ML18054A944
| ML18054A944 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/11/1989 |
| From: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054A943 | List: |
| References | |
| 50-255-89-18, NUDOCS 8908310295 | |
| Download: ML18054A944 (2) | |
Text
NOTICE OF VIOLATION Consumers Power Company Docket.No. 50-255 As a result of the inspection conducted on June 13 through July 17, 1989, and in accordance with the General Policy and Procedures for NRC Enforcement Actions (10 CFR Part 2, Appendix C), the following violation was identified:
10 CFR 50 Appendix B, Criterion III, Design Control, requires establishment of measures to assure that the applicable regulatory requirements and the design basis of the plant are maintained.
The licensee's QA Program at Article 3.2 of CPC-2A Article 3.2 outlines controls for design changes.
Administrative Procedure (AP) 9.31, 11Temporary Modification Control, 11 implements controls for design changes which are of short duration and references AP 4.03 11 Equipment Control" as an example of a temporary modification where a temporary opening needs to. be controlled to maintain the design basis for the system.
Contrary to the above:
A.
During the period of June 21 through August 22, 1988, the control room ventilation boundary was breached during maintenance by the removal of several electrical penetration seals without initiation of a Temporary Modification as required for Equipment Control.
This resulted in the failure of the ventilation system 1 s ability to maintain a positive pressure during a surveillance test.
The ventilation system is described in FSAR Section 9.8 as being designed to control the flow of airborne radioactivity during an accident so as to minimize the impact on operating personnel.
This opening of the penetrations constituted.an unreviewed design change.
B.
On June 14, the 1 i censee b 1 ocked open the 11 Doghouse 11 entrance flood door (to the East Safeguards Room from the 590 foot elevation) to facilitate installation of a bushing/retainer ring to MV3234 per WO 24903179 and did not implement a Temporary Modification as required for Equipment Control.
The provision of flood doors to protect safety related equipment is described in FSAR Section 5.4.
Blocking the flood door open constituted an unreviewed design change.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 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 (for Item B only), including: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid
further violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
AUG.11 1989 Dated Edward G. Greenman, Director Division of Reactor Projects