IR 05000324/1997012

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

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: ML20198P023 ML20198P056
References
50-324-97-12, 50-325-97-12, EA-97-519, EA-97-520, NUDOCS 9801210305
Download: ML20198P023 (46)

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December 23, 1997

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EA 97 519 EA 97 520

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Carolina Power and Light Company ATTN: Mr. C. :

Vice President

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Brunswick Steam Electric Plant P. 0. Box 10429-Southport, North Carolina 28461

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SUBJECT:

NOTICE OF VIOLATION

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(NRC INTEGRATED INSPECTION REPORT 50 325, 324/97 12)

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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

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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

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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

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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

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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-

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Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity Level IV violation. However, the NRC was concerned that the

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engineering analysis justifying the deviation from.the Final Safety Analysis agg g

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CP&L

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.

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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

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Original signed by Luis A. Reyes Luis A. Reyes Regional Administrator

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Docket-Nos.- 50 325, 50 324

License _Nos. OPR 71 DP M 2

~ Enclosures:

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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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cc w/encls:

Director Assistant Attorney General

Site Operations State of North Carolina

Brunswick Steam Electric Plant P. O. Box 629

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. P. O. Box 10429-Raleigh, NC 27602 l

Southport, NC 28461 l

Executive Director

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J. J. Lyash Public Staff NCUC q

Plant Mana9er P. O. Box 29520

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Brunswick Steam Electric Plant Raleigh, NC 27626 0520 Carolina Power & Light Company P. O. Box 10429 Public Service Commission

Southport, NC 28461 State of South Carolina

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P. O. Box 11649 t

0. B. Alexander. Manager Columbia, SC 29211

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Performance Evaluation and

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Regulatory Affairs OHS 7 Chairman

- Carolina Power & Light Company Brunswick County Board of

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412 S. Wilmington Street Commissioners

Raleigh, NC. 27601 P. O. Box 249

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Bolvia, NC 28422 K.-R. Jury, Manager

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Regulatory Affairs Emergency Management Coordinator

Carolina Power & Light Company New Hanover County Department of

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Brunswick Steam Electric Plant Emergency Management

P. O. Box 10429 P. O. Box 1525

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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

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P. O ' Box IE51 Southport, NC 28461 Raleigh, NC 27602

- Director Division of Radiation Protection

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N. C. Dep& Natural Resources artment of Environmental

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Health 3825 Barrett Drive

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Raleigh, NC 27609 7721 P

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Distribution w/encls:-

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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-

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J.'Lenahan, RII

.W. Rankin, RII D. Thompson, RII-PUBLIC

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NRC Resident Inspector.

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U.S. Nuclear Regulatory Commission -

8470 River Road. SE

'Southport, NC -28461

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