ML20195G419

Notice of Violation from Insp on 980830-1010.Violation Noted:On 980916,licensee Failed to Perform Section 7.1.5 of Procedure OMST-RHR-28Q as Required When Returning Flow Transmitter E11-FT-3338 to Service

ML20195G419
Person / Time
Site:	Brunswick
Issue date:	11/09/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20195G416	List: IR 05000324/1998009 ML20195G412 ML20195G419
References
50-324-98-09, 50-324-98-9, 50-325-98-09, 50-325-98-9, NUDOCS 9811200299
Download: ML20195G419 (2)

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NOTICE OF VIOLATION Carolina Power and Light Company Docket Nos. 50-325 and 50-324 l Brunswick Units 1 & 2 License Nos. DPR 71 and DPR-62 l During an NRC inspection conducted from August 30 through October 10,1998, two violations of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

l A. Technical Specification 5.4.1 states that written procedures shall be established, l implemented, and maintained covering activities which are recommended in Regulatory Guide 1.33, Appendix A, November 1972, for performing maintenance on safety-related '

equipment, administrative procedures for procedure review and approval, and records retention.

. Maintenance Surveillance Test Procedure OMST-RHR-280,"RHR RSDP System Flow Channel Calibration," Revision 1, Section 7.1.5, " Return To Service," provides the requirements for venting and flushing flow transmitter E11-FT-3338.

Administrative Procedure OAP-003," Procedure Preparation, Review, and Approval,"

l Revision 13, identifies the requirements for procedures requiring revision, which are governed by the Plant Operations Manual, and requires that those procedures be revised according to the requirements specified for procedure revision.

Administrative Procedure OAP-009, " Records Management Procedure," Revision 0, requires that inservice Test (IST) Deviation Reports be retained and maintained for the life of the plant, in the Brunswick vault, as specified in the Required Record List, Section 5.1.3.

Contrary to the above:

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1) On September 16,1998 the licensee failed to perform section 7.1.5 of procedure OMST-RHR-280 as required when returning flow transmitter E11-FT-3338 to service. The transmitter was not vented and flushed through the transmitter vents in the sequence prescribed by procedure.

2) On August 6,1998, the licensee failed to properly revise Periodic Test OPT-10.1.8, "RCiG System Valve Operability Test." Acceptance criteria were revised and a change to a plant parameter relating to inservice Testing valve stroke time was made and implemented without following the requirements specified for l:

procedure revision.

Enclosure 1 i' 9811200299 981109 PDR ADOCK 05000324 G PDR l _ . - _ _ _ _ _ _ _ . . _ - ._ _. _ -_ - - - _ - . _ _

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3) As of September 11,1998, the licensee had failed to properly maintain or retain I IST Deviation Reports in the Brunswick vault in that IST records for 1996,1997, ,

and 1998 were being maintained by a plant engineer outside the vault, and l records for 1994 and 1995 were destroyed. These reports were used to identify and track IST deficiencies for valves and pumps.

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

B. 10 CFR 50, Appendix B, Criterion V," Instructions, Procedures, and Drawings," requires that activities affecting quality shall be prescribed by documented instructions, l procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, and drawings.

Nuclear Generation Group Procedure EGR-NGGC-005," Engineering Service Requests," Revision 9, Section 9.2.7.2 and Attachment 6,"ESR Screening Criteria,"

require that Engineering Service Requests (ESRs) include identification of potential i impacts to plant programs including if the ESR affected the performance parameters of j a valve within the IST program or affected any safety-related motor operated valve in a l

safety-related system and receive supervisor signature and approval.

Contrary to the above, on August 24,1998, ESR 98-455, Failure of 1-SW-V106 to Close, failed to identify the Inservice Testing (IST) program performance parameters I that were affected and receive supervisor signature and approval. This resulted in the  !

ESR not receiving adequate review or approval.

This is a Severity Level IV violation (Supplement 1). l The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence, and the date when full compliance will be achieved, is already adequately addressed on the docket in the enclosed i inspection report. However, you are required to submit a written statement er explanation I pursuant to 10 CFR 2.201 if the description herein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response l as a " Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, l ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region 11, and a copy to the NRC Resident inspector 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).

Dated at Atlanta, Georgia This 9" day of November 1998 l

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