ML20138J586

Notice of Violation from Insp on 970303-0404.Violation Noted:Effect of Improperly Installed Seals for Installation of Rosemount Transmitters 2-G31-FT-N012,N036 & N041 Was Not Evaluated for 30 Days Reportability Requirement to NRC

ML20138J586
Person / Time
Site:	Brunswick
Issue date:	05/02/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138J568	List: ML20138J564 ML20138J586 ML20138J598
References
50-324-97-03, 50-324-97-3, 50-325-97-03, 50-325-97-3, NUDOCS 9705080264
Download: ML20138J586 (2)

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l NOTICE OF VIOLATION Carolina Power and Light Company Docket Nos. 50-325 and 324 Brunswick Nuclear Plant License Nos. DPR-71 and DPR-62 During an NRC inspection conducted from March 3 through April 4,1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings. Paragraph 5.14.5.1 of CP&L Procedure ORCl-06.1, Reportable Event Evaluation Criteria and Processing, Revision 13, dated June 20, 1995, requires potentially reportable events to be evaluated to determine if they are required to be reported to NRC under 10 CFR 50.73.

Contrary to these requirements, the effect of the improperly installed seals for the installation of Rosemount transmitters, numbers 2-G31-FT-N012, NO36, and N041, on the operability of the Unit 2 reactor water cleanup system was not evaluated for the 30 day reportability requirement to NRC.

This is a Severity Level IV Violation (Supplement I) applicable to Unit 2 (Docket No. 50-324) only.

B. 10 CFR 50, Appendix B, Criteria V requires that activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings. CP&L Procedure OIA-109, Performance of Nuclear Safety Reviews, Revisions 5 through 7, specifies the requirements for performance of safety reviews. Section 5.4 of OIA-109 specifies the requires use of Attachment C of OIA-109 to classify items affected by any proposed activity / change to the facility. Paragraph 5.4.1 of OIA-109 and Question 1 of Attachment C to OIA-109 asks whether the item, Engineering Service Request (ESR), requires a revision to the UFSAR. ESRs that affect the UFSAR are required to be processed in accordance with CP&L procedure ORCI-04.1, FSAR Changes. The purpose of procedure ORCI-4.1 is to update the UFSAR for submittal to NRC per 10 CFR 50.71(e).

Contrary to these requirements, Question 1 of Attachment C was incorrectly answered "No" when attachment C was completed for ESR 96000107. This resulted in failure to update UFSAR figure 8.3.1-9 to reflect the changes caused by the ESR.

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

Enclosure 1 9705080264 970502 PDR ADOCK 05000324 G PDR

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Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby j required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN

Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region ll, and a copy to the NRC Resident inspector at Brunswick Nuclear Plant within 30 days of the date of the letter transmitting this Notice of Violation Motice). This reply should be clearly marked as a " Reply to a Notice of Violation" and

, n'1ould include for each violation: (1) the reason for the violation or, if contested, the basis l

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ior disputing the violation, (2) the 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 i date when full compliance will be achieved. Your response may reference or include

previous docketed correspondence, if the correspondence adequately addresses the required i response. 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.

i Where good cause is shown, consideration will be given to extending the response time.

3 Because your response will be placed in the NRC Public Document Room (PDR), to the 3 extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide

]; a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request i withholding of such material, you must specifically identify the portions of your response that ,

you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal i

privacy or provide the information required by 10 CFR 2.790(b) to support a request for with-

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holding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

i Dated at Atlanta, Georgia this 2nd day of May 1997 4

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