ML19322A234
| ML19322A234 | |
| Person / Time | |
|---|---|
| Site: | Crane |
| Issue date: | 12/06/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19322A231 | List: |
| References | |
| 50-289-78-19, NUDOCS 7902050107 | |
| Download: ML19322A234 (2) | |
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APPENDIX A NOTICE OF VIOLATION Metropolitan Edison Company Docket No. 50-289 Based on the results of an NRC inspection conducted on Novnmber 7-9, and 13-17, 1978, it appears that one of your activities was not conducted in full compliance with conditions of your NRC Facility License No. DPR-50 as indicated below. This item is a Deficiency.
Technical Specification 6.8.1 states, in part:
" Written procedures and administrative policies shall be estab-lished, implemented and maintained that meet or exceed the require-ments and recommendations of... Appendix "A" of USNRC Regulatory Guide 1.33 November 1972 except as provided in..
6.8.3 below."
Technical Specification 6.8.3 states, in part:
" Temporary changes to procedures of 6.8.1 above may be made provided:
a.
The intent of the original procedure is not altered.
b.
The change is approved by two members of the plant management staff...
c.
The change is documented, reviewed and approved by tN Plant Operations Review Committee and approved by the Unit Superin-tendent..."
Regulatory Guide 1.33 November 1972 states, in part:
"The following are typical safety-related activities which should be covered by written procedures...
C.
Procedur-s for Startup, Operation and Shutdown of Safety Related HR Systems 1.
Control Rod Drive System 3.
Reactor Cleanut. System 4.
Shutdown Cooling System 1
7902050P m
Appendix A 2
H.
Procedures for Control of Measuring and Test Equipment 2.
Specific procedures for surveillance tests...
(... listed in Technical Specifications.)"
Contrary to the above, the following examples of nonconformance with administrative procedural controls were found on November 9,1978:
(i) Changes were made to Operating Procedure (0P) 1103-2, " Filling and Venting Reactor Coolant (RC) System," completed April 18, April 26, and April 28, 1978.
The changes, which did not alter the intent of the original procedure, were not approved, documented or reviewed.
(ii) OP 1104-2, " Makeup and Purification System," which provided requirements for each system startup and shutdown, had been used for multiple system startup and shutdown evolutions per-formed on April 25, April 28, June 22, and June 27, 1978.
In addition, verification of individual step (by operator initialing) and system startup satisfactory completion (by licensed operator signature), as required by OP 1104-2, was not completed for the system startup on June 27, 1978.
(iii) OP 1104-4, " Decay Heat Removal System," completed April 28 and June 22, 1978, did not indicate completion of steps in Enclosure (1), Startup Valve Checklist.
In addition, the procedures required completion of an Enclosure (2), which did not exist.
(iv) Satisfactory completion of the post-refueling approach to criticality on April 28, 1978, could not be demonstrated by a completed OP 1103-8, " Approach to Criticality."
(v) Surveillance Procedure 1301-9.5, " Reactivity Anomaly," com-pleted and reviewed October 31, 1978, was not properly imple-mented in that a data sheet contained an incorrect value for the power correction to reactivity. Another unlisted, but correct, value was used in the computation of reactivity anomaly. The erroneous data was not identified during sub-sequent procedure check and approval required by SP 1301-9.5.