ML20101K641
| ML20101K641 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/21/1984 |
| From: | Dietz C CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20101K615 | List: |
| References | |
| NUDOCS 8412310430 | |
| Download: ML20101K641 (3) | |
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COAL ko e-Carotina Power & Light Company HUV d{i p g *,
BrunswickSteam2[ctricPlant P. O. Box 10429 Southport, NC 28461-0429 FILE:
B09-13510C SERIAL: BSEP/84-2472 Mr. James P. O'Reilly, Administrator U.S. Nuclear Regulatory Commission Suite 2900 104 Marietta Street, hV Atlanta, GA 30323 BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS
Dear Mr. O'Reilly:
The Brunswick Steam Electric Plant (BSEP) has received I&E Inspection' Report 50-325/84-27 and 50-324/84-27 and finds that it does not contain information of a proprietary nature.
This report identified one item that appeared to be in noncompliance with NRC requirements. Enclosed please find Carolina Power & Light Company's response to this violation.
Very truly yours, ig C. R. Dietz, General Manager Brunswick Steam Electric Plant TEC/clh/ LETCH 1 Enclosure I
cc:
Mr. R. C. DeYoung i
NRC Document Control Desk l
l 8412310430 841103 PDR ADOCK 05000324 0
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- 6 s RESPONSE TO VIOLATION.
INSPECTION REPORT 50-324/84-27 AND 50-325/84-27 i
l Violation (Severity Level V) 10CFR50.59(b) requires a safety evaluation which provides the bases for the determination that the change (to the facility) does not involve an unreviewed safety question; 50.59(a)(2) states, "a change involves an unreviewed safety question if the probability of.
. malfunction of equipment important to safety... may be increased."
Contrary to the above, an inadequate safety evaluation was performed prior to removing the automatic minimum flow capability from the core spray systems on Unit 1 during the period June 1-9, 1984. The removal increased the probability of malfunction of equipment important to safety for certain conditions under which the pumps could have been called upon to perform a safety function.
Response
1.
Admission or Denial of the Alleged Violation Carolina Power & Light agrees the violation occurred as stated.
2.
Reasons for the Violation The cause of this violation was a failure by plant Operations personnel to obtain a formal evaluation from plant Engineering prior to making the decision not to declare the core spray pump inoperable when the involved minimum flow valves were secured shut.
The evaluation which was performed was an expedited, informal evaluation based on the knowledge and experience of the personnel involved.
Although it was recognized that the possibility of some pump degradation, particularly to the pump seals, could occur, it was concluded that sufficient time would exist for operator action to open the minimum flow valves.
It should be noted that the Limiting Conditions for Operation (LCOs) involved relatively short time frames (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, Technical Specification 3.6.1.1; 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, Technical Specification 3.5.3.1).
3.
Corrective Action Which Has Been Taken Appropriate plant Operations personnel have been directed to use formal communication channels when obtait.ing Engineering evaluations required to support actions associated with operaaility decisions involving safety-related equipment.
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- 4. ' Corrective Action Which-Will Be Taken a) Real time training will be conducted relative to this event.
This training will include a discussion of this event as well as. generic training associated with the consequences of misaligning minimum flow bypass valves.
-b)
The Engineering Evaluation Procedure (ENP-12) will be revised to require consultation with the vendor for evaluations which address modes'of equipment operation which have the potential for degrading the equipment.
5.
Date for Full Compliance Full compliance has been achieved relative to this event. The additional corrective actions specified in Item 4 above shall be completed by March 31, 1985.
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