ML14176A736
| ML14176A736 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/02/1982 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A733 | List: |
| References | |
| 50-261-81-36, NUDOCS 8204010400 | |
| Download: ML14176A736 (2) | |
Text
APPENDIX A NOTICE OF VIOLATION Carolina Power & Light Company Docket No. 50-261 H. B. Robinson 2 License No. DPR-23 As a result of the inspection conducted on December 11, 1981, - January 10, 1982, 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 procedures be established and implemented that meet or exceed the requirements and recommendations of Section 5.1 of ANSI N18.7-1972. Administrative Instructions Section 6 of the Plant Operating Manual implements the ANSI requirements and requires administrative control of modifications of plant equipment. The modification procedures and Technical Specification 6.5.1.7.d. requires PNSC review and approval of modifications.
Contrary to the above, these requirements were not implemented in that the spring tension setting on the power operated relief valves (PORV's) was changed following replacement of the valve internals about May 1979 without the required administrative control, PNSC review and approval, and documentation. This modification resulted in the PORV's being removed from service during hot shutdown and power operation due to excessive seat leakage.
This is a Severity Level IV Violation (Supplement I.D.3.).
B. Technical Specification 6.8.1 requires that procedures be established, implemented, and maintained that meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A to Regulatory Guide 1.33 dated November 3, 1972.
Contrary to the above, as of November 30, 1981, plant procedures AP-19 and OP-30 described the automatic operation of the PORV's to reduce reactor pressure, and provided instruction for control of pressure transients that were either invalid or could contribute to an event when the block valves were closed. Automatic operation had been negated for nearly four years prior to November 30, 1981, because the block valves were closed to prevent known PORV leakage. The lack of formal procedures or administrative guidance, contributed to the partial depressurization event on November 30, 1981.
This is a Severity Level IV Violation (Supplement I.D.3.).
C. Technical Specification 6.5.1.7.f. requires that the PNSC review facility operations to detect potential safety hazards. FSAR Section II describes operation of the gas analyzer to prevent explosive mixtures of hydrogen and oxygen in tanks containing radioactive gases.
Plant procedures require 8204010400 820325 PDR ADOCK 05000261 PDR
Carolina Power & Light Company 2
Docket No. 50-261 Notice of Violation License No. DPR-23 operators to take corrective actions to prevent explosive mixtures based on gas analyzer sample analyses on these tanks.
Contrary to the above, during the period December 12, 1980 through November 20, 1981, the gas analyzer was consistently inoperative, and compensatory gas samples were not been taken. A PNSC review to identify and correct the potential safety hazard associated with this condition was not performed.
This is a Severity Level IV Violation (Supplement I.D.3.).
Pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including: (1) admission or denial of the alleged viola tions; (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. Consideration may be given to extending your response time for good cause shown.
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: FEB 0 1 192