ML19332C727
| ML19332C727 | |
| Person / Time | |
|---|---|
| Site: | Brunswick |
| Issue date: | 11/06/1989 |
| From: | Verrelli D NRC Office of Inspection & Enforcement (IE Region II) |
| To: | |
| Shared Package | |
| ML19332C725 | List: |
| References | |
| 50-324-89-26, NUDOCS 8911280475 | |
| Download: ML19332C727 (2) | |
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ENCLOSURE 1 NOTICE OF VIOLATION Carolina Power and Light Company Docket No. 50-324 Brunswick Unit 2 License No. DPR-62 l
During the Nuclear Regulatory Commission (NRC) inspection conducted on September 1 - October 1,1989, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC 1
Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the violations are listed below:
A.
Technical Specification 6.8.1.a reauires that written procedures be established, implemented and maintained for safety-related BWR systems, i
Operating Procedure 2-0P-13, Fuel Pool Cooling and Cleanup System.
Revision 31, provides the system valve lineup for the fuel pool cooling and cleanup system, a safety-related system. to the procedure specifies the normal position for valve 2-G41-F021 as closed.
01-13 Valve and Electrical Lineup Administrative Controls, Revision 25, Section 4.8.4 requires that the on file valve exception forms be filled out whenever a valve is out of its normal OP lineup, and not controlled by procedure or clearance.
Contrary to the above, Operating Instruction 01-13 was inadequately implemented in that, from September 10, 1989 until September 15, 1989, valve 2-G41-F021 was open instead of closed as required by 2-0P-13 with no other documentation of the valve's position as required by 01-13.
This is a repeat violation.
This is a Severity Level IV violation (Supplement I).
B.
Technical Specification 6.8.1.a requires that written procedures be established covering the activities recommended in Appendix A of Regulatory Guide 1.33, November 1972. Appendix A, Section A-3, recommends procedures for equipment control (i.e., locking and tagging).
l l
Administrative Instruction Al-58 Equipment Clearance Procedure, step l
5.3.7.3 requires that, when tags on valves / controls have been properly affixed, a second operator shall perform an independent verification to ensure that the tagging has been properly performed.
Contrary to the above, Al-58 was inadequately implemented in that, on September 21, 1989, tag number 6 of Local Clearance 2-1149 (clearance for B loop RHR), for valve 2-E11-F075, Service Water Injection, was removed and rehung subsequent to original placement without additional independent verification.
l This is a Severity Level IV violation (Supplement I).
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Carolina Power and Light Company 2
Docket No. 50-324 Brunswick Unit 2 License No. DPR-62 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 Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region 11, and a copy to the NRC Resident inspector, within 30 days of the date of the letter transmitting this Notice.
This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
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.
FOR THE NUCLEAR REGULATORY COMMISSION w
Da id M.
rrelli, Chief Reactor Projects Branch 1 Division of Reactor Projects Dated at Atlanta, Georgia this 6th ay of November 1989 d
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