ML20199C238

Notice of Violation from Insp on 970819-0927.Violations Noted:On 970917,licensee Failed to Enter ASSD Impairment Upon Inability to Energize Breaker DE9 on Motor Control Ctr 1XA for 1-E11-F006A,RHRP 1A Shutdown Cooling Suction Valve

ML20199C238
Person / Time
Site:	Brunswick
Issue date:	10/27/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20199C229	List: IR 05000324/1997011 ML20199C227 ML20199C238
References
50-324-97-11, 50-325-97-11, NUDOCS 9711190276
Download: ML20199C238 (5)

Text

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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 August 19 througn September 27. 1997, seven violations of NRC requirements were identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions."

NUREG-1600. the violations are listed below:

A. Technical Specification (TS) 6.8.1.f requires that written procedures shall be implemented for the Fire Protection Program.

Fire Protection Procedure 0FPP-20 recuired that an alternate safe shutdown (ASSD) impairment be enterec when ASSD equipment is found to be inoperable, not accessible, or not available as required to perform safe shutdown evolutions.

Contrary to the above, on September 17. 1997. the licensee failed to enter an ASSD impairment upon the inability to energize breaker DE9 on motor control center 1XA for the 1-E11-F006A. Residual Heat Removal Pump 1A Shutdown Cooling Suction Valve.

This i a Severity Level IV violation (Supplement 1). This is applicable to Jnit 1 odly.

b. L 6.5.3. Plant Nuclear Safety Committee (PNSC). requires that a quorum shall consist of a chairman or alternate and four members or alternates as designated in writing. No more than two alternates shall be counted toward meeting the quorum requirements.

Contrary to the above a PNSC meeting was conducted on September 19.

1997 without required quorum membership. In attendance were the alternate chairman, a member, and three alternates.

This is a Severity Level JV violation (Supplement 1). This is applicable to both units.

C. TS 6.8.2 permits temporary changes to surveillance and test procedures for safety-related equipment, provided that the intent of the original procedure is not altered, the change is a] proved by two members of the plant management staff, at least one of w1om holds a Senior Reactor Operator License, and the change is documented and approved by the General Manager within 14 days of implementation.

Contrary to the above, on August 29. 1997. several changes were made to Maintenance Surveillance Test 3rocedure 2MST-RPS270, Reactor Protection System Scram Discharge Volume ligh Water Level Channel Functional Test and Channel Calibration, as " pen and ink" changes without the required approvals and documentation for a temporary change.

Enclosure 1 9711190276 971027 PDR 0 ADOCK 05000324 PDR

CP&L 2 This is a Severity l_evel IV violation (Supplement 1). This is applicable to both Units.

D. 10 CFR 50 Appendix B. Criterion XVI, requires measures be established which assure that conditions adverse to quality are promptly identified and corrected.

Contrary to the above, the licensee's measures did not assure prompt identification and correction of conditions aaverse to quality as evidenced by the following:

1. Corporate and industry information indicated that )reviously established motor-operated valve settings and capa)ility requirements assumed at Brunswick, may be unreliable. The licensee had not resolved inadequacies in the thrust settings and capability requirements in several motor-operated valve areas.

For example:

e The licensee had not resolved inadequacies in its justification for the valve factor parameter used in evaluating the thrust settings and capability requirements of its Anchor / Darling double disk gate valves, e The licensee had not resolved inadequacies in its justificatJon for the torque capability requirements established for its butterfly valves.

2. The licensee relied on thrust measurements obtained with VOTES diagnostic test equipment in establishing appropriate thrust settings and capabilities for motor-operated gate and globe valves. On November 19. 1993, the vendor of this test equipment issued Customer Service Bulletin 31. informing its users of previously unrecognized uncertainty that could occur in opening thrust measurement value1 The licensee was not prompt in evaluating the im)act of this uncertainty on the adequacy of the settings and capa)ilities of its motor-operated valves and an evaluation was still in progress in August 1997.

3. Motor-operated valve stall failures found in 1994 and 1996 were not evaluated for possible structural damage to valve components (conditions adverse to quality). Following stall events of Unit 2 motor-operated valves 2-E51-F046 (Reactor Core Isolation Cooling Water Supply Valve) and 3-Ell-F009 (Shutdown Cooling Inboard Suction Isolation Valve), the licensee failed to determine whether structural limits of any motor-operated valve components had been exceeded. Motor-operated valve 2-E51-F046 stalled into its backseat when actuated to open on June 9, 1994 and 2-Ell-F009 was found to have stalled on Fe)ruary 3. 1996 (the actual stall event apparently occurred earlier). The licensee did not determine and document a calcu tion of stall thrust and torque forces, and Enclosure 1

CP&L 3 j compare them to the associated actuator and valve component limits. In August 1997, the licensee determined by calculation that the structural limits of components of both motor-operated

. valves were exceeded during the stall events. ,

- This is a Severity level IV Violation (Supplement 1). This is applicable to both units. ,

E. 10 CFR 50. Appcodix B. Ciiteria V. Instruction Procedures and Drawings requires that activities affecting quality shall be prescribed by documented instructions procedures. r drawings of a type appro)riate to the circumstances and shall be accomplished in accordance wit 1 these instructions, procedures, or drawings.

Maintenance Management Manual 0MiM-022, Instructions for Placement of Temporary Loads (e.g. Rigging. Scaffolding. Ladders. Personnel required that a temporary rigging release be obtained prior to rigging to or above any safety related function regardless of the magnitude of the load.

Contrary to the above, rigging was performed on or above safety related equipment without a temporary rigging release as evidenced by the following:

1. On August 6.1997, the licensee failed to obtain a rigging release during lifting of a 300 pound torus mock-up strainer on the 20 i foot elevation of Unit 2 which was rigged to the Reactor Building Purge Vent and the Reactor Building Service Water discharge piping.

2. On September 3.1997, the licensee failed to obtain a rigging release before installing temporary air piping over Motor Control Center 2XDA which contained local controls for the High Pressure Coolant injection System.

This is a Severity Level IV violation (Supplement 1). This is applicable to Unit 2 only.

F. TS 6.8.1. requires that written procedures shall be established.

implemented, and maintained covering the activities recommended in Appendix A. Paragraph G. Procedures for Control of Radioactivity of Regulatory Guide 1.33, dated November 1972.

Nuclear Generation Group Standard Procedure HPS-NGGC-0003. Radiological Posting. Labeling and Surveys. Rev. 3., Paragraph 9.2.1. requires that each container holding radioactive material shall bear a durable.

clearly visible label bearing the radiation symbol and the words

" CAUTION. RADI0 ACTIVE MATERIAL" OR "0 ANGER. RADI0 ACTIVE MATERIAL."

Enclosure 1 m v e g,-- w - ~ - , --r~n - , + o- - -e -- ,-+r.- m-

CP&L 4 4 Contrary to the above, procedural requirements were not followed in that i two containers of radioactive material were identified, one on March 26 .!

1997, and one on September 24, 1997, that did not have a visible label bearing the radiation symbol or the words "CAUTIDN RADIOACTIVE MATERIAL" OR " DANGER rah 10Ar,iVE MATERIAL".

This is a Severity level IV v N ation (Supplement IV). This is applicable to both units.

G. TS 6.8.1.a requires that written procedures shall be established.

implemented, and maintained covering the activities in Appendix A of Regulatory Guide 1.33. November 1972. Appendix A of Regulatory Guide 1.33 recommends procedures for surveys, monitoring, and radiation work  :

permits (RWPs).

Environmental and Radiation Control Procedure OE&RC-230. Issue and Use of Radiation Work Permits requires an RWP and electronic dosimetry in accordance with the RWP shall be required for entry into the primary radiation control area.

Contrary to the above, on August 13.15. and 18,1997. a contract worker failed to log on an RWP and failed to obtain an electronic dosimeter. .

This is a Severity Level IV violation (Supplement 1). This is applicable to both units.

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 11. and a copy to the NRC Resident Inspectoi 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 " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or. If contested, the basis for disputing the violation. (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 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 Information may be issued as to why the license should not be modified, 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.

Because your res)onse will be placed in the NRC Public Document Room (PDR), to

, the extent possi)1e, it should not include any personal privacy. 3roprietary.

or safeguards information so that it can be placed in the PDR witlout redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be Enclosure 1

i CP&L 5 ,

placed in the PDR and provide the legal basis to support your request for i withholding the information from the public, Dated at Atlanta, Georgia This 27th day of October 1997 i

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Enclosure 1 l

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