0429 Wilmington, NC 28402 | |||
W. D. Johnson. Vice President Mayor ! | |||
and Senior Counsel City of Southport l | |||
Carolina Power & Light Company 201 East Moore Street ! | |||
P. O ' Box IE51 Southport, NC 28461 | |||
Raleigh, NC 27602 ; | |||
- Director ! | |||
Division of Radiation Protection ! | |||
artment of Environmental ' | |||
N.Health | |||
C. Dep& Natural Resources | |||
3825 Barrett Drive - | |||
; | |||
Raleigh, NC 27609 7721 | |||
P | |||
; | |||
1_ | |||
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t | |||
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5 | |||
- | |||
. . _ - - - . | |||
; | |||
$ | |||
< | |||
CP&L 4 , | |||
Distribution w/encls:- ,. | |||
J. Lieberman. OE r | |||
OE:EA File (BStamers.0E) (2 letterhead copies)) | |||
-A.-Boland, RII | |||
H.'Shynlock, RII-(IFS action required) | |||
D. Trimble, NRR J | |||
J.-Coley. RII ' | |||
R. Baldwin, RII- | |||
* | |||
J.'Lenahan, RII | |||
.W. Rankin, RII | |||
D. Thompson, RII- | |||
PUBLIC - | |||
NRC Resident Inspector . ! | |||
U.S. Nuclear Regulatory Commission - | |||
:8470 River Road. SE | |||
'Southport, NC -28461 | |||
- | |||
, | |||
; | |||
i | |||
4 | |||
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OFFICF All d R!l!C F . R M IIC 4 Ril:0R4 R!l:0RA | |||
unt u | |||
,,, e ,,, ' uN cr N (dk an. net | |||
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' | |||
, OFFICIAL RECOR& CGPY - DOCLM NI TA K :M970 PEN,ENF\975198RU.DIR\ FINAL. | |||
' | |||
. | |||
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. . . - . . - . . . _ - - , | |||
}} |
Latest revision as of 07:40, 15 December 2020
ML20198P023 | |
Person / Time | |
---|---|
Site: | Brunswick ![]() |
Issue date: | 12/23/1997 |
From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | Hinnant C CAROLINA POWER & LIGHT CO. |
Shared Package | |
ML20198P028 | List: |
References | |
50-324-97-12, 50-325-97-12, EA-97-519, EA-97-520, NUDOCS 9801210305 | |
Download: ML20198P023 (46) | |
See also: IR 05000324/1997012
Text
___ _ .- . _ _ _ _ _ _ - _ _ _ _ _ _ _ _
'
!
!
'
.
- ' k
,
December 23, 1997 .
EA 97 519
EA 97 520
,
'
Carolina Power and Light Company
ATTN: Mr. C. S. Hinnant :
Vice President -
'
Brunswick Steam Electric Plant
P. 0. Box 10429-
Southport, North Carolina 28461 .
'
SUBJECT: NOTICE OF VIOLATION
(NRC INTEGRATED INSPECTION REPORT 50 325, 324/97 12)
. Dear Mr. Hinnant:
On November 8,1997, the NRC completed an inspection at your Brunswick facility.' l
The inspection included a review of your corrective actions for failure of a ,
Unit I drywell cooler fan and your actions to correct a design deficiency ;
affecting the pressure suppression design function of primary containment. You
were informed of the results of our inspection on November 13, 1997,' and the
inspection report was sent to you by letter dated December 8,1997. An open
predecisional enforcement conference was conducted in the Region II office on
December 19, 1997, with you and members of your staff to discuss the apparent .
violation, the root causes, and your corrective actions to preclude recurrence. *
A list of conference attendees NRC slides, and a copy of Carolina Power and
Light Company's (CP&L) _ presentation materials are enclosed.
Based on the information developed during the inspection and the information you
provided during the conference, the NRC has determined that a violation of NRC
requiremerits occurred. The violation is cited in the enclosed Notice of
<
Violation (ko+W) and the circumstances sarrounding it are described in detail
in the subject inspection resort. The violation involves the failure to take
acsquate corrective action w1en the tem >erature of areas in the Unit I drywell
exceeded the 221.7 degrees Farenheit ( ") temperature value prescribed by
Engineering Lervice Reouest 96 397. Specifically, upon tailure of the 101
~ drywell cooler in Ane 1997, the effect of the subsequent temperature rise to
230*F on the seal life of snubbers near the reactor vessel head were not
evaluated. As a result, +he calculated life expectancies of seven out of ten
snubbers on the raactor head vent line were exceeded.
. As discussed at the predecisional enforcement conference, the condition was -
, identified by a CP&L engineer evaluating Unit 2 equipment qualification issues
ind the actual and potential safety significance of the inoperable snubbers was -
ty since analyses indicated that the restraints on the head vent lines were
.adeguate without the snubbers.- In addition, testing pe-formed on Unit 2
snuboers, exposed to similar high temperature conditions, indicated that the
- Unit 1 snubbers probably wouM have performed their design function. Therefore,
'
)the violation has been categorized in accordance with the " General Statement of- 3
Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-
1600, as a Severity Level IV violation. However, the NRC was concerned that the
- engineering analysis justifying the deviation from.the Final Safety Analysis
{l
agg g [~ ll lg gll ll
u um
__
CP&L 2
Report (FSAR) design limit was not updated when the actual plant conditions
increased above the analyzed value.
The NRC was also concerned with the documentation and handling of the out of-
specification drywell temperature. O rations wrsonnel were documenting the
out of specfication condition on dail logs. T1e entries were routinely marked
with a red pen indicating the res foun value was above the limit. The condition
was accepted by Operations because an engineering analysis had been completed
justifying a value higher than that described in the FSAR and the daily logs,
However, the actual values prescribed by the engineering analysis, which were
different for Unit I and 2, were not annotated on the logs. As a result, when
~ the Unit 1 drywell cooler failed, and drywell temperatures exceeded the analyzed
values for Unit 1, Operations accepted the higher temperatures without a formal
engineering evaluation of the effect on containment equipment.
One example of the apparent violation identified in NRC Inspection Report
=No. 50 325, 324/97 12 included inadequate corrective actions to ensure the ;
pressure suppression function of the torus was-adequate. Based on your
presentation at the predecisional enforcement conference, the NRC concluded that-
your corrective actions did adequately address the torus design issues identified
at other sites and that when the specific design problem affecting Brunswick was
identified, your corrective actions were timely. Therefore, this example of the
apparent violation is withdrawn. As stated at the conference, the NRC is
conducting a review of the generic implications of the torus design deficiency
and will address the resolution of this issue and any associated enforcement
action at a later date.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response. In your response,
you should document the specific actions taken and any additional actions you
plan to prevent recurrence of the violations. After reviewing your response to
this Notice, including your proposed corrective actions and the results of future
inspections, the NRC will determine whether further NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements. '
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this
letter and its enclosures will be placed in the NRC Public Document Room.
Sincerely.
Original signed by
Luis A. Reyes
Luis A. Reyes
Regional Administrator ,
.
Docket-Nos.- 50 325, 50 324
License _Nos. OPR 71 DP M 2
~ Enclosures: 1. Notice of Violation
2.- List of Attendees-
3. CP&L Presentation Materials
4. . NRC-Presentation Materials
I
.cc w/encls: See page 3'
'
g
- . - . - . . . .- - . . - - - . --, - -- ---
_ _ _ _ - - _ _ . _ _ _ _ _ - - _ - _ .
.
'
!
,-
CP&L 3 !
!
cc w/encls:
Director Assistant Attorney General 1
Site Operations State of North Carolina :
o Brunswick Steam Electric Plant P. O. Box 629 !
. P. O. Box 10429 -Raleigh, NC 27602 l
Southport, NC 28461 l
Executive Director !
J. J. Lyash Public Staff NCUC q
Plant Mana9er P. O. Box 29520 -
Brunswick Steam Electric Plant Raleigh, NC 27626 0520
Carolina Power & Light Company
P. O. Box 10429 Public Service Commission 7
Southport, NC 28461 State of South Carolina >
P. O. Box 11649 t
< 0. B. Alexander. Manager Columbia, SC 29211 :
'
Performance Evaluation and !
Regulatory Affairs OHS 7 Chairman
- Carolina Power & Light Company Brunswick County Board of '
412 S. Wilmington Street Commissioners ;
Raleigh, NC. 27601
-
P. O. Box 249 ;
Bolvia, NC 28422
'
K.-R. Jury, Manager
Regulatory Affairs Emergency Management Coordinator :
Carolina Power & Light Company New Hanover County Department of
'
Brunswick Steam Electric Plant Emergency Management ;
'
P. O. Box 10429 P. O. Box 1525
Southport, NC 28461 0429 Wilmington, NC 28402
W. D. Johnson. Vice President Mayor !
and Senior Counsel City of Southport l
Carolina Power & Light Company 201 East Moore Street !
P. O ' Box IE51 Southport, NC 28461
Raleigh, NC 27602 ;
- Director !
Division of Radiation Protection !
artment of Environmental '
N.Health
C. Dep& Natural Resources
3825 Barrett Drive -
Raleigh, NC 27609 7721
P
1_
-
t
f , ,. - - . , . - - , , , , n- ,,......,,...-,-..m,,,,,- ,,-l -
5
-
. . _ - - - .
$
<
CP&L 4 ,
Distribution w/encls:- ,.
J. Lieberman. OE r
OE:EA File (BStamers.0E) (2 letterhead copies))
-A.-Boland, RII
H.'Shynlock, RII-(IFS action required)
D. Trimble, NRR J
J.-Coley. RII '
R. Baldwin, RII-
J.'Lenahan, RII
.W. Rankin, RII
D. Thompson, RII-
PUBLIC -
NRC Resident Inspector . !
U.S. Nuclear Regulatory Commission -
- 8470 River Road. SE
'Southport, NC -28461
-
,
i
4
4
f
i
,
L-
5fW TO PLSLIC MM, vt5'
OFFICF All d R!l!C F . R M IIC 4 Ril:0R4 R!l:0RA
unt u
,,, e ,,, ' uN cr N (dk an. net
., ,,,1 - o ,, ,,. ,,, ,,, ,,, . 1
cervt vtsMol vrs - (m) /vt0 m vrs- m vts e
'
, OFFICIAL RECOR& CGPY - DOCLM NI TA K :M970 PEN,ENF\975198RU.DIR\ FINAL.
'
.
4 P
i s
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. . . - . . - . . . _ - - ,