IR 05000324/2004008

EA-04-076 - Final Significance Determination for a White Finding and Notice of Violation (NRC Inspection Report No. 05000324-04-008, Brunswick Steam Electric Plant)

ML041590186
Person / Time
Site:	Brunswick
Issue date:	06/02/2004
From:	Plisco L Region 2 Administrator
To:	Gannon C Carolina Power & Light Co
References
EA-04-076, IR-04-008
Download: ML041590186 (24)

Text

UNITE D STATES N U C LEAR REG U LATO R Y C O MM ISS IO N RE GI O N II une 2, 2004

SUBJECT:

FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 05000324/2004008, BRUNSWICK STEAM ELECTRIC PLANT)

Dear Mr. Gannon:

The purpose of this letter is to provide you with the Nuclear Regulatory Commissions (NRC) final significance determination for a finding at your Brunswick Steam Electric Plant involving the failure to take adequate corrective action for conditions adverse to quality associated with the No. 3 emergency diesel generator (EDG 3) jacket water cooling (JWC) system. This corrective action failure resulted in EDG 3 being inoperable for a period in excess of the Technical Specifications (TS) allowed outage time. Specifically, excessive leakage occurred from the JWC system that resulted in an inoperable EDG from December 8, 2003, until it was corrected on January 7, 2004.

The finding was documented in NRC Inspection Report (IR) 05000325/2004002 and 05000324/2004002, dated April 19, 2004, and was assessed under the significance determination process as a preliminary White issue for Unit 2 (i.e., an issue of low to moderate safety significance, which may require additional NRC inspection). The cover letter to the inspection report informed Carolina Power and Light Company (CP&L) of the NRCs preliminary conclusion, provided CP&L an opportunity to request a regulatory conference on this matter, and forwarded the details of the NRCs preliminary estimate of the change in core damage frequency (CDF) for this finding.

At your request, an open regulatory conference was conducted with you and members of your staff on May 19, 2004, to discuss your position on this issue. The enclosures to this letter include the list of attendees at the regulatory conference, and copies of the material presented by you and the NRC at the regulatory conference. During the conference, you provided the results of your review of the safety significance of the finding, root causes, and corrective actions. CP&L performed additional risk evaluations, including a human reliability analysis, a review of the EDG 3 fault exposure hours, and a review of external events. In some cases, the assumptions and inputs into your risk evaluation were different from those assumed by the NRC; however, you concluded that the results of your additional risk evaluations were insufficient to challenge the NRCs estimate that the finding was of low to moderate safety significance. In addition, CP&L agreed with the NRCs characterization of the finding as violations of regulatory requirements. CP&L also provided information regarding its investigation into the cause of the problem, and long-term corrective

CP&L 2 actions to preclude this issue in the future. CP&L determined that the root and contributing cause of the finding was the missing structural supports on the jacket water turbocharger supply line, in combination with the failure to perform post-maintenance functional verification after CP&Ls conduct of minor maintenance on the pipe coupling leakage on December 8, 2003.

After considering the information developed during the inspection and the information CP&L provided at the conference, the NRC has concluded that the final inspection finding is appropriately characterized as White for Unit 2, in the mitigating systems cornerstone.

You have 10 business days from the date of this letter to appeal the staffs determination of significance for the identified White finding. Such appeals will be considered to have merit only if they meet the criteria given in NRC Inspection Manual Chapter 0609, Attachment 2.

The NRC also determined that a violation occurred involving the requirements of 10 CFR 50, Appendix B, Criteria XVI, Corrective Action, in that CP&L failed to promptly correct a condition adverse to quality. Specifically, two structural supports located on the jacket water turbocharger supply line for EDG 3 (as indicated on Brunswick as-built Drawing No. FP-20323) were removed prior to approximately January 1, 2001 (or, as CP&L indicated at the conference, may have never been installed), and were not reinstalled until January 7, 2004. The failure to reinstall the missing supports contributed to the misalignment of the pipe coupling, and resulted in an EDG jacket water system leak on December 7, 2003. Corrective maintenance was performed on the leak on December 8, 2003, however, the leak was still present and larger on January 4, 2004. As a result, CP&L failed to comply with TS 3.8.1, in that EDG 3 was inoperable from December 8, 2003 until January 7, 2004, a period in excess of seven days. Because the failure to take adequate corrective action resulted in a failure to comply with TS, the NRC considers it appropriate to cite these as one violation. Accordingly, a Notice of Violation is included as an enclosure to this letter. In accordance with the NRC Enforcement Policy, NUREG-1600, the Notice of Violation is considered escalated enforcement action because it is associated with a White finding.

The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is adequately addressed on the docket in the information provided by CP&L at the conference (Enclosure 3). Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position.

In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.

Because plant performance for this issue has been determined to result in the increased regulatory response band, we will use the NRC Action Matrix to determine the most appropriate NRC response for this finding. We will notify you, by separate correspondence, of that determination.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosures, and your response (should you choose to provide one), will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the NRCs document

CP&L 3 system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

For administrative purposes, this letter is issued as a separate NRC Inspection Report, No. 05000324/2004008, and the above violation is identified as VIO 05000324/2004008-01:

Failure to Promptly Correct EDG Jacket Water Coolant Leakage. Accordingly, the associated apparent violations, AV 05000324/2004002-01 and AV 05000324/2004002-02, are closed.

Should you have any questions regarding this letter, please contact Paul Fredrickson, Chief, Reactor Projects Branch 4, at 404-562-4530.

Sincerely,

/RA/

Loren R. Plisco Deputy Regional Administrator Docket No.: 50-324 License No: DPR-62

Enclosures:

1. Notice of Violation 2. List of Attendees 3. Material presented by CP&L 4. Material presented by NRC

REGION II OFFICE, ATLANTA, GEORGIA I. OPENING REMARKS, INTRODUCTIONS AND MEETING INTENT L. Plisco, Deputy Regional Administrator II. NRC REGULATORY CONFERENCE POLICY V. McCree, Director, Division of Reactor Projects III. STATEMENT OF THE ISSUE WITH RISK PERSPECTIVES V. McCree, Director, Division of Reactor Projects IV. SUMMARY OF APPARENT VIOLATIONS V. McCree, Director, Division of Reactor Projects V. LICENSEE RISK PERSPECTIVE PRESENTATION VI. LICENSEE RESPONSE TO APPARENT VIOLATIONS VII. BREAK / NRC CAUCUS L. Plisco, Deputy Regional Administrator VIII. CLOSING REMARKS L. Plisco, Deputy Regional Adminstrator

Enclosure 4