ML14182A249
| ML14182A249 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 07/30/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14182A248 | List: |
| References | |
| 50-261-93-12, NUDOCS 9308060069 | |
| Download: ML14182A249 (4) | |
Text
ENCLOSURE 1 NOTICE OF VIOLATION Carolina Power and Light Docket No. 50-261 H. B. Robinson 2 License Nos. DPR-23 During an NRC inspection conducted June 28 through July 2, 1993, violations of NRC requirements were identified. According to the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:
- 1.
10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented procedures and that such activities be accomplished in accordance with these procedures.
CP&L Maintenance Management Manual Procedure MMM-006, Calibration Program, specifies the methods and procedures used in assuring the calibration of safety related instrumentation and requires in part, that in the event a calibration is found out-of-tolerance, a technical review shall be performed evaluating the effect of the out-of-tolerance parameter on plant safety and address the corrective action. The review shall be documented and filed with the completed calibration sheets.
Contrary to the above, on numerous occasions in 1991, 1992, and 1993, activities affecting quality were not accomplished in accordance with documented procedures in that the required reviews to evaluate the effects of out-of-tolerance parameters on plant safety were not performed, documented, or filed with the completed calibration sheets when the following parameters were found to be out-of-tolerance:
FI-1698C, HVH-3 Return Water Flow on October 23, 1991 DPS-1608B, North Service Water Strainer on January 7, 1993 DPS-1698A, HVH-1 Return Water Flow on October 8, 1991 DPS-1698D, HVH-4 Return Water Flow on October 8, 1991 DPS-1608A, South Service Water Strainer on January 7, 1993 FI-1698A, HVH-1 Return Water Flow on October 26, 1992 DPS-1698B, HVH-2 Return Water Flow on October 26, 1992 This is a Severity Level IV violation. (Supplement I.D.3)
- 2.
10 CFR 50.55a (a), "Codes and standards," requires, in part, that components that are classified as ASME Code Class 1, 2, and 3, must meet the inservice test requirements set forth in Section XI of the ASME Boiler and Pressure Vessel Code except in cases where an acceptable alternative has been approved by the Director, Office of Nuclear Reactor Regulation.
CP&L letter dated August 1, 1991, requested relief from the normal pump vibration testing requirements of paragraph IWP-4500 of ASME Section XI and proposed to satisfy pump vibration requirements by performing ASME/ANSI OMa-1988, Part 6. The licensee's relief request specified 9308060069 930730 PDR ADOCK 05000261 G
Carolina Power & Light Co.
2 that the acceptance criteria would be the most limiting of 2.5Vr or 0.325 in/sec for the alert range and the most limiting of 6V, or 0.7 in/sec for the required action range. In a letter dated June 1, 1992, the Office of Nuclear Reactor Regulation approved the relief request.
Contrary to the above, as of July 2, 1993, the licensee had not always established the most limiting pump vibration acceptance criteria in that the acceptance criteria for service water pumps A and B and service water booster pump B for vertical vibration velocity measurements and the acceptance criteria for service water booster pump A for the vertical and horizontal vibration velocity measurements were based on 0.325 and 0.7 in/sec instead of 2.5Vr and 6V, which would have been more limiting.
This is a Severity Level IV violation (Supplement I.D.3).
- 3.
Technical Specification 6.5.1.1, "Procedures, Tests, and Experiments,"
Subsection 1, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Rev. 2, February 1978. Appendix A, Section 6.g, requires procedures for combating emergencies and other significant events including loss of service water, and Section l.a requires administrative procedures for equipment control.
Contrary to the above, as of July 2, 1993, inadequate written procedures were established and maintained in that:
- a.
AOP-022, "Loss of Service Water," would not provide fire suppression system water as backup supply to the control room HVAC coolers following a single failure of the north service water header at a pressure below the design pressure rating of the heat exchanger.
- b.
AOP-022, "Loss of Service Water," would not provide the required Primary Water Storage Tank backup cooling water to the Safety Injection pump thrust bearings with sufficient pressure to perform it's intended safety function.
This is a Severity Level IV Violation (Supplement I.D.3).
- 4.
10 CFR 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety related functions of structures, systems, and components.
The licensee's accepted Quality Assurance Program, Section 17.2.3, requires, in part, that design changes to the facility be accomplished
Carolina Power & Light Co.
3 in a planned and controlled manner in accordance with written, approved procedures and that there is an adequate review of the suitability of material, parts, equipment, and processes which are essential to the safety related functions of structures, systems, and components.
Contrary to the above, as of July 2, 1993, the licensee had modified the pressure boundary of three safety related air-to-service water heat exchangers with a proprietary epoxy based material without evaluating the suitability of the application.
This is a Severity Level IV violation (Supplement I.D.3).
- 5.
10 CFR 50, Appendix B, Criterion III, "Design Control," requires, in part, that measures shall be established to assure applicable regulatory requirements and design bases for systems and components are correctly translated into procedures.
Contrary to the above, as of July 2, 1993, measures were not established to maintain the design basis of the safety related portion of the service water system in that:
- a.
Operating Procedures did not specify minimum positions for the component cooling water heat exchanger outlet valves. This could have allowed the non-safety related turbine building loads to remain un-isolated, reducing cooling to safety related loads such that they could not fulfill their safety related functions in response to a loss of coolant accident.
- b.
OP-903, Attachment 9.1, "Service Water System Valve Checklist,"
contained seven valves listed as open that were designated throttled on design documents and one valve listed as throttled that was designated as open on design documents.
This is a Severity Level IV violation (Supplement I.D.3).
Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission for items 1, 3, 4 and 5, ATTN:
Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, a copy to the NRC Resident Inspector, within 30 days of the date of the letter transmitting this Notice of Violation. 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 with full compliance will be achieved.
Carolina Power & Light Co.
4 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 with full compliance will be achieved.
If an adequate reply is not received in the time specified in this Notice, an order or 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. Corrective actions for the violation addressed in item 2 of this Notice have been completed and the actions reviewed by NRC representatives. Therefore, no reply to this item of the Notice is required.
Dated at Atlanta, Georgia this go day of July, 1993