ML20235L739

Notice of Violation from Insp on 870831-0904.Violation Noted:First 10 Yr Insp Interval Requirements Not Completed as Required,In That Portions of Hydrostatic Tests Not Completed

ML20235L739
Person / Time
Site:	Brunswick
Issue date:	09/30/1987
From:	Herdt A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20235L732	List: ML20235L729 ML20235L739 ML20235L744
References
50-324-87-30, 50-325-87-30, NUDOCS 8710050582
Download: ML20235L739 (3)

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ENCLOSURE 1 NOTICE OF VIOLATION Carolina Power and Light Company Docket Nos. 50-325 and 50-324 Brunswick License Nos. DPR-71 and DPR-62 During the Nuclear Regulatory Commission (NRC) inspection . conducted on August 31 - September 4,1987, violations of NRC requirements were identified.

The violations involved failure to adequately complete first inspection interval hydrostatic: testing, failure to issue a nonconformance report on licensee identified code discrepancies and inadequate hydrostatic test i procedures. In accordance with the " General Statement of Policy and Procedure ,

for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:

A. 10 CFR 50.55a(g) as implemented by the Brunswick Technical Specification, Paragraph 4.0.5a(2), requires that piping and components of boiling and l pressurized water reactor plants be examined and pressure tested to the  ;

requirements of Section XI of the ASME Code and that the examinations and l testing be completed during each of four ten-year intervals. By regulation, the first ten-year interval ended for Brunswick Unit 2 on November 2, 1985.

Contrary to the above, the first ten-year inspection interval requirements l were not completed as required, in that portions of hydrostatic tests I conducted in accordance with Periodic Test Procedures (PT) PT-24.3.2.C, PT-24.3.2.D,-PT-24.3.6, PT 24.3.7, and PT 22.2.2 have not been completed.

This is a Severity Level IV violation (Supplement I) Unit 2 only.

B. 10 CFR 50, Appendix B, Criterion XVI, as implemented by the licensee's accepted Quality Assurance (QA) Program (FSAR Chapter 17.2.16) requires that, measures be established to assure that conditions adverse to quality, such as failures, deficiencies and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of a significant condition adverse to quality, the cause of the condition; aHPthe corrective action taken shall be documented and reported to appropriate levels of management.

Contrary to the above, significant conditions adverse to quality were not

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documented or reported to appropriate levels of management in that, on January 1987 licensee personnel discovered that PT-24.3.6 and PT-24.3.7 used to hydrostatically test the discharge side of the RHR Service Water Booster Pumps 2A and 2C; 2B and 2D respectively, were incomplete. These were first ten-year interval tests for Unit 2. The individuals responsible for the performance of the test, scheduled the omitted portion of each test to be performed during the second ten-year interval. However, no nonconformance 87100505B2 870930 PDR ADOCK 05000324 o PDR

.. Carolina. Power and Light Company 2 Docket Nos. 50-325 and 50-324 Brunswick License Nos. DPR-71 and DPR-62 report was written 'and the safety significance, deportability, or corrective action to prevent recurrence had not been evaluated until the inspector identified the item to management on September 2,1987. The inspector's record review also found other examples' of incomplete /

inadequate hydrostatic test records.

This is a Se/erity Level IV violation (Supplement I) Unit 2 only.

C. 10 CFR .50, Appendix B, Criterion V as implemented by the licensee's .

accepted Quality Assurance (QA) Program (FSAR Chapter 17.2.5) requires that activities affecting quality shall be prescribed by documented instructions or procedures of a type appropriate to the circumstances and work shall be ' accomplished in accordance with these instructions or procedures. The instructions or procedures shall include appropriate quantitative .or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, the following hydrostatic test procedures were found to be inadequate in that:

1. PT-24.3.2.C and PT-24.3.2.0, failed to provide instructions for positioning of in-line check valves 274 and 275 to permit the i hydrostatic testing of the designated piping boundary. This resulted 4 in the performance of incomplete hydrostatic tests on Unit 2.  ;

2. The hydrostatic test performed under Unit 2 pipe modification PM-83-90 failed to list valve No. F0-73 on the valve lineup sheet.

3. In addition to the above, PT-22.2.2 for Units 1 and 2 reactor l building closed cooling water, was tested at system operating pressure, in lieu of code specified hydrostatic pressure.

Portions of the test procedure sign-off instructions had been discarded, including the valve line-up sheets for the test.

This is a Severity Level IV violation (Supplement I) Units 1 and 2. '

Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply 1

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l . Carolina Power and Light Company 3 Docket Nos. 50-325 and 50-324 f

Brunswick License Nos. DPR-71 and DPR-62 including for each violation: (1) admission or denial of the violation, l (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.

FOR THE NUCLEAR REGULATORY COMMISSION 410 Alan R. Herdt, Chief Engineering Branch Division of Reactor Safety Dated atm Atlanta, Georgia this joPday of September 1987 i

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