ML20197H169

Notice of Violation from Insp on 970928-1108.Violation Noted:On 970923,torus Master clearance,2-97-555 Was Not Adequate to Prevent Draining of Water Into Unit 2 Torus

ML20197H169
Person / Time
Site:	Brunswick
Issue date:	12/08/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20197H167	List: ML20197H162 ML20197H169 ML20197H188
References
50-324-97-12, 50-325-97-12, NUDOCS 9712310209
Download: ML20197H169 (5)

Text

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NUTICE OF VIOLATION Carolina Power and Light Company Docket Nos. 50-325 and 50-324 Brunswick Units 1 & 2 License Nos. DPR-71 and DPR-62

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During an NRC inspection conducted from September 28 through November 8. 1997, i five 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. Technical Specification 6.8.1 requires that procedures shall be ,

established implemented. and maintained covering the activities i recommended in Appendix A of Regulatory Guide 1.33. November 1972. 1 Paragraph A of Appendix A of Regulatory Guide 1.33 requires specific l procedures for equipment u ntrol.

The Conduct of Opera +1ons Manual. Operating Instruction 001-1.09.

Eqaipment Tagging. Secti 5.1.2 requires that equipment tagging provide a high degree v personnel and equipment safety as well as maintain the status ar integrity of important plant components and systems.

Contrary to the above, equipment tagging requirements were not correctly l implemented as evidenced by the following:

1) On September 23. 1997, the torus master clearance. 2-97-555, was not adequate to prevent draining of water into the Unit 2 torus.

Water drained onto electrical power cords and welding equipment in an area where welding activities were scheduled.

2) On October 16. 1997, the Unit 2, 2B recirculation pump clearance.

2-97 1623, was not correctly implemented, when an operator did not follow the clearance by racking out the 4160 volt feed to the 2B bus instead of the 2B recirculation pump motor breaker.

3) On October 16. 1997. the Unit 2. 2B recirculation pump clearance 2 97-1623 was not adequate when seal cooling water flow was isolated to the recircu'.ation Jump seals whi k reactor coolant temperatures were 500 degrees rahrenheit, resulting in exceeding the design temperature rating of the seals.

This is a Severity level IV violation (Supplement 1). This is applicable to Unit 2.

B. 10 CFR 50 Appendix B Criterion XVI. Corrective Action, requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause cf the condition is determined and correctiv action taken to preclude repetition.

Enclosure 1 9712310209 971200 PDR ADOCK 05000324 G PDR

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CP&L 2 i Contrary to-the above, when an error was discovered in the Unit 1

• Cycle 11 minimum critical power ratio database on April 24. 1997, adequate measures were not taken to assur; that no other errors existed in the database. Additional errors were identified on September 25. 4 1997. Both errors were identified to have been present since the database was developed.

inis is a Severity Level IV violation (Supplement 1). This is app 1t cois. to  ;

both Units C. 10 CFR 50. Appendix B. Criterion XVI recuires that measures shall be established to assure that conditions acverse to quality, such as ,

failures, malfunctions.. deficiencies. deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

10 CFR 50. Appendix B. Criterion V, requires that activities -

af fecting quality be prescribed by documented instructions or procedures, and shall be accomplished in accordance with these instructions or procedures.

Carolina Power and Light Company Plant Program Procedure PLP 04.

" Corrective Action Management" implements the requirements of Criterion XVI at the Brunswick Nuclear Plant.

Contrary to the above as of the dates indicated, the licensee '

failed to assure that conditions adverse to quality were 3romptly identified and corrected and failed to follow Procedure P_P 04 as evidenced by the following:

1) Paragraph 4.2.7 of CP&L Procedure PLP-04 Revisions 19 through 23. dated October 21, 1996, through October 23.

1997, requires managers to ensure that corrective actions required to resolve condition reports are implemented.

As of October 8. 1997, managers in the EQ Organization in the Design Control Unit failed to ensure corrective actions were implemented for 18 Actior Items associated with 11 Corrective Actions (CRs). These CRs documented safety related E0 components for which environmental qualification under 10 CFR 50.49 was indeterminate.

2) Paragraph 5.4 of CP&L Procedure PLP-04 requires that corrective actions shall be tracked per CP&L Procedure PLP-04.1. Section-5.2 of CP&L Procedure PLP-04.1. Revision 7.

dated September 12. 1997, requires the responsible units to ,

complete assigned action item responses by the assigned due dates, or justify deviations from the specified actions.

Paragraph 4.2 of Procedure PLP 04.1 requires managers to assure that extensions to completion of. action item i responses beyond the due dates are justifiable and documented .

CP&L 3 As of October 8. 1997 the responsible units failed to complete the assigned action responses and Managers failed to ensure that requests for extensions were justified and documented for 11 CRs.

3) Paragraphs 4.2.2 and 6.2.2 of "&L Procedure PLP-04.

Revisions 19 through ."1. date. October 21. 1996, through A)ril 21. 1997. requires managers and personnel to ensure CRs are initiated when they became aware of adverse conditions or conditions not meeting expectations.

Managers and personnel in the E0 grono of the Design Control Unit did not initiate CRs or ensure uts were initiated for more than two months after they became aware of conditions not meeting expectations such as lack of wee) holes in EQ junction boxes, damaged gaskets on junction s oxes. and potential adverse effects of moisture on operability of E0 equipment, These conditions were identified during E0 equi) ment walkdowns completed between February 1 and Marc 1 15. 1997. CRs were not initiated to document and disposition these problems until May 23 through July 9.

1997.

4) CP&L Procedure PLP u4. Revisions 19 through 22. dated Cctober 21. 1996. thrcugh August 29. 1997, rec uires corrective actions be effective to resolve anc correct adverse conditions and conditions not meeting expectations.

Condition Reports numbers CR 96 03693, 97-01436 and CR 97-01904 document assignment of non qualified individuals to perform engineering work activities. The corrective actions to resolve the conditions where unqualified individuals were performing engineering work activities were not effective.

The lack of effective corrective actions was again documented in CR 97-03305 which concerned assignment of unqualified individuals.to perform engineering work activities.

This is a Severity Level IV violation (Supplement 1). This is applicable to both units.

D. 10 CFR 50. Appendix 0. Criterion V, requires that activities affecting cuality shall be prescribed by documented instructions, procedures or crawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings. Paragraph 9.3.7.4.9 of CP&L Procedure EGR-NGGC-0005, Engineering Service Requests. Revisions 1 through 6. dated August 2.

1996 through . Se)tember 5. 1997 requires an engineering service '

request (E$R) to >e initiated for evaluations in support of system operability (o)erability assessments). Paragraph 9.3.2.3 of CP&L Procedure EGR-9GGC-0156. Environmental Qualification of Electric E

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service request to document operability determinations and '

justifications for continued operation for any item in the E0 program -

found to be in a degraded or nonconforming condition.

Contrary to the above, as of October 8. 1997. ESRs had not been  :

prepared to document operability and justification for continued i operation for E0 equipment found in a degraded or nonctnforming t condition. (i.e., equipment important to safety for whu n environmental qualification was indeterminate) for the deficiencies / nonconforming conditions documented in seven Condition Reports.

i This is a Severity Level IV violation (Supplement 1). This is applicable to  ;

both units. e E. Technical S)ecification 6.8.1.d requires that written procedures shall '

be establis1ed, implemented, and maintained covering implementation of  :

the Security Plan.

Phys' cal Sccurity Plan Revisien 1. August 1997 states that a Member of the Security Force located within a bullet resistant structure is ,

responsible for the final access control function.

Security Instruction 05105. Security Post Duties. Responsibilities and Patrol Procedures, defines the responsibilities of the Access Control

• Person (ACP).

Contrary to the above. 0S1 05 failed to adequately define those actions required for the ACP to control the final access function into the

. protected area to prevent unauthorized access. Specifically, no i guidance existed for controlling a condition on October 3 and again on  ;

October 7, 1997 wherein the ACP failed to lock down the Protected Area ,

turnstiles or remove the second individual from the area during a ,

condition which could have allowed an unauthorized individual to gain  ;

access into the PA.

This is a Severity Level IV violation (Supplement Ill). This is applicable to both Units.

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 U.S. ,

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

20555 with a copy to the Regional Administrator. Region 11. and a copy to the NRC Resident inspector at the Brunswick 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 " 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 '

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. Your response may reference or i

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corrective steps that will be taken to avoid further violations and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence. if the correspondence adequately

. addresses the required response. If an adequate-reply is not received within i the time specified in this Notice, an order or a Demand for Information may be 1ssued 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 'i. 11ng the response time.

Because your res>onse will be placed in the NRC Public Document Room (PDR). to <

the extent possi)le, it should not include any personal privacy. )roprietary, i or scfeguards information so that it can be placed in the PDR witicut redaction. However, if you find.it necessary to include such information, you ,

should clearly indicate the specific information that you desire not to be placed in the PDR. and provide the legal basis to support your request for withholding the information from the public.

Dated at Atlanta Georgia This 8th day December 1997 d

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