IR 05000324/1991015

Insp Repts 50-324/91-15 & 50-325/91-15 on 910520-30.No Violations Noted.Major Areas Inspected:Examined Licensee Actions on Previous Insp Findings & Evaluated Three Concerns Reported to NRC by Former Employee

ML20138F691
Person / Time
Site:	Brunswick
Issue date:	07/02/1991
From:	Girard E, Jape F, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138F666	List: IR 05000324/1991015 ML20138F663
References
50-324-91-15, 50-325-91-15, NUDOCS 9610180035
Download: ML20138F691 (16)

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, UNITE] STATES a me49A o NUCLEAR REGULATORY COMMIS$10N p , REGION 11

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g 101 MARIETTA STREET. t ATLANTA, GEORGI A 30323

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Report Nos.: 50-325/91-15 and 50-324/91-15 Licensee': Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.: DPR-62 and DPR-71 Facility Name: Brunswick I and 2

? 1 Inspection Conducted: May 20-30, 1991 Inspectors: h . I //j b / d e ~7 - 2 - 9/

E. Girard

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Date Signed Approved by: C F. Jape, Section Chiefp

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Test Programs Section Engineering Branch ,

Division of Reactor Safety i SUMMARY Scope:

This special, announced inspection examined licensee actions on previous inspection findings and, in addition, evaluated three concerns reported to the NRC by a former licensee employee. The previous inspection findings consisted of one violation associated with local leak rate testing and five inspector followup items that correspond to licensee Integrated Action Plan (IAP) action items. The reported concerns of the former employee involved calibration and maintenance of a recorder, recirculation pump shaft seals leakage, and whether the designated importance to safety of hydraulic control unit cartridge valves had been properly considered in a licensee Engineering Evaluation Repor Results:

! Licensee actions relative to the violation and two of the IAP action items were i

found adequate to warrant closure. The three other IAP action items will l remain open because the actions taken had not been demonstrated effective. The concerns of the former employee regarding two of the equipment items were deterinined to be unsubstantiated and the third, involving the recorder, will require further review during a subsequent inspectio l 9610180035 910702 I PDR ADOCK 05000324 3 G PDR 4

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2 No significant overall licensee strengths or weaknesses were noted in the areas examined, though the need for additional httention to determine and monitor the effectiveness of IAP actions was indicate No violations or deviations w!re identifie l

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REPORT DETAILS i

l Persons Contacted Licensee Employees

• K. Ahern, Manager, Regulatory Compliance

• M. Bradley, Manager, Nuclear Assessment Department (NAD)

L P. Brown, Reactor Recirculation System Engineer l L. Bryant, Control Rod Drive Engineering Technician l

• S. Callis, On-Site Representative, Licensing i R. Creech, Manager - Instrumentation and Control Maintenance 1

• A. Crockett, Senior Specialist Engineer, Nuclear Engineering Department !

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• M. Foss, Manager, NRC Compliance i l T. Groblewski, Manager - Component Engineering  ;

• R. Helme, Manager, Technical Support D. Hendricks, Control Rod Drive Engineering Tec.inician i 0. Hudson, Corporate Nuclear Compliance Staff

• L. Jones, Manager - Procurement Engineering

1. T. Jones, Senior Specialist - Investigation, Compliance

• M. Kesmodel, Manager - Records Management, Control and Administration

• P. Musser, Manager, Maintenance Staff

• D. Quick, Manager, NAD

• Simpson, Manager, Control and Administration

1. J. Spenser, General Manager

• J. Titrington, Manager, Operations Support

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• R. Warden, Manager, Maintenance

• C. Willets, Plant Office Supervisor, Control and Administration L. Wheatley, Manager Inservice Inspection / Inservice Testing NRC Personnel

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R. Prevatte, Senior Resident Inspector

• D. Nelson, Resident Inspector

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• Attended exit interview held May 24, 1991

1. Attended exit interviews held May 24, 1991 and May 30, 1991 Acronyms and initialisms used throughout this report are listed in the l

last paragrap . Action on Previous Inspection Findings (92701, 92702)

The items addressed below include a vioistion and five inspector followup l items (IFIs). ~ The violation was identified through routine NRC inspection l and involves local leak rate testing. To determine whether it should l remain open, the inspectors assessed the actions taken by the licensee to

. correct and preclude its recurrence. The IFIs correspond to licensee

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Integrated Action Plan (IAP) summary action items which were developed to correct weaknesses reported by a 1989 NRC Diagnostic Evaluation Team l

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(DET). The status of the IFIs was determined by examining evidence of the licensee's completion of the associated sumary actions and of the

effectiveness of the actions in correcting the weaknesses originally identified. In most instances the licensee had specifically identified subordinate actions to accomplish the sumary action items and evidence of

, completion of these subordinate actions was also examined by the .

inspectors. The sumary actions were referred to by the licensee as Level i 1 actions and the subordinate actions were referred to as Level (Closed) Violation 50-325, 324/89-32-01: Failure to Maintain Records of Penetration Venting and Draining Activities Conducted Prior to Local Leak Rate Testing This violation related to procedure PT-20.3, Local Leak Rate Testing, ,

which is the controlling procedure for Type C leak rate testing of l containment isolation valves. This procedure specifies the valve alignment of valves within the test boundary for perfonning the local leak rate test (LLRT). However, PT-20.3 does not specify how venting and draining are to be accomplished to ensure that no artificial fluid '

barriers affect test results. Venting and draining the penetrations and associated piping were accomplished by the operations personnel through the clearance and tagging process. By this process, the  !

alignments used for venting and draining may vary from test to test, i are not reviewed by the Technical Support test personnel, and are not )

retained as a part of the test recor To correct these conditions i the Technical Support Group has developed procedure ENP-16.13, System *

Draining For Local Leak Rate Testing, which specifies a pre-approved I

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valve alignment and sequence for draining the penet' rations and associated piping. This procedure is ' retained as a permanent test record. Any deviations from the approved valve alignments must be I reviewed and approved by the Technical Support Group prior to implementatio The inspector reviewed portions of procedure ENP-16.13 and concluded that the licensee has taken adequate corrective action (Closed) IFI 50-325, 324/89-34-13: Followup on Implementati'on and Effectiveness of Nuclear Engineering Improvements in IAP Item B2, (Ref. 2.6.1.12.a)

This IFI represents the DET concern that the engineering transition to a central design organization (CDO) was poorly planned and implemented with regard to the Brunswick plant. The process had been time consuming, was still being refined and was expected to continue to change as various management studies and assessments were finalize In the Integrated Action Plan (IAP) response to the DET findings, the licensee stated that the transition from a fragmented engineering design control organization to the CD0 was undertaken slowly and methodically to minimize confusion and disruptions in safety

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considerations and normal business function However, the licensee has identified IAP Level 1 action item B2 to track the completion of changes in the Nuclear Engineering Department (NED) and to provide for staff assessment of the effectiveness of the CD0 concep The . i Level 1 IAP action item B.2 was stated as: " Implement Nuclear l Engineering Department (NED) Organizational Improvements." The l Level 1 (IAP) action item B.2 was subdivided into five Level 2 action l items which define the scope of item B.2. These Level 2 action items'

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include completing NED staffing, planning long range resources, improving engineering skill icvels (rotation plan), developing standardized site procurement functions, and transferring engineering data base system (EDBS) expertise to NE In a previous NRC inspection in July 1990 (NRC Report Nos. 50-325/

90-31 and 50-324/90-31) the inspectors concluded that the licensee had contoleted the activities described by the Level 2 action item However, IAP B2 was left open pending the licensee development and implementation of a method or program to evaluate the effectiveness of activities related to the IAP Level 1 action item B.2 and the completion of certain procedures and documents. Areus to be completed by the licensee included: 1) revise NED Guideline No. A-29. Revision 2 to include the NED onsite unit function ~s, 2) revise ~BNP/NED Interface Document to define procurement engineering responsibility, and 3) delineate job position descriptions for onsite NED supervisor Review of appropriate documents showed that the above comitments have been adequately completed. The documents reviewed included:

l (1) NED Guideline No. A-29, Revision 3, NED Unit Functions, dated

. August 24, 199 (2) BSP-9, Revision 2, NED and BNP Interface Agreement, dated October 29, 199 (3) Supervisor Job Descriptions for NED Onsite Unit (six)

During this inspection the inspector reviewed the method established by NED for self assessment and action taken to monitor NED performance. Documents reviewed during this evaluation included:

(1) NED Guideline No. E-17, Revision 3, NED Performance Modification Quality Assessment This document defines the responsibilities and methods to assess the number of field revisions (FRs) made to modification packages as a result of design input deficiencies (Performance Indicator).

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(2) NED Procedure 3.18, Corrective Action Program

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This document defines the responsibilities and processes for I identifying, investigating, correcting and tracking to closure conditions adverse to quality.

l (3) CP&L Internal Customer Satisfaction Survey j This document provides a method to evaluate work satisfaction with NED Services (Performance Indicator) group

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i 4 (4) Memorandum To File from K. A. Williamson, May 21, 1991 f This memo documents the percentage of contractor employees in ,

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the NED Brunswick Engineering Support Section (BESS), On-Site 1 l Unit (Performance Indicator). j

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! (5) Facts No. 90B0662, Sumary/ Conclusion

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l This document provides the results of FR assessments made on

August 1989 and May 1990 (Performance Indicator).

(6) Brunswick Engineering Support Section (BESS) Field Revision

Assessment May 11, 1990.

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This document provides an analysis of FRs to modification l packages from the Unit 2 1989-1990 outage (Performance

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Indicator).

(7) NED-B-3557, Memorandum from J. M. Brown to W. W. Simpson, May 15, 1991.

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This document provides the results of FRs to modification i' packages for the 1990-1991 Unit 1 Outage (Performance indicator).

i (8) NED-B-3558, Memorandum from J. M. Brown to W. W. Simpson, May 17, 1991.

l This document summarizes NED accomplishments for 1990 in relation to cost.. schedules, FR reduction, and plant support 2 (PerformanceIndicator)

i (9) NED Analysis Of Traini~ng Activities - Chart (Performance i

Indicator).

I (10) 1990-1994 and 1991-1995 NED Business Plan Summaries (Performance Indicator).

Based on review of these documents the inspectors detennined that NED has developed a method for assessing performanc NED goals are set in the 5 year Business Plan as it is updated each year. Visible parameters are identified and monitored as performance indicators to measure achievement Some observations of performance indicators in RMm cxMre arm m fastcegu

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(1) NED goal for training in 1991 is six percent of manhour In I the first quarter of 1991 NED has achieved eight percen .

(2) Reduction in FRs to modification packages resulting from design

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deficiencies was identified as a major NED effort. To monitor this effort NED issued a guideline (E-17) for assessment of FR causes. The initial assessment in August 1989 indicated that 20 percent of the FRs were related to design deficiencies. An

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assessment at the end of the 1989-1990 Unit 2 outage indicated 13 percent of the FRs were related to design deficiencies.

l An assessment at the end of the 1990-1991 Unit 1 outage indicated only 11 percent of the FRs were related to design cause Only four percent were classified as resulting from

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design deficiencie (3) NED has identified customer (CP&L work groups) satisfaction as a j performance indicator. This parameter is measured by a company l wide survey of work groups which interface with NED. The survey is anonymous and is statistically evaluated by a company i independent of CP& CP&L management believes that this l parameter is a measure of communication, team work, and the l timely delivery of a quality design product. Based on the survey for 1990, customer satisfaction has significantly j increased at all three nuclear project .

(4) NED identified the intent to reduce the number of contractor employees and replace these with CP&L employee Contractor employees in the Brunswick site NED group was reduced from 71 percent in July 1990 to 68.75 percent in May 199 (5) NED identified the intent to totate per:,onnel between sites and NED to enhance engineering skills. Personnel participating in this program have increased from two in mid 1990 to 16 in mid 199 Although not all NED goals were achieved in 1990, the inspectors concluded that NED had implemented a methodology to assess performance and measure the effectiveness of the CD Data obtained by tr:cking performance indicators for 1990, the Unit 2 outage (fali 89), and Unit 1 outage (fall 90) indicates that NED has demonstrated reasonable effectiveness in the limited time that the assessment program has been in effect. However, this conclusion is considered preliminary since it is based on a minimal amount of dat Specifically, early indications are that the centralization of L gn engineering functions has been effective in improving the qualit, af

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the design product but true effectiveness must be, judged over a longer period of time through continuing performance assessmen Plant management stated that CP&L is consnitted to a continuing performance monitoring and self assessnent progra c. (Closed) IFI 50-325, 324/89-34-20: Followup on Implementation and Effectiveness of Motor-Operated Valve Maintenance Program Improvements in IAP Item D3, (Ref. 2.1.3.10)

This IFI represents e DET concern that, although the Brunswick motor-operated valve NV) maintenance program had many strong provisions, it sufkred 6 om weaknesses in implementation. Problems identified by the D M e as follows:

(1) Procedure OCM-M0500 permitted the use of incorrect gearbox grease (2) Torque switch settings were only required to be verified to be within specified limits every 6 year (3) Preventive maintenance (PM) was not being con.pleted on schedul (4) A conflict existed between administrative procedure ENP-43 and modification procedure NED-1A-003 regarding controls on changing MOV switch settings. In addition, ENP-43 contained switch setting and other error Most had been identified in a licensee report over four months earlier but had not been corrected ye A maintenance engineer kept an unofficial corrected version of ENP-43 for use when valve work was to be undertake NRC Inspection 325, 324/90-32 determined that the licensee had corrected the deficiencies in (1) and (4).

In formally responding to the NRC DET, the licensee stated that (2)

did not represent a weakness or require correction as past experience indicated that the 6-year frequency was sufficient. However, they comitted to review their program and make necessary changes to ensure compliance with the reconsnendations of NRC Generic Letter (GL) 89-10 " Safety-Related Motor-0perated Valve Testing and Surveillance". This was addressed by Level 2 action item b, " review and make necessary changes to MOV testing procedures". The NRC is undertaking an extensive inspection program relative to GL 89-10 which will evaluate the effectiveness of all licensee MOV maintenance programs. The inspectors verified that the licensee had undertaken changes to procedures in response to the Generic Letter, such as development and implementation of a M0V trending program. The trending program procedure (ENP-52) and the initial April 1,1991, M0V trending report were reviewed by the inspectors. The inspectors found the report provided useful trend information on the licensee's

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! failures but noted it appeared deficient in not providing any goals, i recomendations, or drawing any conclusions regarding the presence or ,

) absence of trends. Its principal conclusion was that M0V operator 1

failures occurred most frequently during forced outages, scrams, and  !

l refuel outages. The inspectors noted that this was no indication of l

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. a trend, but only the obvious fact that more MOV failures will be 1 identified when the actions that identify failures are increased - as through the increased surveillances, inspections, and attempted

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operation of MOVs that occurs during forced outages, scrams, and

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refuel outages.

{ In response to the DET criticism described in (3), that PM was not i being completed on schedule, the licensee identified a Level 2 action i item " review the adequacy of MOV preventive maintenance and

scheduling". The inspectors interviewed licensee personnel who

indicated that the above actions had been accomplished.

4 Additionally, the licensee's file was found to contain a response to an internal commitment (CJJ 89-260) confirming that a review had been completed to ensure incorporation of proper PM practices into plant procedures. The inspectors verified that PMs were being completed as scheduled by reviewing the records for examples of PMs recently i scheduled. Nine valves (e.g., Residual Heat Removal system valves 1-E11-F026A, -F027A, -F104A, etc.) were checked for completion of mechanical preventive maintenance procedure OPM-M0504 and all were found to have had the procedure performed as schedule Based on the above, all of the specific concerns of the DET regarding MOV program implementation appear to have been corrected, exdept the concern that torque switch settings were. not being verified with sufficient frequency - a matter disputed by the licensee. Further, the licensee has instituted trending and other steps which should make the effectiveness of the MOV maintenance program more apparen The effectiveness of the licensee's MOV maintenance will be monitored and assessed by the NRC through inspections of the licensee's implementation of the recomendations of GL 89-10. The weaknesses identified by this IFI are considered adequately addressed by the actions already taken and the scheduled NRC inspection of the licensee's actions in response to GL 89-1 (0 pen) IFI 50-325, 324/89-34-21: Followup on Implementation and Effectiveness of Developed Post-Maintenance Testing Guidance in IAP Item D4, (Ref. 2.1.4.10)

.This IFI represents a DET concern (originally licensee identified)

that proper post-maintenance inservice inspection and testing was not always being specified for ASME Cr,de materials and component The Level 2 actions which the licensee specified for correction of this matter were verified complete in NRC Inspection 325, 324/90-4 However, that inspection found that the effectiveness of the actions taken in correcting the original concern had not been verified by the licensee and the IFI was left ope .

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In the current inspection the licensee was found to have recently completed an assessment of the effectiveness of the actions previously taken and determined that they could not demonstrate effective resolution of the original concern. This was documented in two internal licensee memos from R. Helme to W. Simpson dated May 6 and May 8,1991. The latter memo stated that it appeared that additional time would be required to reevaluate and enhance the actions to resolve IAP item D4. The memo also indicated that followup on this item had been inadequate and that Adverse Condition Report B-91-224 had been issued to identify this deficiency. The memo requested the reopening of this IAP summary item, which had previously been considered complete by the license Based on the licensee's determination that their actions had not been adequate to resolve this item, it will remain ope e. (0 pen) IFI 50-325, 324/89-34-23: Followup on Implementation and Effectiveness of Corrective Action Program Improvements in IAP Item D9, (Ref. 2.1.1.7, 2.1.3.8, and 2.1.5.2, and 2.1.6.14)

This IFI represents DET concerns that the corrective action program I at Brunswick was inadequate due to weaknesses in problem '

identification, cause determination, and prompt development and implementation of corrective actions. The licensee's Level 1 IAP action item to address this matter was " implement corrective action program improvements". Seven Level 2 action items were established to accomplish the improvements. NRC Inspection 325, 324/90-31 determined that these Level 2 items had all been completed. However, reservations were expressed regarding' the effectiveness of the actions and the IFI was not close To determine whether the programmatic actions implemented by the licensee were effective in improving the corrective action program and resolving the weaknesses identified by the NRC DET, the-inspectors held discussions with licensee personnel responsible for l coordinating and monitoring the program, verified examples of Adverse '

Condition Reports generated by the program, and reviewed licensee reports relating to the effectiveness of the program. The inspectors found that the program was officially implemented at the end of 1990, it had resulted in the identification of a large number of problems, a large backlog of problems requiring resolution had resulted, and the effectiveness of the program remained in question. An effectiveness review conducted by the licensee's Nuclear Assessment Department in March 1991 (memo from M. Bradley to W. Simpson dated April 16, 1991) concluded that the program was " marginally effective" and that the IAP item should remain open pending further evaluatio Licensee corporate corrective action program personnel stated that they considered that the effectiveness of the program (site and corporate) could not be adequately judged at this early stage but that its effectiveness should be apparent by the end of 199 l

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The inspectors concluded that this IFI should remain open. They

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informed the licensee that they considered that the following areas, l in particular, required further attention:

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l (1) It appeared that there was inadequate staff to accommodate the l increased workload generated by the corrective action program, I especially in its current developmental stage.

! (2) Better methods of monitoring the effectiveness of the program were needed. For example, it appeared that the negative effects of backlog and imbalances in the distribution of backlog among organizations were not being adequately recognized, (0 pen) IFI 50-325, 324/89-34-24: Followup on Implementation and Effectiveness of Institutionalization of Corporate Corrective Action Program in IAP Item D10, (Ref. 2.1.1.7, 2.1.3.8, and 2.1.5.2)

This IFI represents a DET concern that the licensee had no corporate involvement in the corrective action program to provide oversight and direction and assess its effectiveness. The licensee's !evel : IAP action item to address this matter was " develop and instiutionalize-corporate corrective action program". Two Level 2 items were specified to accomplish the Level 1 item. The first was to estab'.'sh a group to develop the program and the other was for the group to complete the task. The inspectors verified that both Level 2 tasks had been completed through review of related documentation (e.g.,

Nuclear Generation Group Manual Group Guideline NGGM 405-04, Corrective Action Program) and discussions with the involved corporate personnel. The inspectors found, however, that the program had not been fully implemented. For example, the corporate level staff for the program had not been fully identified. As indicated in 2.e above, licensee personnel informed the inspectors that they expected to be able to measure the effectiveness of the program by the end of 1991. Pending licensee demonstration of the effectiveness of the corporate program, the IFI associated with this IAP item will remain ope . Evaluation of Concerns Reported to the NRC by a Former Licensee Employee Temperature Recorder B32-TR-R625 In response to concerns expressed by a former licensee employee, the inspectors performed a review to determine if temperature recorder TR B32-TR-R625 is properly calibrated and maintained. This equipment is part of the motor-generator (M-G) set instrumentation and serves to protect the M-G set from abnormal operating conditions and for l monitoring the unit performance.

l l Copper-constantan calibration ISA Type T thermocouples are furnished to monitor the temperature of each bearing of the M-G set drive motors, generators and variable speed converters, and of the oil

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temperature from the oil coole The output of each sensor is recorded on multipoint recorder B32-TR-R62 Any temperature exceeding a predetermined level will actuate an alarm.

j Recorder B32-TR-R625 records the following information:

i MONITORING INSTRUMENTATION 4 B32 - R625

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INSTRUMENT FUNCTION POINT NO.

! M-G Set A Fluid Drive Impeller 1

Outboard Bearing Temperature

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M-G Set A Fluid Drive Impeller 2 Inboard Bearing Temperature M-G Set A Fluid Drive Runner 3 Outboard Bearing Temperature M-G Set A Fluid Runner 4 j Inboard Bearing Temperature M-G Set A Fluid Drive Oil From 5 011 Cooler Temperature

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M-G Set A Drive Motor Output 6 Shaft Bearing Temperature

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M-G Set A Drive Motor Exciter 7 End Bearing Temperature

M-G Set Generator Input Shaft 8 l Bearing Temperature  ;

M-G Set A Collector End 9 Bearing Tenperature M-G Set B Fluid Drive Impeller 13 Outboard Bearing Temperature T

M-G Set B Fluid Drive Impeller 14

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Inboard Bearing Temperature

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a K-G Set B Fluid Drive Runner 15 l Outboard Bearing Temperature M-G Set B Fluid Runner 16

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Inboard Bearing Temperature

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l M-G Set B Fluid Drive Oil 17 From 011 Cooler Temperature

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M-G Set B Drive Motor Output 18 Shaft Bearing Temperature 1

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M-G Set B Drive Motor Exciter 19 Bearing Temperature M-G Set B Generator Input Shaft 20 Bearing Temperature f

M-G Set B Generator Collector End 21 Bearing Temperature Points 10, 11, 12, 22, 23, and 24 are installed spare Procedure OPIC-TR002, Calibration of Type W Leeds and Northrup Multipoint Recorder, provides instructions for calibration of this equipmen The licensee has also provided Preventive Maintenance Instruction OPM-VR013 for performing PM on this recorder. The calibration procedure requires a record of the as-found and the as-left values

, for each active poin The results of several past calibrations were reviewe Little or no .

difference was noted between as-found and as-left value '

Galibrations are done at a 6-month frequency. The signals to the recorder came from thermocouples and when a thermocouple fails the signal causes the recorder to go extreme up or down scale. On

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occasion some other problem, such as a broken cord or malfunctioning ink pad, may require maintenanc After such maintenance a calibration is performed. The calibration data sheets were reviewed for both Units for the period from present back to 198 A question was raised about verification of each point on the recorder with respect to the thermocouple function. The former

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employee stated that points on Unit I had been verified, but not for Unit Verification should have been performed during the original

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installation. Since this equipment is considered balance-of-plant and is not safety related, the NRC inspection performed during

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construction would not have covered this activity. If a connection

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error had been made, it is likely it would have been detected through d

the years as maintenance on the system has been performe If error had not been detected the consequence is not a safety concern, but more of an operability concern. The plant cannot operate without a

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reliable M-G se After this inspection effort was completed the inspectors questioned if the effort was directed to the correct recorder, since no problems

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a licensee representative and it was concluded that recorder  !

B32-TR-R601 was more likely the area of concern since there have been

< some problems with R601 in the past, R601 monitors performance of

the recirculation pumps rather than the M-G set. Therefore, during a j future inspection, recorder TR601 will be reviewed to determine its

, performance, b. Recirculation Pump Shaft Seals The recirculation pump shaft seal assembly consists of two seals j built into a cartridge which can be readily replaced without removing '

the motor from the pump. The seal assembly is designed for minimum maintenance over a long period of time. Each individual seal in the cartridge is capable of . sealing against pump design pressure so that any one seal can adequately limit leakage in the event that the other ]

seal should fail. A breakdown bushing is provided in the pump casing '

to reduce leakage in the event of a gross failure of both shaft seal Provision is made for monitoring the pressure drop across each individual seal, as well as the cavity temperature of each sea Instrumentation is provided to alarm on high seal leakage. If both seals were to fail, the associated loss of inventory is assumed to be about 50 to 60 gpm. This size of inventory loss is considered to be bounded within the Loss-of-Coolant Accident Analysis which is i discussed in FSAR Section 15. ]

On those occasions where one of the two seals has degraded, the licensee prepares an Engineering Evaluation Report (EER). This  ;

report describes the justification for continued operation until the l degraded seal can be replaced. The EER typically uses the assumed leakage of 50 to 60 gpm and states that the margin of safety has not changed to permit continued reactor operation. The former employee '

stated that he was uncomfortable using a flow value that did not have a rigorous technical analysis. This justification is acceptable since, by design, one seal is considered acceptable. If the leakage exceeds the assumed 50 to 60 gpm by an order of magnitude, continued operation would not be possible due to excessive loss of inventor Therefore, a rigorous analysis of the leakage upon loss of both seals is not considered absolutely necessary. The origin of the assumed leakage rate is believed to be the pump manufacturer. By design the breakdown bushing will limit the leakage to an acceptable amoun c. Hydraulic Control Units (HCUs) - Cartridge Valve V-111 The function of the Cartridge Valve V-111 is to provide a method to isolate the gas side of the accumulator for gas pre-charging and to isolate portions of the accumulator instrumentation for periodic servicing. These valves do not perform any active safety functio They are manual isolation valves and are unique in that they are not used elsewhere in the plant in other systems. The valves are interchangeable from one HCU to another. These valves are on the Q-List and Q-Parts are used when a valve is to be refurbished. They are also required to be kept in a Q-List storage are .., .-

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A former employee of the licensee expressed a concern to the NRC that these valves were designated as non Q-Listed on an Engineering

Evaluation Report. The inspectors located the EER and could not find

. where these valves are designated as non-Q-List. EER No. 88-0520

clearly shows that the valves are Q-List and were treated as such.

The EER states that 25 control Rod Drive HCU cartridge valves were

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removed from Unit 2 and replaced with new valves from stock. The removed valves were stored in the Hot Maintenance Shop since they j were contaminated.

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The 25 valves on Unit I were to be replaced, but new replacements could not be delivered in time. Therefore, the 25 valves from Unit 2 ,

were rebuilt in the Hot Shop under work request WR/JO 88-BDHH1 and l were used as replacements for the Unit 1 HCUs. Q-List parts were used during the refurbishment and the rebuilt valves were stored in the Q-List storage area within the Hot Shop until their installation 1 as Unit 1. Since installation, no work requests have been issued for i these valves on either Unit 1 or Unit 2. This indicates there has been no problem with their performanc A copy of work request WR/JO 88-BDHH1 was obtained and reviewed by the inspector The request states that these valves are on the ,

Q-List and the replacement parts were also Q-List item ' Exit Interview The inspection scope and findings were sumarized on May 24 and 30,1991, I with those persons indicated in paragraph I above. Licensee management was informed of the closure of a violation and two IAP-related IFIs described in paragraph 2. The inspectors stated that three other IAP-related IFIs examined during the inspection would remain open pending demonstration of the effectiveness of the actions taken to correct the associated weaknesse The inspectors noted their concern that the licensee make further efforts to develop and utilize methods to demonstrate both the initial and the ongoing effectiveness of their IAP action items. Particular mention was made of the need to monitor and correct any resource deficiencies apparent in their new corrective action progra Licensee management was informed that a former employee's concerns regarding three pieces of equipment had been evaluated. The concerns for two of the equipment items were determined unsubstantiated but the third will require further NRC review, as described in paragraph 3. The licensee did not identify any of the material used in this report as proprietary. No dissenting coments were received from the license . Acronyms and Initialisms ASME - American Society of Mechanical Engineers BESS - Brunswick Engineering Support Section BNP - Brunswick Nuclear Project BSP -

Brunswick Site Procedure CD0 - Central Design Organization

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' 14 CP&L - Carolina Power and Light Company DET - Diagnostic Evaluation Team EER - Engineering Evaluation Report FR -

Field Revision FSAR - Final Safety Analysis Report GL -

Generic Letter gpm - gallons per minute HCU - Hydraulic Control Unit IAP - Integrated Action Plan IFI - Inspector Followup Item ISA - Instrument Society of America LLRT - Local Leak Rate Test M0V - Motor-Operated Valve NAD - Nuclear Assessment Department NED -

Nuclear Engineering Department NRC - Nuclear Regulatory Commission PM -

Preventive Maintenance Type C -

Alternate Name for LLRT

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