ML20059L044

Corrected Notice of Violation from Insp on 930726-0903. Violation Noted:Nrc Identified That Instructions Specified in WR Wr/Jo 93-AFNW1 for Repairs to Unit 1 Drywell Liner Plate Were Not Appropriate to Evaluate

ML20059L044
Person / Time
Site:	Brunswick
Issue date:	11/10/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059L032	List: ML20059L027 ML20059L044
References
50-324-93-31, 50-325-93-31, NUDOCS 9311160285
Download: ML20059L044 (2)

Text

t ENCLOSURE 1 NOTICE OF VIOLATIOW Carolina Power & Light Co. Docket Nos.: 50-325 and 50-324 Brunswick License Nos.: DPR-71 and DPR-62 i During an NRC inspection conducted on July 26 - September 3,1993, violations j of NRC requirements were identified. In accordance with the " General State- i ment of Policy and Procedure for NRC Enforcement Actions," the violations are ,

listed below:

A. 10 CFR 50, Appendix B, Criterion V, requires that activities affecting l quality be prescribed by documented instructions or procedures and shall  :

be accomplished in accordance with these instructions or procedures.

Paragraph 6.6.1 of CP&L engineering Procedure ENP-33.5 requires that safety-related classification of items be based on the functional analysis of design basis events and licensing commitments specified in i licensing basis documentation, i.e., FASR, Technical Specifications, etc. t Contrary to the above, on July 29 and 30, 1993, backfill materials placed  !

over and around a safety-related portion of replacement service water piping was not classified as safety-related in accordance with the  ;

requirements of ENP 33.5. A functional analysis of the requirements for .

the backfill was not performed to determined safety classification for '

the backfill in consideration of design basis events and FSAR commit-  ;

ments. FSAR Section 2.5 indicates the backfill in the plant area was safety-related.

This is a Severity Level IV violation (Supplement 1).

B. 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions or procedures of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions or procedures.

Contrary to the above, on July 26, 1993, NRC identified that the instructions specified in Work Request WR/JO 93-AFNW1 for repairs to the Unit I drywell liner plate were not appropriate to evaluate and repair severely corroded areas of the liner. As a result, approxi-mately 47 areas of the liner which were below minimum wall thickness had not been identified, more than half of the corrosion on the liner had not been removed and evaluated, and new protective coat-ings had not been applied to more than half of the corrosion affect-ed areas. This violation is applicable to Unit 1 only.

l This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company 1

is hereby required to submit a written statement or explanation to the U. S.

9311160285 931110 PDR O ADOCK 05000324' PDR 2

a 2

Carolina Power & Light Co. Docket Nos.: 50-325 and 50-324 i Brunswick License Nos.: DPR-71 and DPR-62  ;

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D. C.

20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facility that is the subject of this' Notice, 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 j 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 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.

Dated at Atlanta, Georgia this 10th day of November 1993 F

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