ML20203N450

Notice of Violation from Insp on 860301-31

ML20203N450
Person / Time
Site:	Brunswick
Issue date:	04/22/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20203N447	List: IR 05000324/1986012 ML20203N445 ML20203N450
References
50-324-86-12, 50-325-86-11, NUDOCS 8605050422
Download: ML20203N450 (2)

Text

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ENCLOSURE 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-62 The following violations were identified during an inspection conducted on March 1-31, 1986. The Severity Level was assigned in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).

1. 10 CFR 50, Appendix B, Criterion V, requires procedures to include appropriate quantitative and qualitative acceptance criteria for determining that important activities have been sat.i sfactorily accomplished. ENP-03, Plant Modification Procedure, Revision 32, implementing the approved Quality Assurance (QA) program, states that acceptance tests shall verify performance requirements to the extent necessary to determine operability.

Contrary to the above, the acceptance test in plant modification PM-81-309, reviewed on February 24, 1986, did not adequately specify quantitative and cualitative acceptance criteria for the cor? spray injection valve, 2-E21-F005A, in that the Technical Specification system response time of 27 seconds was specified for the valve only, in lieu of verifying that the valve in conjunction with other active components would meet the 27 second response time and also the valve was timed to its closed position instead aof the open position.

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

2. Technical Specification 6.8.1.a requires the licensee to establish, implement, and maintain procedures recommended in Appendix "A" of Regulatory Guide 1.33, November 1972. Item H.2 of the guide specifies that procedures are required for each surveillance test, inspection and calibration listed in the Technical Specification. Technical Specification surveillan;e requirements 4.1.5.c.1 and 2 are implemented by PT-06.2.3, Rev. 16, dated May 13, 1985.

a. Step 7.2.12 requires recording of Standby Liquid Control (SLC) system test tank level after filling the test tank. (This record is used as the initial value for the timed two minute capacity check of the pump.)

Contrary to the above, the proper test tank level was not recorded while performing step 7.2.12 of PT-06.2.3 on March 20, 1986 in that an auxiliary operator recorded a tank level obtained without the use of a measuring device, k

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

b. Technical Specification 4.1.5.c.1 requires that the SLC system loop shall be initiated, including an explosive valve, and verifying that a flow path from the pumps to the reactor pressure vessel is available by pumping demineralized water into the reactor vessel. Technical Specification 4.1.5.c.2 requires demonstrating that the minimum flow requirement of 41.2 gpm at a pressure of greater than or equal to 1190 psig is met.

Contrary to the above, PT-06.2.3 did not adequately implement Technical Specification requirements 4.1.5.c.1 and 2 in that a potential bypass flowpath was isolated during the surveillance test. PT-06.2.3 shut the normally cpen idle SLC pump discharge valve. ,

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

3. 10 CFR 50, Appendix B, Criterion V, as implemented by FSAR Section 17.2.5 requires that activities affecting quality shall be prescribed by documented procedures. The Standby Liquid Control System relief valves are removed every 18 months to verify the lift setpoint per Technical Specification 4.1.5.c.3. AddiHonally, the Brunswick Final Safety Analysis Report (FSAR), .

Section 9.3.4.2, ;tates that "the relief valves are installed with the discharge floode to prevent evaporation and precipitation within the valve." Verification that the discharge piping is flooded when the relief '

valves are installed is in activity affecting quality.

Contrary to the above, activities affecting quality were not prescribed ,

by documented procedures in that a verification process to insure that the FSAR commitment for flooding of the discharge piping with the relief valves installed has not been prescribed by a procedure.

This is a Severity Level IV (Supplement I), applicable to Units I and 2.

Pursuant to 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including: (1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid furtherrviolations; and (5) the date when full compliance will be achieved.

Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 CFR 73.21.

APR 2 21988 Date:

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