BSEP-82-1952, Responds to NRC Re Violations Noted in IE Insp Repts 50-324/82-26 & 50-325/82-26.Corrective Actions:New Comprehensive post-testing Program Being Developed
| ML20063P713 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/13/1982 |
| From: | Dietz C CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20063P708 | List: |
| References | |
| BSEP-82-1952, NUDOCS 8210150106 | |
| Download: ML20063P713 (2) | |
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Tim?.?SA C9&L Carolina Power & Light Company A S 19 82 SEP 16 Brunswick Steam Electric Plant P. O. Box 10429 Southport, NC 28461-0429 September 13, 1982 FILE:
B09-13510E SERIAL: BSEP/82-1952 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street N.W.
Atlanta, GA 30303 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS
Dear Mr. O'Reilly:
The Brunswick Steam Electric Plant (BSEP) has received IE Inspection Report 50-324/82-26 and 50-325/82-26 and finds that it does not contain any information of a proprietary nature.
The report identified one item that appears to be in noncompliance with NRC requiretrents. This item and Carolina Power and Light Company's response is addressed in the following text:
Violation:
(Severity Level IV) 10CFR50, Appendix B, Criterion XIV, and the Accepted Quality Assurance Program (letter to Eisenhut from Utley, Serial Number 0QA-81-026, dated March 18, j
1981) requires that measures provide for identification of items which have satisfactorily passed required inspections and tests, where necessary, to preclude inadvertent bypassing of such inspections and tests. The Accepted Quality Assurance Program endorses Regulatory Guide 1.33, 1972, and ANSI N18.7-1976. Section 5.2.6 of ANSI N18.7 requires, when equipment is ready to l
be returned to service, operating personnel shall place the equipment in operation and verify and document its functional acceptability.
Corrective Maintenance Procedure MP-14 implements this requirement by having the Shift Foreman identify on the work request all testing that will be required to demonstrate operability following maintenance.
1.
Contrary to the above, eight work requests associated with corrective j
maintenance which had been parformed on containment isolation valves were reviewed, and testing to be perforced following maintenance was not specified. On each work request, the space provided for required testing 8210150106 820924 PDR ADOCK 05000324 G
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had been marked not applicable by a Shift Foreman.
Four of the eight valves were returned to service without operability testing. All eight work requests were signed by a Shift Foreman signifying final acceptance i
of the work and satisfactory demonstration of valve acceptability.
2.
Contrary to the above, measures have not been established to assure that all required testing will be performed at a later date when conditions do not permit appropriate testing at the time maintenance work is completed.
As indicated in Item 1 above, existing measures did not preclude bypassing requires tests.
Carolina Power and Light Company's Response Carolina Power and Light Company acknowledges that its post maintenance testing program violates NRC requirements. Administrative oversight during the development of the postmaintenance testing program allowed the identified discrepancies to evolve.
To correct the postmaintenance testing problems identified in this report and to assure future compliance, a completely new comprehensive testing program is being developed. This program will be designed to ensure that both postcorrective maintenance and postpreventive maintenance requirements are satisfied. 'lhis program, to be elucidated in MP-10 and MP-14, and the required training for those personnel responsible for its implementation will be completed prior to the startup of either unit.
Very truly yours, iQ C. R. Dietz, General Manager Brunswick Steam Electric Plant RMP/gvc Enclosure cc:
Mr. R. C. DeYoung
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