ML20237D197

Notice of Violation from Insp on 870914-18 & 0928-1002. Violations Noted:Failure to Properly Maintain Core Spray Sys,Failure to Take Corrective Action to Resolve Engineering Work Requests & Failure to Conduct Adequate Audits

ML20237D197
Person / Time
Site:	Brunswick
Issue date:	12/11/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237D181	List: IR 05000324/1987031 ML20237D179 ML20237D197
References
50-324-87-31, 50-325-87-32, NUDOCS 8712230104
Download: ML20237D197 (3)

Text

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u ENCLOSURE 1 NOTICE OF VIOLATION Carolina Power and Light Docket Nos. 50-324 and 50-325 Brunswick License Nos. DPR-62 and DPR-71 During the Nuclear Regulatory Commission (NRC) inspection conducted on September 14-18, 1987, and September 28 - October 2,1987, violations of NRC requirements were identified. The violations involved failure to take prompt and adequate corrective action to resolve Engineering Work Requests (EWRs),

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failure to document the results of reviews of EWRs, failure to properly main-tain the Core Spray system in accordance with the United States of America Standard (USAS) requirements, and failure to conduct adequate audits. In accordance with the " General Statement of Policy and Procedure for NRC Enforce-ment Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:

A. 10 CFR 50 Appendix B, Criterion XVI and the licensee's accepted Quality Assurance Program, Final Safety Analysis Report (FSAR), Section 17.2.16, collectively require that measures be established to assure that condi-tions adverse to quality shall be promptly identified and corrected.

Contrary to the above, although measuras have been established for identi-fying conditions adverse to quality, measures have not been established to assure these conditions are promptly corrected in that, there exist approximately 1900 Engineering Work Requests (EWRs) that are currently outstanding. A detailed review of 30 EWRs identified multiple examples of EWRs that had been written in 1979 - 1984 with the corrective action remaining unresolved. Typical examples include EWR 83-083,84-362, 82-294, 84-1024,83-417, 84-872A, 83-1100, 84-809A,83-463, 83-168,80-272, 84-170,84-719, 02151,84-685, and 84-472. This list is not intended to be all inclusive.

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

B. 10 CFR 50 Appendix B, Criteria XVII and the licensee's accepted Quality Assurance Program (FSAR, Section 17.2.17) collectively require that sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include. .the results of reviews..

Contrary to the above, the results of reviews have not been documented as required for various EW'et The results of the reviews for EWRs were not documented to demonstrate that the known deficiency did not impact plant safety, thereby justifying continued plant operation. Typical examples include EWRs84-685, 84-496,83-463, 83-168, 01334,84-472, 84-391, 84-1024,79-399. 84-809A,84-362, and 82-294. This list in not intended to be all inclusive.

This is a Severity Level IV violation (Supplement I) 8712230104 871211 PDR ADOCK 05000324 0 M PDR

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Carolina Power and Light 2 Docket Nos. 50-324 and 50-325 Brunswick License Nos. DPR-62 and DPR-71 C. 10 CFR 50.55a(g) requires for a boiling water-cooled nuclear power facility whose construction permit was issued prior to January 1,1974, that components shall meet the requirements of paragraph (g)(4) to the extent practical. Paragraph (g)(4) requires that throughout the service life of a boiling water-cooled nuclear power facility, components which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, 2, or 3 shall meet che requirements set forth in Section XI of editions of the ASME Boiler and Pressure Vessel Code (B&PVC) and Addenda. ASME B&PVC Section XI Part IAW 7210 allows replacements (including system changes) to be accomplished with the original design requirements. The original design requirements for the Core Spray System committed to by the licensee are United States of America Standard B31.1, Power Piping. Paragraph 102.2.5B of this standard states that:

" Exhaust and pump suction lines for any service and pressure shall have relief valves of suitable size unless the lines and attached equipment are designed for the maximum pressure to which they may accidentally or otherwise be subjected, or unless a suitable alarm indicator, such as a whistle or free blowing relief valve, is installed where it will warn the operator."

Contrary to the above, the core spray suction relief valves (1-E21-F0328 and E21-F032A) were removed and blank flanged in 1979 and 1985, respectively.

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

D. 10 CFR 50, Appendix B Criterion XVIII and the licensee's accepted Quality Assurance Program (FSAR, Section 17.2.18) collectively require that a system of planned and periodic audits shall be carried out to verify compliance with all aspects of the Quality Assurance Program. The FSAR, Section 1.8 commits to Regulatory Guide 1.144, " Auditing of Quality Assurance Programs for Nuclear Power Plants." This Regulatory Guide endorses ANSI /ASME N45.2.12 - 1977, " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants." Paragraph 4.3.2.3 of this standard states that selected elements of the Quality Assurance Program shall be audited to the depth necessary to determine whether or not they are being implemented effectively.

Contrary to the above, the corrective action system was not audited to the depth necessary to determine it was being implemented effectively in that corrective action audits conducted from 1985 to 1987 did not include the l Engineering Work Request system.

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

Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light is hereby f required to submit to this Office within 30 days of the date of the letter I transmitting this Notice a written statement or explanation in reply including (for each violation): (1) admission or denial of the violation, (2) the reason

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Carolina Power and Light 3 Docket Nos. 50-324 and 50-325 Brunswick License Nos. DPR-62 and DPR-71 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.

FOR THE NUCLEAR REGULATORY COMMISSION c 3r I J. Nelson Grace Regional Administrator l Dated at Atlants, Georgia this lith day of December 1987 1

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