ML14178A141
| ML14178A141 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/23/1991 |
| From: | Verrelli D NRC Office of Inspection & Enforcement (IE Region II) |
| To: | |
| Shared Package | |
| ML14178A140 | List: |
| References | |
| 50-261-91-17, NUDOCS 9109100067 | |
| Download: ML14178A141 (2) | |
Text
ENCLOSURE 1 NOTICE OF VIOLATION Carolina Power and Light Company Docket No. 50-261 H. B. Robinson License No. DPR-23 During the NRC inspection conducted on July 13 - August 9, 1991, two violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure For NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the violations are listed below:
- 1. Technical Specification (TS) 6.5.1.1.1 requires written procedures be established for test activities of safety-related equipment and activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Item 6.a of Appendix A requires procedures for combating a loss of coolant event.
Contrary to the above, written procedures were not adequately established, in that:
- a. Special test procedure, SP-1023, IVSW Leak Test of Penetration 6, Revision 0, was approved on July 10, 1991, with a limitation that would allow the plant to enter a less restrictive TS limiting condition for operation (TS 3.3.6.2) than the applicable limiting condition for operation (TS 3.0).
- b.
Loss of coolant emergency operating procedure EPP-10, Transfer to Hot Leg Recirculation, Revision 4, was not subsequently revised as required when EPP-9, Transfer to Cold Leg Recirculation, was revised on March 1, 1991.
This resulted in EPP-10 not providing adequate instructions for the establishment of an alternate hot leg injection flow path.
This is a Severity Level IV violation (Supplement I).
- 2.
10 CFR 50 Appendix B Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or
- drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Maintenance Management Manual Procedure MMM-001, Maintenance Administration Program, revision 12, section 5.3.2, requires that all maintenance activities and labor performed by maintenance craft personnel shall be initiated using proper maintenance work requests.
Contrary to the above, on July 29,
- 1991, maintenance was performed on safety-related equipment of the Safety Injection system without a proper maintenance work request.
The maintenance activity resulted in valve SI-867A, Boron Injection Tank inlet bypass valve, as well as its associated injection flow path, being declared inoperable.
This is a Severity Level IV violation (Supplement I).
9109100067 910823 PDR ADOCK 05000261 0
Carolina Power and Light Company 2
Docket No. 50-261 H. B. Robinson License No. DPR-23 Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit a written statement or explanation to the U. S.
Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, 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.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause 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.
FOR THE NUCLEAR REGULATORY COMMISSION DaviM. Ve elli, Chief Reactor Projects Branch 1 Division of Reactor Projects Dated in Atlanta, Georgia this day 23 of August 1991