ML20211E877

Notice of Violation from Insp on 970706-0816.Violations Noted:Ionization Fire Detection Test Procedure Was Not Implemented to Assure Satisfactory Performance of Ionization Detectors as Evidenced as Listed

ML20211E877
Person / Time
Site:	Brunswick
Issue date:	09/15/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20211E849	List: IR 05000324/1997009 ML20211E843 ML20211E877
References
50-324-97-09, 50-324-97-9, 50-325-97-09, 50-325-97-9, NUDOCS 9709300291
Download: ML20211E877 (5)

Text

<

4 NOTICE 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 During an NRC inspection conducted from July 6 through August 16, 1997, six 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.

Contrary to the above, activities involving performance of engineering activities for determination of environmental qualification of safety related electrical equipment were not accomplished in accordance with documented procedures as ev1denced by the following:

1. Paragraph 7.5.2.1 of Procedure OENP 014 Tem Documentation, Revision 8, dated January 199717,porary Power Feed requires an engineering service request (ESR) to be initiated to provide temporary )ower installations from permanent plant equi) ment.

Procedure EGR NGGC 0005, Engineering Service Requests, levision 4, dated March 25, 1997, specifies that environmental qualification program (10 CFR 50.49) requirements are to be evaluated in development of ESRs.

As of August 1.1997, the environmental qualification of a Hinds.

Crouse fitting was not evaluated in ESR 9700258 as required by Procedure OENP 014 and EGR NGGC 005. This ESR was initiated for installation of the temporary fuel pool cooling system power connection to safety related Unit 2 HCC 2XH. The temporary power was connected to permanent plant equipment on July 24, 25, 1997.

2. Paragraph .10 of Procedure OENP 020. Engineering Work Requests, Revision 16. dated June 20, 1993 requires input / review by environmental qualification (EQ) personnel of vendor recommendations for EQ electrical equipment located in a harsh environment.

As of November 16, 1993, an EQ review, as required by Procedure OENP 020, haa not been performed regarding a vendor recommendation to reduce the EQ qualified life of thermo electric coolers documented on EWR number 12721 VR. The thermo electric coolers are safety related EQ electric equipment installed in a harsh environment.

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

S 0

D$$ NONS24 PDR -

CP&L 2 B, 10 CFR 50, Appendix 3, 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, Carolina Power and Light Company Nuclear Generation Group Procedure EGR-NGGC 0156, Environmental Qualification of Electric Equipment Important to Safety, Revision 2, dated July 10, 1997, )rovides instructions for establishing maintaining, and implementing t1e requirements of 10 CFR 50.49. Environmental Qualification.

Contrary to these requirements, the instructions in CP&L Procedures EGR-NGbC 0156 were not followed for preparation of Qualification Data Package 67. General Electric Company IC Series Motor Control Centers, Revision 6, dated July 9, 1997, and Document Reference 227 for Environmental Qualification Service Conditions, Revision 2, dated July 1,1997, as evidenced by the following:

1. Paragraph 9.3.2 of Procedure EGR NGGC 0156 requires an operability determination to be performed in the form of a written justification for continued operation and initiation of a Condition Report (CR) when environmental qualification of EQ equipment is indeterminate.

As of August 21, 1997, a justification for continued operation was not 3repared to address the faci. that environmental qualification of t1e motor control centers (HCCs) was indeterminate pertaining to abnormal temperature conditions.

2, Attachment 2 to Procedure EGR NGGC 0156 specifies the instruction and requirements for preparation of environmental qualification data )ackages. The Q)P instructions specified in number (9) of Attac1 ment 2 requires QDP open items to be tracked using a CAPS action item number.

As of July 31, 1997, the seven open items in QDP 67 were not being tracked using CAPS action items.

3. The QDP instructions specified in numbers (32) and (64) of Attachment 2 requires equipment evaluated by the QDP to be based, in part, on the abnormal temperatures the equipment is expected to be exposed to in its installed location.

The HCCs were not evaluated for abnormal temperatures in QDP

67. CP&L Emergency Operating Procedure E0P 03 SCCP, Secondary Containment Control Procedure, Revision 5, dated June 17,1994 permitted the plant to be operated to abnormal temperatures in excess of the 104 degrees Fahrenheit normal taperature evaluated in QDP 67.

CP&L 3

4. Paragraph 4.4.3 of Attachment 2 to EGR NGGC 0156 requires document reference (DR) open items to be tracked using CAPS open items, r As of July 30, 1997, the 29 open items in DR 227 were not being tracked using CAPS action items.

This is a Severity Level IV Violation (Supplement I). This is applicable to both units.

C. Technical Specification 6.8.1.f requires that procedures shall be established, implemented, and maintained for implementation of the Fire Protection Program.

Sections 15.11, Quality Assurance (QA) Program for Fire Protection Systems, Preventive Maintenance, and 11.4 Maintenance Control, Preventive Haintenance, of the Carolina Power & Light Corporate Quality Assurance Manual require that preventive maintenance procedures shall consider manufacturer recommendations and plant operating and maintenance experience.

The National Fire Protection Association Code Section 72E 1974 states that to assure that each smoke detector is operative, it shall be tested, in place, in accordance with the manufacturer's instructions.

Pyrotronics Multi Zone Fire & Smoke Detector Systems and Control Panels:

Models CTZ 1,2 Operation, Installation, and Maintenance Manuals, Maintenance Section states that upon initial installation and once a year the detector sensitivity should be measured.

Contrary to the above, the ionization fire detection test procedure was not properly implemented to assure the satisfactory performance of the ionization detectors as evidenced by the following:

1. Since installation, the ionization detectors were not tested yearly in the Service Water Building in accordance with the manufacturer recommendations.

2. Since 1994, 47 ionization detectors located throughout both units were not tested during initial installation in accordance with the manufacturer recommendations.

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

D. Title 10 Code of Federal Regulations, Part 50, Appendix B Criterion V, states, in part, that activities affecting quality shall be prescribed by procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures.

The Brunswick Updated Final Safety Analysis Report, Paragraph 17.3.1.5, Personnel Training and Qualification, states in part, that sRe pe."sonnel who perform activities affecting quality shell be tiained such

CP&L 4 that they are knowledgeable and capable of performing their assigned tasks.

Licensee procedure OTI 100, Conduct of Training, Revision 13, effective January 6,1996, states in Paragraph 12. Exemptions, "to be qualified to perform a task independently, the individual must complete the task performance qualification requirements".

Contrary to the above, two individuals conducted independent radiation protection support activities for spent fuel shipments during 1996 who were not qualified to conduct these tasks independently in that they failed to complete Qualification Checkout Card 9.21N task performance qualification requirements.

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

E. Title 10 Code of Federal Regulations Part 71 Packaging arid Transportation of Radioactive Material, Subpart H-Qt ality Aswrance, Section 71.137, Audits, states the licensee shall carry out a comprehensive system of planned and periodic auditt, to verify compliance with all aspects of the quality assuran:e program, and to determine the effectiveness of the program.

Contrary to the above, prior to March 27, 1997, the licensee failed to carry out a comprehensive system of planned and periodic audits, and failed to verify compliance with all aspects of the quality assurance program for packaging and transportation of radicactive n.3terials.

This is a Severity Level IV violation (Supplement IV). This is appUcable 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: D3cument Ccntrol 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 violatiors, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed corres addresses the required response.pondence, if the correspondence adequatelyIf a 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 may be pro m r shculd not be taken. Where good cause is shown, consideration will be given to extending the response time.

t CP&L 5 Because your resanse will be placed in the NRC Public Document Room (PDR), to  !

the extent possi)1e, it should not include any personal privacy, aroprietary, t or safeguards information so that it can be placed in the PDR wit wut 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 j withholding the information from the public.  ;

Dated at Atlanta, Georgia j, This 15th day of September 1997 1

l 4

C D

F 9

C

• -+,m+- >,vw- -o + -r-- -~~s <*---r- ,-