ML20058K249

Notice of Violation from Insp on 900801-0907 & Augmented Insp on 900821-25

ML20058K249
Person / Time
Site:	Brunswick
Issue date:	11/30/1990
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058K245	List: IR 05000324/1990029 ML20058K249
References
50-324-90-29-01, 50-324-90-29-1, 50-324-90-36, 50-325-90-29, 50-325-90-36, EA-90-154, NUDOCS 9012170050
Download: ML20058K249 (4)

Text

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NOTICE OF VIOLATION .l Carolina Power and Light Company Docket Nos. 50-324 and 50-324 I Brunswick Steam Electric Plant License Nos. DPR-62 and DPR-71~

Unit 2 EA 90-154-During NRC inspections conducted on August 1 - September 7, and August 21-25, l 1990, 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 (1990), the' violations a o listed below:

i A. Technical Specification 6.8.1.a. requires that written procedures be established, implemented, and maintained for. applicable procedures recom-mended in Appendix A,. Regulatory Guide 1.33, Ouality Assurance Program  ;

Requirements, November 1972,'which requires that administrative procedures be established detaili i *ocedure - adherere req.ivements.

Appendix A, Section H. , Qulatory Guide 1.33, November 1972, requires that procedures be written and implemented for each survei_llance test listed in Technical Specifications.-

Maintenance Management Manual 0-MM-001, Maintenance; Conduct of Operations, Revision 13, Section 5.2.2, requires that maintenance procedures be conducted with strict adherence to procedure steps. The steps are.to be performed in the sequence written and, where indicated, procedure steps should be ini'ialed upon completion'of stated' action.

Plant Administrative Procedure, AP, Volume 1, Revision 126, Section 11.7, requires that independent verification be performed:on components returned to service for systems listed in Table 11.7.1,. including the Primary l Containment Isolation System. Individuals performing independent verifica-l tion shall not rely upon the observed actions of-the individual performing l 'the initial alignment.

Contrary to the above, on August 19, 1990. Maintenance Surveillance Test (MST) 2MST PCIS24H, Primary Containment. Isolation System High Condenser l Pressurc 4p Unit Channel Calibration, Revision 4, which satisfies the I requir m , of Technical S l 1.e) abc ,.J.2-1 (Item 1.e)pecification 4.3.2.1implemented-in was not properly and.. Tables 3.3.2-2 (Item that testing l of channel A-2 was not completed prior to testing; channel B-2. Further, ,

i steps 7.5.15, 7.5.36, 7.5.37, 7.5.38, 7.5.39, 7.5.58, 7.5.59,'and 7.5.63 l were inapproporiately initialed as completed when they had not been I performed. In addition, 2MST PCIS24M was not properly implemented, in-l that required independent verification was not performed. Further, steps l 7.5.50 through 7.5.54 and steps 7.5.57 through 7.5.60 that require >

independent verification, were inappropriately initialed-off as being

' independently verified when they had not been. The improper performance of the MST resulted in a Group 1 isolation and a Unit 2 automatic reactor scram.

This is a Severity Level III violation -(Supplement I).

l 9012170050 901130 PDR ADOCK 05000324.

O PDR ;

Notice of Violation -2.

B. Technical Specification 6,8.1.a. requires that written procedures be j established and implemented for applicable procedures recommended in j Appendix A, Regulatory Guide:1 33, November 1972.

1. Appendix A Section E Regulatory. Guide 1.33, November 1972,. requires:

that procedures be established for correcting' alarm conditions.;

I ;

Operating Instruction 01-01, 0perating Principles and Philosophy, Revision 32, Section 6.4.7, requires that the Plant Monitor Reactor Operators silence, acknowledge, andl respond to annunciators. .

Section 9.0 states that all alarms should.be investigated thoroughly  ;

and imediately. ' '

Contrary to the above, the Plant Monitor. Reactor Operator did not  !

properly acknowled TRIPPED (A-05 5-3)ge and-respond and RPS toCabinet Chan B Trip annunciators TroubleGRPI (A-04 ISOL 6-1) Logic A/C-which existed simultaneously at approximately 9:50 p.m. on August 19, q 1990, on Unit-2. The failure to properly. acknowledge'and respond to 4 these alarms resulted-in the Instrumentation and Control (I&C) '

technician contir.uing with the_ surveillance > test and' tripping Unit 2.

This'is a Severity Level-IVl violation (Supplement I).  :

2. AppendixA,Section.DjRegulatoryGuide1.33, November 1972, requires  ;

that procedures be established for Reactor Core-Isolation Cooling i (RCIC) Systems and.the Feedwater System.-

Contrary to the above:

a. OP-16, Reactor Core Isolation Cooling System, Revision 57,  !

Section 4.0, states that.DC.limitarque valves are limited to a duty cycle of three, starts in five minutes followed by a fifty l minute cool-down period. :0P-16 was not implemented in that the  !

RCIC V8, a trip and throttle DC limitorque motor operated valve, I was cycled a fourth time after three starts in a:five minute  ;

period without a fifty ~ minute cool-down period on Unit 2 at- '

approximately 2:00 a.m. on August 20, 1990. :The valve motor tripped on thermal overload during the fourth. cycle,

b. 2-0P-32, Condensate and Feedwater System Operating Procedure,-

Revision 58, Section 5.2, and GP-05, Plant Shutdown. Revision 43, requires that V177, the long cycle cleaning return to condenser valve, not be opened until-the Startup Level _ Control. Valve (SULCV) is opened. 2-0P-32 and CP-05 were'not proper.ly imple- -

mented in that the V177--was opened prior to opening the SULCV' when placing the SULCV in service on August 19,1990, at ,

approximately 11:30 p.m. l 1

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

Notice of Violation - 3-- ,

3. Appendix A Section D. Regulatory Guide'1'.33,. November.1972, requires that procedures'be established for.the Main Steam System Reactor Core Iso.lation Cooling System and' Emergency' Core ~ Cooling Systems.- ,

Centrary to the 6"oove:

a. The procedure, Operator Aid 210099, used by the operator to open i the main steam-isolation valves-(MSIV)-on August 19,1990, at approximatelyl10:30 p.m.'was inadequate in that it:did not. '

I require the operator to place the condenser vacuum by' pass switch in the bypass position prior to attempting to open the MSIVs whent a lowLvacuum condition existed.

b. 2-0P-16, Reactor Core7 Isolation Cooling System, Revision.57, was 4 inadequate in that the method used to're-latch the Reactor Core Isolation Cooling (RCIC) trip and throttle valve (V8) following a turbine trip, holding;the valve close switch closed for an- i additional five seconds.after receiving closed' indicators, is not specified.

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

C. 10 CFR 50.72(b)(2)(ii) requires that the licensee not1fy the NRC Operations -

Center via the Emergency Notification System;as soon as possible and-in all

' cases, within four hours of-the occurrence of any event or condition-that .j results in manual or automatic actuation of any Engineered Safety Feature, including the Reactor Protection System. .The Final Safety: Analysis Report,,

Chapter 6, lists the Engineered Safety Features including the Containment-Isolation System. '

Contrary to the above, a notification to the NRC Operations Center was not made within four hours of the following events:

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1. Containment ~ Isolation System (Group 1) actuation on Unit 2 at 10:27 p.m. on. August 19,E1990, j

2. Reactor. Protection . System and Containment Isolation System _ (Groups 2, 6, and 8) actuations in Unit;2 at 11:17 p.m. on' August 19, 1990, and 12:04 a.m. on August 20, 1990.

3. Containment Isolation System '(Group 3) actuation in Unit 2 at 12:27 a.m. on August 20, 1990..

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

D. 10 CFR_Part 50.47(b)(45 requires that emergency response plans for' nuclear- '

power reactors be in uta .ncluding a standard emergency classification and

~

action level scheme', -the bases of which include facility.. system ano effluent parameters.

.)

+

Notice of Violation 4-10 CFR Part 50, Appendix E (IV)(B)'requ' ires that emergency plans. include.

the means to be used for determining action' levels ~that are to.be used=as.

criteria for determining the need for notification 'and participation of ' '

local and state agencies, the Commission, and other Federal' agencies.. .

The emergency action levels shall: be based on in-plant conditi_ons and -

• instrumentation in addition to on-site _and off-site monitoring.

Technical Specification _6.8.l.e. requires that written pro'cedures be? 3 established, implemented,'and maintained' covering the Emergency Plan >

implementation.

Plant Emergency Procedure, PEP 02.1, ' Initial Emergencyf Action,-Revision 27, Section: 2. Step 2.1.1, requires that' an- Unusual Event be~ declared 'upon-failure of a. nuclear steam system safety / relief valve,'includingJAutomatic Depressurization '. System, to open if challenged as indicated.at panel -(P603)-

on C32-R609, or C32-R605. .

Contrarytotheabove, PEP 02.'1was.notproperlyimplementedLinithat August 19, 1990, an Unusual Event was not declared following the failure of Unit 2 nuclear steam system safety / relief valves 821-F013.A, C, G, H, and K to open when challenged'following-the. automatic reactor shutdown!at--

9:54 p.m.-

This is a' Severity Level IV Violatibn:(Supplement VIII).

~

Pursuant to the provisions of 10 CFR 2.201, Carolina Power and. Light Company .

l (Licensee)'is.hereby required = to submit a written ' statement or- explanation to ,

the V.* Nuclear . Regulatory Commission, ATTN: ' Document Control Desk, Washington, y

D.C. 20555 with a copy to the-Regional Administrator, Region II,'and a copy to' l

the NRC Resident Inspector at the facility that is the subject of- this-Notice.  ?!

of Violation (Notice), within 30 days of the date ofJthe letter transmitting- s this Notice. This. reply should. be clearly. marked as a "ReplyLto a Notice of Violation" and should , include'for each violation: c (1): the reason- for the iviola-- '

L tion, or, if contested the~ basis for disputing the violation, (2)'the correc-tive steps that have been taken and the results achieved,,(3)t the~ corrective steps that have been taken and the results achieved,-(4) theydate when full compliance will be achieved. If an adequate- reply isJnotireceived'within the 1 time .specified 'in this Notice, an order.may be issued to show cause why;the . ,

license ~ shoulci not be modified,- suspended,70r ' revoked or whyssuch other action as may be proper should'not be taken. Consideration.may.be given.to extending.

the response time for good cause shown. Under the authority of'Section:182~of.

the Act,'42 U.S.C. 2232, this response-shall be submitted-under oath or

-affirmation.

l. FOR THE NUCLEAR REGULATORY COMMISSION l 4 "md gy.

• P Oi Ebneter l

g al Ad s ator Dated at Atlanta, Georgia l this30M day of November 1990

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