ML19260A782
| ML19260A782 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/05/1979 |
| From: | Banks H CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19260A780 | List: |
| References | |
| GD-79-2472, NUDOCS 7912030225 | |
| Download: ML19260A782 (5) | |
Text
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COCL 4
Carolina Power & Light Company October 5, 19 H FILE: NG-3513 (B)
SERIAL: GD-79-2472 Mr. James P. O'Reilly, Director Z
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 W
Atlanta, GA 30303 2
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1&2
,[
LICENSE NOS. DPR-71 AND DPR-62 DOCKET NOS. 50-325 AND 50-324 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS
Dear Mr. O'Reilly:
Brunswick Steam Electric Plant har. reviewed IE Inspection Report 50-324/79-19 and 50-325/79-19 and iinds that it does not contain any information of a proprietary nature.
The report identified three items which appear to be in noncompliance with NRC requirements and one item that appears to deviate from our commitment to the Commission. These items and Carolina Power & Light Company's response are addressed in the following text:
p fraction A:
Technical Specifications Section 6.9.1.9.b requires the licensee to submit to the Regional Office within 30 days of occurrence, conditions leading to operation in a degraded mode permitted by a limiting condition for operation.
1.
Contrary to the above:
The licensee's records (Limiting Condition for Operation Reports 1-79-5, 6, and 7) indicate that three containment isolation valves were determined inoperable, placing the Unit I facility in a degraded mode permitted by a limiting condition for operation. The licensee's records did not indicate that a 30-day report was submitted to the Regional Office.
2.
On February 19, 1979, during a surveillance test of the High Pressure Coolant Injection System (HPCI), the licensee determined the system had failed the test and as a result placed Unit 2 in a degraded mode permitted by a limiting condition for operation. This was not reported to the Regional Office.
1461 086 411 Fayetteville Street
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October 5, 1979 Mr. James P. O'Reilly
- k Carolina Power & Light Company's Response:
1.
All conditions leading to operation in a degraced mode as a result of a failure are treated as reportable to the Region II office. The information available to the Operating Supervisor and the Operations & Maintenance Superintendent when Limiting Conditions for Operations (LCO) Numbers 1-79-5, 6, and 7 were reviewed for reportability indicated that the valves would have performed their isolation function and that a Licensee Event Report (LER) was not required. Subsequent investigation, as reported in LER 1-79-35, revealed that these solenoid operated valves had actually stuck open, making this a reportable item.
Corrective steps had already been taken to eliminate this type of problem from occurring when this item of noncompliance was identified.
Specifically, the Operations
& Maintenance Superintendent, the Operating Supervisor, and the NFC Coordinato:- had recognized the need for additional written information on any LCO report that was questionable.
As a result, all questionable LCO's are treated as reportable until additional written information determines that it is not reportable. Full compliance with this practice was achieved in March, 1979.
This practice will be included in Engineering Procedure ENP-7 (Licensee Event Reports) by November 30, 1979.
2.
This event was not detected as a reportable event due to an administractive deficiency. The HPCI System was under an LCO for a non-reportable reason. Additional problems developed during this time which were reportable, but since plant procedures did not require another LCO to be written, the reportable problems were not presented to management for consideration of reportability.
Engineering Procedure ENP-7 (Licensee Event Reports) was written and issued on July 25, 1979, to cover the reporting of LER events, review, approval, and issue of LER's.
This procedure provides a method to prevent a similar occurrence by requiring an LCO on all problems found on safety-related equipment in normal operation or when under an LCO condition.
Additional review shows that Administractive Operating Instruction AOI-6 (LCO Evaluation and Follow-up) should be revised to include the requirements of ENP-7 for LCO's. These revisions to AOI-6 will be completed by October 31, 1979.
Infraction B:
Technical Specifications Section 6.5.1.6.e requires the Plant Nuclear Safety Committee (PNSC) be responsible for investigations of all violations of the Tehnical Specifications. Additionally, Technical Specifications Section 6.5.1.7.b requires the PNSC to render determinations in writing with regard to whether or not each item considered under Technical Specifications Section 6.5.1.6.e consti-tutes an unreviewed safety question.
1461 087
Mr. Jamer. P. O'Reilly October 5, 1979 s
Contrary to the above, the inspector found, by discussions with licensee representatives and by review of PNSC minutes, that violations of the Technical Spt.cifications which are identified in NRC inspection reports were not investigated by PNSC as required above.
Carolina Power & Light Company's Response :
As of October 1, 1979, all violations will be reviewed by PNSC as required by 6.5.1.6.e and PNSC will state in writing whether these Technical Specification violations constitute an unreviewed saf ety question. Administrative Instruction AI-9 (PNSC Administration) will be revised by November 30, 1979, to provide a format for these actions.
Infraction C:
10 CFR 50 59 (a) (1) and (2) state:
(a) (1)
The holder of a license authorizing operation of a production or utilization facility may (i) make changes in the facility as described in the safety analysis report, (ii) make changes in the procedures as described in the safety analysis report, (iii) conduct tests or experiments not described in the safety analysis report, without prior Commission approval, unless the proposed change test or experiment involves a change in the technical specifications incorporated in the license or an unreviewed safety question.
(2) A proposed change, test, or experiment shall be deemed to involve an unreviewed safety question (i) if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased; or (ii) if a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created; or (iii) if the margin of safety as defined in the basis for any technical specification is reduced.
Contrary to the above, the licensee made changes to the Quality Assurance Program as described in Section 13 of the Brunswick FSAR and had not evaluated these changes to determine if an unreviewed safety question was involved.
Carolina Power & Light Company's Response :
1.
The Plant Nuclear Safety Committee will review all past changes in the accepted QA program as required by 10CFR50.59. The accepted QA Program and changes are as follows:
1461 088
Mr. James P. O'Reilly October 5,1979
\\
a.
Section 13.4 of the BSEP FSAR b.
Janua ry 16, 1975, letter from J. A. Jones, CP&L to E. Case, USNRC.
Serial No. NG-75-080 c.
February 27, 1975, letter from-J. A. Jones, CP&L to E. Case, USNRC.
Serial No. NG-75-300 d.
August 26, 1975, letter from J. A. Jones, CP&L to B. Rusche, USNRC.
Serial No. NG-75-1278 e.
September 11, 1975, letter from J. A. Jones, CP&L to B. Rusche, USNRC.
Serial No. NG-75_1453 f.
March 30, 1977, letter from E. E. Utley, CP&L to R. Reid, USNRC.
Serial No. OQA-77-16 g.
June 22, 1977, letter from E. E. Utley, CP&L to E. Case, USNRC. Serial No. NG-77-718 h.
September 14, 1977, letter from E. E. Utley, CP&L to E. Case, USNRC.
Serial No. 0QA-77-125 i.
September 14, 1977, letter from E. E. Utley, CP&L to E. Case, USNRC. Serial No. OQA-77-79 j.
February 14, 1979, letter from E. E. Utley, CP&L to H. Denton, USNRC. Serial No. OQA-79-38 k.
April 23, 1979, letter from E. E. Utley, CP&L to H. Denton, USNRC.
Serial No. OQA-79-65 1.
April 23, 1979, letter from E. E. Utley, CP&L to T. Ippolito, USNRC. Serial No.
OQA-79-70 2.
The CP&L Corporate Quality Assurance Program, Parts 2 & 3, which implement the accepted QA program, shall be reviewed to determine if it conflicts with the accepted program. All such conflicts shall be reviewed in accordance with 10CFR50.59.
These reviews and necessary corrective actions, in the event any unreviewed safety questions are determined, will be completed by March 1, 1980.
3.
All future changes to the accepted QA program will be reviewed as required by 10CFR50.59 prior to implementation.
Deviation:
Contrary to Carolina Power and Light Company's commitment to the guidance of ANSI Standard N18.7-1972, which requires procedures to control equipment including where appropriate, independent verification that the control measures have been correctly implemented, the licensee's Administrative Procedures for controlling equipment clearance tags did not provide for an independent verification of the removal of tae clearance tags or the return of the affected system to an operable status.
Carolina Power & Light Company's Response:
Administrative Procedures, Section 11.5 (Clearances) is being revised to require an independent second verification of clearance tag removal and 1461 089
Mr. James P. O'Reilly October 5, 1979 ia system lineup. The clearance forms have been revised and sent to the printers for copies. The procedure will be revised, the forms received from the printer, and this item fully implemented by January 1, 1980.
Very truly yours, H. R. Banks Manager Nuclear Generation
-DCS/eaj*
cc:
Mr. V. Stello 1461 090