ML20148H778

Notice of Violation from Insp on 880125-29.Violation Noted: Applicable ASME Test Requirements Not Met & Procedures Did Not Contain Steps or Criteria Which Would Assure Conformance of Testing to ASME Requirements

ML20148H778
Person / Time
Site:	Brunswick
Issue date:	03/10/1988
From:	Herdt A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20148H775	List: ML20148H770 ML20148H778 ML20148H790
References
50-324-88-06, 50-324-88-6, 50-325-88-06, 50-325-88-6, NUDOCS 8803300080
Download: ML20148H778 (3)

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L ENCLOSURE 1 NOTICE OF VIOLATION Carolina Power and Light Company Docket Nos. 50-325,-324 Brunswick License Nos. DPR-71, 62 During the Nuclear Regulatory Comission (NRC) inspection conducted on January 25-29, 1988, a violation' of NRC requirements was identified. .In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below:

Technical Specification (TS) 4.0.5.a.2 requires that inservice testing of ,

ASME Code Class valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g) except where specific written relief has been granted by the Comission pursuant to 10 CFR 50, Section 50.55a(g)(6 (1). (The applicable Addenda for Brunswick is the Winter 1931 Addenda .

TS 6.8.1 requires establishment, implementation and maintenance of written procedures for performance of test activities, such as the valve testing -

specified by ASME Section_ XI. Implicit in the establishment of the procedures is that they must contain steps and criteria to assure conform-ance with the ASME test requirements. Implicit in implementing and maintaining the procedures is assuring that personnel follow the procedures and that they be alert to identify and promptly correct procedural deficiencies.

Contrary to the above, instances were identified in which the applicable ASME test requirements (W81 Addenda) were not met, procedures did not contain steps or criteria which would assure conformance of testing to the ASME requirements, personnel failed to perform the ASME valve testing in accordance with the test procedures, and knowledgeable personnel who used the procedures did not promptly identify and correct deficiencies in the Further, the Commission had apparently not granted the J procedures.

! licensee relief to deviate from the related ASME requirements. The subject instances are described below:

1. Licensee procedure PT-11.3 (Rev.12), used between November 1984 and

January 1988, specifies the ASME Section XI stroke time testing i method for air-operated valves incorrectly. Based on test data, the error results in omission of about 70% of the actual stroke time.

(Previous revisions may have also contained the error). As of

, January 1988, other licensee procedures for stroke timing air-operated valves contained a similar error.

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r Carolina Power and Light Company 2 Docket Nos. 50-325,.324 Brunswick License Nos. DPR-71, 62

2. Data from stroke time tests performed using PT 11.3 indicate that test personnel performed the timing correctly in many instances and thus, violated the procedure requirements.

3. Although the test data and statements by -test personnel indicated that many test personnel knew the correct method for stroke timing the valves in PT 11.3, the test personnel failed to identify and obtain correction of the procedural error. The error existed for at least three years and was also found in .other procedures.

4. ASME Section XI and licensee procedure ENP 16.1 specify criteria requiring stroke time testing frequency to be increased to monthly (from quarterly) when large increases in stroke time have been -

experienced. Licensee records indicate that such large increases in stroke time occurred when procedure PT 11.3 was perfonned on April 27 and July 28, 1987, but that test frequency was not increased.

5. The licensee has no procedural criteria for identifying and reporting abnormal or erratic valve actions, such as abnormal changes in stroke time. Abnormal changes in stroke time, which occurred while performing PT 11.3 during 1986 and 1987, were not identified or evaluated as such.

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

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 II, and a copy to the NRC Resident Inspector, Brunswick, within 30 days of the date 'of the letcer 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, j l

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Ca olina Power and Light Company 3 Docket Nos. 50-325, 324 Brunswick License Nos. DPR-71, 62 )

Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 CFR 73.21.

FOR THE NUCLEAR REGULATORY COMMISSION Alan R. He dt, Chief Engineering Branch Division of Reactor Safety Dated at Atlanta, Georgia, this gayof 1988

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