ML14176A637
| ML14176A637 | |
| Person / Time | |
|---|---|
| Site: | Robinson |
| Issue date: | 06/01/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A633 | List: |
| References | |
| 50-261-81-15, NUDOCS 8107240242 | |
| Download: ML14176A637 (2) | |
Text
APPENDIX A NOTICE OF VIOLATION Carolina Power and Light Company Docket No. 50-261 H. B. Robinson 2 License No. DPR-23 As a result of the inspection conducted on April 11 May 10, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980),
the following violations were identified.
A. Technical Specification 6.8.1 requires that written procedures be estab lished, implemented, and maintained to satisfy the requirements of Section 5.1 of ANSI 18.7-1972. Section 5.1 of ANSI 18.7-1972 requires that the maintenance program maintain safety-related equipment at the quality required for it to perform its intended function.
This program is implemented by Robinson Maintenance Instruction-2 and Administrative Instructions Section 2.1.30, which require plant personnel to initiate work requests to correct safety-related equipment degradation.
Contrary to the above, as of April 13, 1981, the maintenance program had not been implemented in that work requests had not been initiated on the following nonconforming conditions in the primary sampling system:
- 1. The switch controlling the containment isolation valves for the pres surizer liquid space sample was taped open due to a valve control circuitry malfunction.
- 2. The closed position indications for seven of the eight sample system containment isolation.valves were not functional.
- 3. The position indications for six of the eight other sample system valves, which are part of the reactor coolant pressure boundary, were not indicating properly.
This is a Severity Level IV Violation (Supplement I.D.3). A similar matter was brought to your attention in our letter of September 16, 1980.
(IE Inspection Report 50-261/80-21).
B.
Technical Specification 3.6.1.a. requires that containment integrity shall not be violated unless the reactor is in the cold shutdown condition.
As defined in paragraph 1.7 of Technical Specifications, containment integrity requires that all automatic containment isolation trip valves required to be closed during accident conditions are operable or secured closed.
/Contrary to the above, on April 13 and 14, 1981, during power operation, the V switch for the two containment isolation valvesjfor the pressurizer liquid space sample~was taped open for sampling) (making the valves unable to respond automatically to a containment isolation signal.
81PO242 050707 IPDR ADOCK 05000261
Carolina Power and Light Company 2
Docket No. 50-261 Notice of Violation License No. DPR-23 This is a Severity level V Violation (Supplement I.E.).
C. Technical Specificaiton 4.4.3 requires that the residual heat removal system be tested for acceptable leakage rates on a twelve month interval.
This surveillance requirement is implemented by Plant Periodic Test 14.0, Residual Heat Removal System Integrity Test (Annual).
Contrary to the above, as of April 13,
- 1981, Periodic Test 14.0 had not been conducted annually and had been overdue as of February, 1981.
This is a Severity Level V Violation (Supplement I.E.).
D. Technical Specification 4.4.2.a requires that containment isolation valves be tested for operability at each refueling. Operability requires that the valves be capable of performing their intended function. As stated in FSAR Tables 5.2.2 -
1E and 1H, the letdown line and the containment air sample lines are automatically isolated on a Phase A Containment isolation signal.
Contrary to the above, as of April 15,
- 1981, no surveillance procedure verifies that the containment isolation valves for the letdown line and for the containment air sample lines properly respond to a phase A containment isolation signal.
This is a Severity Level VI Violation (Supplement I.F.).
Pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within twenty-five days of the date of this Notice, a written state ment or explanation in reply, including: (1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
Date: _
.0I