ML20216H434
| ML20216H434 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/16/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20216H421 | List: |
| References | |
| 50-324-98-04, 50-324-98-4, 50-325-98-04, 50-325-98-4, NUDOCS 9804210133 | |
| Download: ML20216H434 (2) | |
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NOTICE OF VIOLATION Carolina Power and Light Company Docket Nos. 50-325.50-324 Brunswick Nucleaf Plant License Nos. DPR-71. 62 Units 1 and 2 As a result of an NRC inspection completed March 20. 1998, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions." NUREG-1600. the violation is listed below:
10 CFR 50. Appendix B. Criterion V requires that activities affecting quality shall be prescribed by documented instructions procedures or 3
drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions. procedures or drawings.
Paragraph 3.13 of CP&L procedure EGR-NGGC-0005. ~ Engineering Service Requests (ESR)" Revision 4. dated March 24. 1997, specifies the use of Engineering Disposition (ED) ESRs provided the ED ESRs do not produce j
design output documents, or does not change or approve deviations to existing engineering documents.
ED ESRs do not require design verification.
Paragraphs 3.7 and 3.9 of EGR-NGGC-0005 require the use of either configuration change (CC) or design change (DC) ESRs to produce design outputs or change existing engineering documents.
Paragraph 9.4.9 of EGR-NGGC-0005 requires that design verification be performed for safety related CC and DC ESRs.
Contrary to the above, on June 3, 1997. the licensee failed to accomplish activities affecting quality in accordance with procedure EGR-NGGC-0005. Engineering Service Requests.
Specifically. the licensee used ED ESR 9700314 Rev. O. dated June 3. 1997 to change the design temperatures for environmentally qualified equipment located in the Units 1 and 2 drywells.
This ED ESR constituted a design output document in which the licensee used neither a CC ESR nor a DC ESR as required by EGR-NGGC-0005.
The license subsequently used ED ESR 9700314 to revise the drywell temperature data in document Reference 227.
Environmental Qualification Service Conditions. Revisions 3 and 4.
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 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 Brunswick facility, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a " Reply to a Notice of Violation" and should 9804210133 980416 PDR ADOcK 05000324 G
PDR i
NOV 2
include for each violation:
(1) the reason for the violation, or if contested. the ba' sis for disputing the violation or severity level. (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 l
date when full compliance will be achieved.
Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply 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 t
why such other action as may be proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response to the Director. Office of Enforcement. United States Nuclear Regulatory Commission. Washington D.C. 20555-0001.
Because your response will be placed in the NRC Public Document Room (PDR) to the 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 toe information that should be protected and a redacted copy of your response that deletes such information.
If you request withholding of such material, you must specifically identify the pcrtions of your response that you week 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 privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding 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.
Dated at Atlanta. Georgia this 16th day of April 1998 f
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