ML20248A914

Notice of Violation from Insp on 890801-31.Violations Noted: Operating Procedure 1-OP-24 Inadequately Established & Written Procedures for post-maint Test Activities Inadequate for Containment Atmosphere Dilution Valve 2-CAV-CV-2714

ML20248A914
Person / Time
Site:	Brunswick
Issue date:	09/22/1989
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20248A908	List: IR 05000324/1989020 ML20248A904 ML20248A914
References
50-324-89-20, 50-325-89-20, NUDOCS 8910030050
Download: ML20248A914 (4)

Text

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ENCLOStlRE 1 NOTICE OF VIOLATION Carolina Power and Light Company- Docket'Nos. 50-325 and 50-324-Brunswick 1 and 2 License Nos. DPR-71 and DPR During .the Nuclear Regulatory -Commission. (NRC) inspection. conducted on August 1-31, 1989, violations of NRC requirements were identified. In accordance with -the " General Statement of Policy and Procedure. for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989)' the violations are -

listed below:

A. 10 CFR 50, Appendix B, Criterion XVI, requires that measures shall be established to assure that conditions adverse to quality such as failures,.

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I malfunctions,' deficiencies,' deviations, defective material and equipment, .

and non-conformances 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.

Contrary - to the above, the ' licensee failed to : take: prompt corrective action, in that on March 31, 1989 - after the .identif1 cation of. a third example of a corroded service water pump lubricating water piping support resulting in the possible inoperability of the associated service water pump, the licensee failed to promptly identify and correct other degraded service water pump lubricating water piping supports.

This is a Severity Level IV violation (Supplement I). l 1

B. Technical Specification 6.8.1.a requires that . written procedures be established, lemented, and maintained covering ' the applicable procedures "- 1 ended in Appendix A of Regulatory Guide 1.33,

. November 19h.

1. Section D of Appendix A requires Operating Procedures for .

safety-related BWR systems. .

Operating Procedure 1-0P-24,  !

Containment Atmosphere Control System, Revision 32., provides; the j system valve lineup for the Containment Atmosphere Dilution System, .

a safety-related system.

l Contrary to the above, Operating Procedure 1-0P-24 was inadequately' established. . in that, 'on and before July 20, 1989, it failed to- .:j l

specify the position for the manual override'for valve 2-CAC-CV-2714. '

The manual override and valve CV-2714 were shut instead of 'open from -

June:7,1989 to July 20, 1989, with no other. documentation of the valve's position. 4 P &# mgg ,

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Carolina Power and Light Company 2 Docket Nos. 50-325 and 50-324 Brunswick 1 and 2 License Nos. DPR-71 and DPR-62

2. Section D of Appendix A requires instructions for filling and venting the Standby Liquid Control (SLC) System. Operating Procedure 2-0P-5, Standby Liquid Control System, Revision 27, provides instructions for filling and venting the SLC System.

Contrary to the above, Operating Procedure 2-0P-5 was not adequately implemented, in that, on August 6,1989, valve 2-C41-F017, Return to Test Tank Valve, was throttled during filling and venting of the SLC System without any instructions to do so in 2-0P-5.

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

C. Technical Specification 6.8.1.c requires that written procedures shall be established, implemented, and maintained covering surveillance and test activities of safety-related equipment. MMM-03, Corrective Maintenance, Revision 1, Section 4.2.8.3, states that post maintenance testing requirements contain legitimate requirements that will verify the maintenance activity has been completed satisfactorily or the equipment has been returned to service properly. Work Request / Job Order 89-AHGE1 specified post maintenance test requirements for containment atmosphere dilution valve 2-CAC-CV-2714 after repair / replacement of the accumulator.

Contrary to the above, written procedures for post maintenance test activities were inadequate for 2-CAC-CV-2714, in that the valve was not cycled on June 7, 1989, to show it functioned, nor was the accumulator's ability to hold CV-2714 shut tested. (This testing would have also revealed that the manual override for CV-2714 had been shut.)

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

D. Technical Specification 6.8.1.c requires that written procedures be ,

established governing surveillance activities of safety-related i equipment. l 1

Technical Specification 4.6.5.1 requires that Secondary Containment I l Integrity be demonstrated by verifying at least once every 18 months by )

operating a standby gas treatment system for one hour and maintaining 1 greater than or equal to one quarter inch of vacuum, water gauge, at a j flow rate not exceeding 3000 CFM. PT-15.4, Secondary Containment  !

Integrity Test, Revision 14, implements this requirement.

Contrary to the above, surveillance procedure PT-15.4 was inadequately established, in that, it did not specify the testing configuration cf the railroad airlock doors. This resulted in operation, on at least two occasions, outside the tested configuration. The two occasions when the inner railroad doors were open were from about 1:30 p.m. until about midnight on August 1, 1989 for Unit 1 and from about 2:00 p.m. on August 23, 1989 until 9:30 a.m. on August 24, 1989 for Unit 2.

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

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4 Carolina Power and Light Company 3 Docket Nos.-50-325 and 50-324 Brunswick I and 2 License Nos. DPR-71 and DPR-62 E. Technical Specification 6.8.1.a requires that written procedures be established covering the activities recommended 'in Appendix A of Regulatory Guide 1.33, November 1972. Appendix A ',- Section A.3, recommends procedures for equipment control (e.g., locking and tagging).

Administrative Instruction AI-58, Equipment Clearance ' Procedure, step.

5.3.5.2, requires that the boundary of a clearance will provide adequate-safe working conditions for the. scope of work to be performed.

Contrary to the above, AI-58 was inadequately implemented, in that, on August 5, 1989, the boundary of a clearance did~ not provide adequate conditions for the scope of work. Local Clearance 2-886 (Clearance. to Support Standby Liquid Control (SLC) System Relief. Valve Removal) for the removal of relief valve 2-C41-F029A, affected both SLC pumps instead of just the 2A pump as originally intended.

This is a Severity Level IV violation (Supplement I) applicable to Unit 2 only. This clearance problem is a repeat violation.

F. The Brunswick Steam Electric Plant, - Unit 1, Updated Facility Operating License, DPR-71, Section 2.c.(1), authorizes the facility to operate with maximum steady state reactor core power levels not in excess of 2436 megawatts thermal.

Contrary to the above, the facility operated'in excess of 2436 megawatts thermal from approxuately 7:00 p.m., on August 23, 1989, until approxi-mately 6:00 a.m., on August 24, 1989.

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

G. Technical Specification 4.1.5.c.3, requires that the Standby Liquid Control (SLC) System shall be demonstrated OPERABLE at least once per 18 months during shutdown by demonstrating that the pump relief valve i setpoint is 1450 + 50 psig. '

i Contrary to the above, the Unit 2 SLC System was not demonstrated OPERABLE l during shutdown, in that, on August 3-6, 1989,- the pump relief valves' i setpoints were demonstrated during power operation of Unit 2.  !

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

H. Technical Specification 6.2.3.2 requires that the Onsite Nuclear Safety unit be responsible for maintaining . surveillance of facility activities to .i provide independent verification that these activities are performed correctly.

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- Carolina Power e ..d Light Company 4 Docket Nos.~ 50-325 and 50-324 Brunswick 1 and 2 License Nos. DPR-71 and DPR-62

Contrary to the above, as specified in Regulatory Compliance Instruction 06.6, Rev. O, Site Event Investigation Process, ONS functions as a member of.the. site incident' investigation team; a facility activity that ONS also maintains independent surveillance.

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

I. 10 CFR 50.54 (h) requires that the operating license be subject to all Orders of the ' Commission. Confirmatory Order EA-82-106, ~ dated December 22, 1982, required the licensee to implement the Brunswick Improvement-Program (BIP).

BIP Item VI-5 required the licensee to hold quarterly nuclear safety review meetings.

Contrary to the above, quarterly corporate nuclear safety review meetings were not held at least during 1988 and 1989.

This is a Severity Level V 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 Nuclear -

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and- a copy' to the NRC Resident Inspector, Brunswick, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked 'as a " Reply to a Notice of Violation" and should include for each violation: (1) admission or denial of the violation, (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. If an adequate reply is not received within the time specified in this Notice, an order may be i issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

FOR THE NUCLEAR REGULATORY COMMISSION

/I {L &

'Luis A. Reyes, Director Division of Reactor. Projects Dated at Atlanta, Georgia this 22 day of September 1989 i

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