ML19274E617

Responds to NRC 790315 Ltr Re Violations Noted in IE Insp Repts 50-324/79-04 & 50-325/79-03.Corrective Actions: Revision of Surveillance Test,Establishment of New Procedures in Formation & Prompt Submission of LERs

ML19274E617
Person / Time
Site:	Brunswick
Issue date:	03/12/1979
From:	Furr B CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19274E614	List: ML19274E617
References
NUDOCS 7904090268
Download: ML19274E617 (3)

Text

' TT ~ ~ ~ .

~

Y

? C ft C & w g .

Carolina Power & Light Company

• Harch 12, 1979 on MAR 14 P 1 : 3'l FILE: NG-3513 (B) SERIAL: GD-79-651 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 & 2 LICENSE NOS. DPR-71 AND DPR-62 DOCKET NOS. 50-325 AND 50-324 RESPONSE TO IhTRACTIONS OF NRC REQUIREMENTS

Dear Mr. O'Reilly:

In your letter of February 15, 1979, you forwarded a copy of IE Inspection Reports 50-324/79-4 and 50-325/H-3 for the Brunswick Steam Electric Plant Unit Nos. I and 2. We have reviewed this report and find that it does not contain any information of a proprietary nature.

The report identified two items that appear ta deviate from requirements to the NRC. The items and Carolina Power & Light Company's response to them are addressed in the following text:

Infraction As required by Technical Specifications 6.5.1.3.A, the Plant Nuclear Safety Committee (PNSC) is responsible for reviewing the written procedures required by Specification 6. 8. Technical Specification 6.8.1.a requires that the applicable procedures of Appendix "A" of Regulatory Guide 1.33 1972 shall be established.

Regulatory Guide 1.33, " Appendix "A," Section H.2.b(5) lists surveillance test procedures for the standby gas treatment system tests including filter tests.

Contrary to the above, the PNSC did not review the contractor's procedure for performing the surveillance tests of the standby gas treatment system filters and absorbers prior to the performance of the tests in October,1978.

Noc'/;L>

Omc1AL copy 7 9 0 4 0 9 0 Scog 411 Fayettevdie Street

• P O Boi 1551

• Ra'e.g%. N C 27602

-2 March 12, 1979 Mr. James P. O'Reilly L ,I h

CP&L Response

~

The lack of review by PNSC was an administrative oversight. The A

purchase requisition required that the procedure be performed in accordance with ANSI-N510-1975 and Regulatory Guide 1.52, Revision 1, July 1976. This requirement is per the Technical Specifications.

The contract procedure was used to fulfill the requirements of surveillance test PT 15.1. This surveillance test is being revised to The incorporate the possible future use of contracted procedures.

revision will ensure that a contracted procedure will completely satisfy the requirements of PT 15.1, and that PNSC has reviewed the procedure prior to use. The revision to this periodic test will be complete by June 30, 1979.

Deficiency As required by 10 CFR F .205(a)(4), the licensee is required to make a written report to the NRC within 30 days for any incident for 10 CFR which notification was required by 10 CFR 20.403.

20.403(b)(1) requires that the licensee shall notify the NRC of any incident which may have caused or threatens to cause an exposure to the whole body of 5 Rems or more. On November 30, 1978, the licensee notified NRC, Region II by telephone and a facsimile of an incident which may have caused an exposure to the whole body in excess of 5 Rems to an individual as determined by the licensee on that date.

Contrary to the above, the licensee did not submit the written report required by 10 CFR 20.405(a)(4) within the required 30days 1979, 37 days.

The written report was submitted on January 5, following the incident.

CP&L Response On November 29, 1978, it appeared that an individual had received an exposure to the whole body in excess of 5 Rem. After a preliminary investigation, we reported to the NRC in accordance with 10 CFR 20.403(b)(1) on November 30, 1978.

] g "

2 j Following the initial reporting by telephone, a.more. detailed 7 investigation was ;:onducted. It was revealed that the individual had

" l purposely exposed his T1.D and that his indicated dose was not his true l dose. The investigation and confidential report were completed on j December 22, 1978. This change in the situation plus delays in routing and approval due to the holiday period caused the report to be {

late.

March 12, 1979

.. Mr. James P. O'Reilly _.

The personnel involved have been counseled on the necessity to the required reports. A procedure is now being promptly submitwritten to give guidance in the formation of IIR's and will establish a guideline for ensuring that all IIR's are submitted in an expeditious manner. This new procedure will be complete by April 30, 1979.

Yours very trul ,

B. J. Furr Manager

' ~ ~ ~ Generation Department DCS/RMP/jpv*

.y,