ML20236N945
| ML20236N945 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/06/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236N933 | List: |
| References | |
| 50-324-98-06, 50-324-98-6, 50-325-98-06, 50-325-98-6, NUDOCS 9807160071 | |
| Download: ML20236N945 (4) | |
Text
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l 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 April 26 through June 6.1998, five violations of NRC requirements were identified.
In accordance with the
" General Statement of Policy and Procedures for NRC Enforcement Actions."
NUREG-1600. the violations are listed below:
A.
Technical Specification (TS) 6.8.2.a requires that temporary changes to procedures.or proposed tests may be made provided that the intent of the original procedure or proposed test is not altered.
Administrative Procedure 0AP-004. Temporary Changes To Procedures.
Section.5.1.2 requires'that "[t]em]orary changes can only be implemented
-if the revision clearly does not clange the intent of the approved 1
procedure."
Contrary to the above, on May 21, 1998, the licensee made a temporary z
procedure change that altered the intent of Ma-intenance Surveillance a
Test 1MST-DG11R, DG-1 Loading Test. by substituting a 25 horsepower load for a 50 horsepower load into the Diesel Generator load test profile.
This is a Severity Level IV violation (Supplement 1),
B.
TS 6 8.1.a. requires that written procedures shall be established.
implemented, and maintained covering the activities in Appendix "A" of Regulatory Guide (RG) 1.33. November 1972.
RG 1.33, requires procedures for abnormal' releases of radioactivity and for surveys and monitoring.
Abnormal Operating Procedure 0A0P-5.0 Radioactive Spills, High Radiation, and Airborne Activity defines those actions required to be
'taken in'the event of indications of abnormal releases.
The entry conditions for 0A0P-5.0 include when a Continuous Air Monitor (CAM)
Alarms and/or when routine surveys indicate airborne activity.
I Environmental and Radiation Control Procedure OE&RC-120. Routine /Special Airborne Radioactivity Survey contains guidance on actions to take in the event of high airborne activity.
Contrary to the above, on A)ril 25, 1998,.the licensee failed to properly implement and esta)lish procedures for abnormal releases of i
l radioactivity in the following examples:
l 1)-
The-licensee failed to take actions in accordance with 0A0P-5.0 when a CAM alarmed and survey results indicated abnormal airborne activity ranging from 0.2946 to 0.39 Derived Air Concentration.
I 9907160071 990706 PDR ADOCK 05000324 G
PDR L
_.__________o
2)-
The licensee failed to properly establish 0E&RC-120 to define those actions to be taken when abnormal airborne activity from 0.2946 to 0.39 Derived Air Concentration was identified in the Unit'l Control Building. As a result.-airborne areas were not adequately centrolled such that five personnel were present in partially posted airborne areas not allowed by their respective radiation worker permits.
This is a' Severity Level:IV violation (Supplement 1).
C.
TS 6;8.1.f requires that written 3rocedures shall be established, implemented, and maintained for t1e Fire Protection Program.
10 CFR 50 Appendix R..Section III.L.4 recuires equipment and systems be ca)able of maintaining hot shutdown /stancby until cold shutdown can be ac11eved in the event of damage from_ fire.
The number of operating shift personnel. exclusive of fire brigade members.' required to operate such equipment shall be on site at all-times.
. Alternate Safe Shutdown Procedure OASSD-00. User's Guide, partially defines those actions to take when required Alternate Safe Shutdown Staffing (ASSD) cannot be maintained.
Section 6.3.5 of 0ASSD-00 states that "[t]he ASSD staffing composition may be less than the minimum requirements for a. period of time not to exceed two hours in order to
. accommodate unexpected absence of on-duty shift crew members 3rovided immediate action is taken to restore requirements to within t1e minimum requirements of the Shift ASSD Staffing Roster.
If the ASSD staffing composition is not restored to within the minimum required in two hours, establish an Alternative Safe Shutdown Impairment in accordance with
'PLP-1.5. Alternative Safe Shutdown Capability Controls, and FPP-020.
System ' Impairment Notification. ~
Contrary to the above, the licensee failed to properly implement and establish Fire Protection Procedures in the following examples:
1)-
On five separate occasions identified by the inspector on the following dates: April 3. April 18-19. April 20-21,1998, the licensee failed to maintain the minimum staffing requirements in accordance with 0ASSD-00. The absences identified where either in excess of two hours and/or were not for unexpected absences of required personnel.
L_.
2)-
Procedures OASSD-00 and OPLP-1.5 were not 3roperly established in that the guidance provided allowed the num)er of operating shift, personnel, exclusive of fire brigade members, required to operate such equi] ment to not be on site at all times which is in conflict with 10 C R Appendix R.Section III.L.4.
This is a Severity Level IV violation (Supplement 1).
- D.
TS 6.8.1.a. requires that written procedures shall be established.
~ implemented, and maintained covering the activities in Appendix "A" of Regulatory Guide (RG).1.33. November-1972.
RG 1.33, requires procedures for record retention.
Nuclear Generation Group Manual NGGM-PM-0007. Quality Assurance Program
~
Manual. Section 15.15 required that "[t] hose records required to verify compliance with criteria of the Fire Protection Program shall be identifiable'and retrievable and shall be assigned retention -
requirements.~
Contrary to the above in April 1998, the licensee failed to maintain to 0ASSD-00 on-the following occasions: March 27-28 and for the day shift on April 3 and 18.1998. Attachment 1 to 0ASSD-00 was used to record those individuals assigned to perform ASSD responsibilities.
This is a Severity Level IV violation (Supplement 1).
E.
TS 6.11.1-requires, in part. 'that procedures for personnel radiation protection be adhered to for all operations involving personnel radiation exposure.
OE&RC Procedure-100. Routine /Special Dose Rate Survey. revision 26.
dated. July 23. 1997, section 5.0 and Attachment 1 provide the schedule for plant radiation surveys. Approximately eleven surveys are required to be performed each month.
Contrary to the above, the licensee failed to perform approximately nine recuired routine monthly radiation surveys during the months of March anc April 1998.
This is a Seven.y i.evel f/ violation'(Supplement IV).
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 Inspec+or 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 as a " Reply to a' Notice of Violation" and should include for each violation; (1) the reason for the violation L or, if. contested the basis 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 1(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 the time specified in this Notice, an order or a Demand for l
Information'may be issued as to why the license should not be modified.
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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 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. DC 20555-0001.
Under the authority of Section 182 of the Act. 42 U.S.C. 2232. this response shall be submitted under oath or affirmation.
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 witlout 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 the 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 s)ecifically identify the portions of your response that you seek to have withield 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 6th day of July 1998 l
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