ML20198F399

Notice of Violation from Insp on 970525-0705.Violation Noted:Licensee Failed to Properly Implement Procedural Requirements as Evidenced by Listed Examples

ML20198F399
Person / Time
Site:	Brunswick
Issue date:	08/01/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198F382	List: ML20198F374 ML20198F399 ML20198F410
References
50-324-97-08, 50-324-97-8, 50-325-97-08, 50-325-97-8, NUDOCS 9708130031
Download: ML20198F399 (4)

Text

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NOTICE OF VIOLATION Carolina Power and Light Company Brunswick Units 1 & 2 Docket Nos. 50 325 and 50 324 License Nos. DPR 71 and DPR 62 During an NRC inspection conducted from May 25 through July 5, 1997, six violations of NRC requirements were identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions,"

NUREG 1500, the violations are listed below:

A. Technical Specification (TS) 6.8.1.a. requires that written arocedures shall be established, implemented, and maintained covering tie activities in Appendix "A" of Regulatory Guide (RG) 1.33, November 1972.

RG 1.33,Section I, requires administrative procedures for log entries and equipment control.

Operating Instruction 001 01.08. Control of Equipment and System Status, requires that for limiting condition for oaerations (LCOs) an entry describing the condition be entered into t1e LC0 tracking system. This procedure also requires that o>erability assessments that extend beyond the established time duration 3e approved by the Manager of Operations and Manager of the assisting organizations.

Contrary to the above, the licensee failed to properly implement procedural requirements as evidenced by the following examples:

F 1. No LCO entry was made when TS 3.7.2 action statement was entered

( for loss of the smoke and radiation protection mode of the Control Room Emergency Ventilation System during the April 1997 testing.

2. On June 11, 1997, an extension was granted verbally for an operability assessment concerning the reduction of the qualified life of the containment hydrogen / oxygen analyzer thermo electric cooling units without approval from the required managers.

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

B.

TS 6.8.1.a. requires that written procedures shall be established, implemented, and maintained covering the activities in Appendix "A" of RG 1.33, November 1972. RG 1.33,Section I, requires that maintenance which can affect the performance of safety related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Pl.nt Program Procedures OPLP 20, Post Maintenance Testing Program, requires post-maintenance testing to verify satisfactory completion of maintenance activities.

Contrary to the above, on May 27, 1997, maintenance performed on emergency bus E 2 under work request / job order (WR/J0) AELB 001, specified no post maintenance testing requirements to verify relay Enclosure 1 9700130031 970801

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A e CP&L 2 continuity or operability and did not incorporate vendor recommendations to verify contact gap prior to relay replacement, This is a Severity Level IV violation (Supplement 1), This is applicable to both Units, C. TS 6,8,1 requires that written procedures shall be established, implemented, and maintained covering test activities of safety related equipment, TS 6,8,2 allows temporary changes to procedures of TS 6,8,1 provided, in the intent of the original procedure, proposed test or experiment is not altered.

Administrative Procedure OAP 004, Temporary Changes to Procedures, Section 3,2, defines an intent change to a procedure as one that alters or deletes setpoints or required operating parameter range, Contrary to the above, on May 27, 1997, a change was made to relay calibration procedure OPIC RLY026, Relay Calibration Using Pulsemaster Software and Pulsar Relay Tester, that changed the pickup voltage range as a pen and ink change to the procedure. No procedure revision or temporary procedure change was made, This is a Severity Level IV violation (Supplement 1). This is applicable to both Units, D, 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures shall be established to assure that conditions adverse 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, Instructions, Procedures, and Drawings, recuires that activities affecting quality shall be prescribed by documentec instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings, Carolina Power and Light Company Plant Program Procedure OPLP 04, Corrective Action Management, implements the requirements of 10 CFR 50, Appendix B Criterion XVI, at the Brunswick Nuclear Plant, Paragraph 6,2 of CP&L Procedure OPLP 04, Revisions 19 through 21.

dated October 21, 1996 through April 30, 1997, require individuals identifying a condition to consult with their supervisors and initiate a Condition Report, A condition is defined in paragraph 3,5 of OPLP 04 as an adverse condition or a condition not meeting expectations, Contrary to the above, the licensee failed to take corrective actions for conditions adverse to quality as evidenced by the following:

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l- . s CP&L 3

1. A Condition Report was not initiated to document the fact that the-incorrect material was used for door gaskets in the safety related MCCs when the incorrect material was identified in October November,1996,

2. A Condition Re mrt was not initiated to document the fact that Rayclem splices were identified during EQ equipment walkdowns in March through June, 1997 which were not in accordance with the manufacturer's installation instructions.

This is a Severity Level IV Violation (Supplement I). This is applicable to both units-E. TS 6.8.1.f requires that written procedures shall be implemented for the Fire Protection Program.

Periodic Test 1PT 34.13.3.3, Transformer Deluge System Functional Test, Section 7.3, Startup Transformer Deluge System, required actuation of the heat detector on the Startup Auxiliary Transformer.

Fire Protection Procedure 0FPP 13, Transient Fire Load Evaluation, requires that fire separation zones be maintained free of transient combustibles.

Contrary to the above, the licensee failed to implement Fire Protection Program procedures as evidenced by the following:

1. On June 22, 1997, a technician heated a detector of the Unit Auxiliary Transformer instead of the Startup Transformer resulting in the spraying of water on the energized high voltage Unit Auxiliary Transformer.

2. On June 23,1997,- transient combustible material was found in the "

fire separation zone on the 50 foot elevation of the Unit I reactor building.

This is a Severity Level IV violation (Supplement 1). This is applicable to Unit 1 only.

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 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 " 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

CP&L 4 include previous docketed corres addresses the required response.pondence, If an adequateifreply the correspondence adequately is not received within the time specified in this Notice, an order or a Demand for Information may be

-issued as to why the license should not be modified, suspended,-or revoked,-or why such other action as :nay be proper should not be taken. Where good cause is shown, consideration will be given to extending 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, 3roprietary, or. safeguards information so that it can be placed in the PDR wit 1out 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, l Dated at Atlanta, Georgia This 1st day of August 1997

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