EA-96-181 - Brunswick (Carolina Power & Light Company)

July 12, 1996

EA 96-181

Carolina Power & Light Company
ATTN: Mr. W. R. Campbell, Vice President
Brunswick Steam Electric Plant
P. O. Box 10429
Southport, NC 28461

SUBJECT: NOTICE OF VIOLATION (NRC Inspection Report Nos. 50-325, 324/96-09)

Dear Mr. Campbell:

This refers to the inspection conducted on May 1 through 28, 1996, at your Brunswick facility. The inspection included a review of the circumstances surrounding the dual unit shutdown initiated on March 17, 1996, due to inoperable Service Water System pumps. You notified the NRC Operations Center on March 17, 1996, of the dual unit shutdown and followed-up with Licensee Event Report No. 1-96-003, dated April 16, 1996. The results of our inspection were sent to you by letter dated June 7, 1996. A closed predecisional enforcement conference was conducted in the Region II office on June 24, 1996, with you and members of your staff to discuss the apparent violation, the root cause, and your corrective actions to preclude recurrence. A list of conference attendees, NRC slides, and a copy of your presentation materials are enclosed.

Based on the information developed during the inspection and the information that you provided during the conference, the NRC has determined that a violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation involves the failure to establish adequate design control measures for the review and testing of material changes for Service Water System modifications. Specifically, your design control program did not include provisions for a suitable testing program to verify the performance of new materials used for certain Service Water System pump components following system modifications in 1993 and 1994. As a result, on March 9, 1996, the 2A Nuclear Service Water System pump seized after the thrust ring impeller bolts failed. Following further investigation and the discovery of degraded conditions on two other pumps, the remaining Service Water System pumps were declared inoperable, an Unusual Event was declared, and both units were shut down. You subsequently determined the failure mechanism to be galvanic corrosion of the upper retaining ring Monel fasteners in proximity to stainless steel pump components.

Although your safety assessment concluded that nine of ten service water system pumps continued to meet their safety function, the violation is of significant regulatory concern because of the degraded pump conditions which resulted. The failure to select appropriate pump internal bolting material and to monitor the performance of a dissimilar material application following installation introduced a potential common mode failure mechanism into the Service Water System which went undetected for an extended period of time. During the conference, you stated that the pump replacements had undergone extensive material review since development of the original specification. However, these reviews were not well documented and failed to identify this corrosion mechanism. Notwithstanding the fact that the new material used in the pump design should have been reviewed for suitability of application, an intensive program to examine in situ material performance and condition should have been instituted beyond that normally conducted to monitor overall performance. Therefore, the violation is classified in accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity Level III violation.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considered for a Severity Level III violation. Because your facility has been the subject of escalated enforcement actions within the last 2 years,¹ the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process described in Section VI.B.2 of the Enforcement Policy. In this case, the NRC has concluded that it would be appropriate to give credit for Identification. Although the violation was revealed through an event, your initiatives to investigate and identify the cause of the March 9, 1996, pump trip were prompt and appropriate. With regard to consideration for Corrective Action, your immediate corrective actions included an evaluation which identified a potential common mode failure mechanism and led to the subsequent shutdown of both units. Additional corrective action included, in part: (1) replacement of the Monel bolts with Hastelloy C bolting; (2) review, for proper material selection, of changes to the Service Water System since 1991, as well as approved modifications awaiting installation; (3) development of a Material Selection Guide and Procedure for material application reviews; (4) conduct of an assessment of Service Water System component material selection and application to be completed by August 30, 1996; and (5) schedule follow-up inspections to evaluate the performance of the new Hastelloy bolting material. Based on these actions, the NRC determined that your corrective actions were both conservative and comprehensive and credit was warranted for the factor of Corrective Action.

Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized, after consultation with the Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.

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. 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, its enclosure, and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.

Sincerely, /s/ L. A. REYES for Stewart D. Ebneter Regional Administrator

Docket Nos. 50-325 and 50-324
License Nos. DPR-71 and DPR-62

Enclosures:
1. Notice of Violation
2. List of Conference Attendees
3. Licensee Presentation Material
4. NRC Slides

cc w/encls:
W. Levis, Director
Site Operations
Brunswick Steam Electric Plant
P. O. Box 10429
Southport, NC 28461

R. P. Lopriore
Plant Manager
Brunswick Steam Electric Plant
Carolina Power & Light Company
P. O. Box 10429
Southport, NC 28461

J. Cowan, Manager
Operations & Environmental
Support MS OHS7
Carolina Power & Light Company
P. O. Box 1551
Raleigh, NC 27602

W. D. Johnson, Vice President
and Senior Counsel
Carolina Power & Light Company
P. O. Box 1551
Raleigh, NC 27602

Dayne H. Brown, Director
Division of Radiation Protection
N. C. Department of Environmental
Commerce & Natural Resources
P. O. Box 27687
Raleigh, NC 27611-7687

Karen E. Long
Assistant Attorney General
State of North Carolina
P. O. Box 629
Raleigh, NC 27602

Robert P. Gruber
Executive Director
Public Staff – NCUC
P. O. Box 29520
Raleigh, NC 27626-0520

Public Service Commission
State of South Carolina
P. O. Box 11649
Columbia, SC 29211

Jerry W. Jones, Chairman
Brunswick County Board of
Commissioners
P. O. Box 249
Bolvia, NC 28422

Dan E. Summers
Emergency Management Coordinator
New Hanover County Department of
Emergency Management
P. O. Box 1525
Wilmington, NC 28402

Norman R. Holden, Mayor
City of Southport
201 East Moore Street
Southport, NC 28461

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NOTICE OF VIOLATION

Carolina Power and Light Company Docket Nos. 50-325 and 50-324 Brunswick Steam Electric Plant License Nos. DPR-71 and DPR-62 EA 96-181

During an NRC inspection conducted on May 1 through 28, 1996, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

10 CFR 50, Appendix B, Criterion III, Design Control, requires that measures shall be established for the review for suitability of applications of materials, parts, equipment, and processes that are essential to the safety-related functions of structures, systems and components. Design control measures shall be applied to the compatibility of materials and shall provide for verifying or checking the adequacy of design such as by the performance of design reviews or a suitable test program.

Contrary to the above, the licensee failed to establish adequate design controls measures for the verification and testing of material changes made in the Service Water System pump during modifications implemented in 1993 and 1994. Specifically, the installation of new Monel bolts in the Service Water System pumps as part of a revision to modifications 82-220L and 82-221L were not adequately reviewed for suitability of application or adequately verified to be acceptable through a suitable test program. As a result, the 2A Nuclear Service Water pump seized on March 9, 1996, after the thrust ring impeller bolts failed due to corrosion. Degraded conditions were discovered in other Service Water System pumps following disassembly. (01013)

This is a Severity Level III violation (Supplement I)

Pursuant to the provisions of 10 CFR 2.201, Carolina Power & Light Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the Brunswick Steam Electric Plant, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Atlanta, Georgia
this 12th day of July 1996

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¹A Severity Level III (SL III) violation was issued on April 4, 1996 (EA 96-054) related to the access authorization and fitness-for-duty programs. A SL III violation was issued on November 20, 1995 (EA 95-228) related to design control for the RHR Service Water System. Two SL III violations were issued on September 8, 1995 (EA 95-166) related to design control for HPCI/RCIC.