ML20012C332
| ML20012C332 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/09/1990 |
| From: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20012C331 | List: |
| References | |
| 50-341-89-34, NUDOCS 9003210050 | |
| Download: ML20012C332 (2) | |
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i NOTICE-OF-VIOLATION y.-r, m
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e DThe Detroit Edison, Company-Docket No. 50-341'
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License No. NPF-43 e
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v [As ahesult oflthe inspection conducted onLNovember 29, 1989 through
' l January 8,11990;. and in accordance with 10 CFR_Part 2, Appendix CL~ General n
Statement of Policy and Procedure for NRC Enforcement Actions.(1988), the s
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(following violations were identified:
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3 Technical-Specification 3.3.7.12 and' associated Table 73.3.7.12-1, -
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~ Item 2.a;requiresLthe offgas system hydrogen monitor to be operable r
when the offgas system is in operation or to take Action 124 in the Tabl.e.:iTechnical Specification Table 3.3.7.'12-1, Action 124 allows.
four hour. grab samples in lieu of'having.the1 hydrogen monitor' operable.
. Technical Specification.4.3.7.12 -and associated Table 4.3.7.12-1, Item:2.a _ requires periodic channel calibration and functional tests be performed _for the offgas system hydrogen monitor when the=offgas system
~is'in operation.
Contrary;to1the above, the-offgas system ' as placed into service on.
w December 10, 1989 without performing surveillance 44.080.501 to verify.
the hydrogen-monitor operable nor were the compensatory four. hour grab samples initiated. 'This condition existed until discovery on December 12, 1989i
-This is a. Severity Level _IV violation (Supplement I).
~2.
Technical Specification 3.'0.4 states in part " Entry into an OPERATIONAL
. CONDITION shall' not be made unless the conditions for the Limiting Condition for Operation are met without reliance on provisions contained '
in the ACTION requirements."
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Technical Specification 3.6.3 requires all primary containment isolation valves to be; operable in OPERATIONAL CONDITIONS 1, 2 and 3.
Table 3.6.3-l' Item A.2 of this specification identifies' valve B31-F020 as' a primary-containment isolation valve.
Contrary to the above, plant operators entered into OPERATIONAL CONDITION 2
.on December 6, 1989, with valve-B31-F020 inoperable in that the-
. quarterly ASME Section XI stroke time test had not been performed.
x This is a Severity Level IV violation (Supplement I).
3.
10 CFR.50,' Appendix 8, Criterion V, requires in part " Activities
' affecting quality shall be prescribed by... procedures... and shall be. accomplished in accordance with these... procedures...."
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Administrative Procedure NPP-0P1-12, " Tagging and Protective Barrier System," provides the implementing instructions for tagging valves and switches to prevent inadvertent operation of structures, systems and components as required by 10 CFR 50, Appendix B,-Criterion XIV,
" Inspection, Test, and Operation Status." Section 6 of NPP-OP1-12 requires documentation of independent verifications, reactor operator authorization to establish a selected tagging boundary, senior reactor operator acknowledgement of tagging boundary being implemented / removed, and notification to maintenance personnel of a modification to the tagging boundary.
Contrary to the above:
a.
The tagging measures associated with valve B31-F020 allowed the valve to be opened on December 18-19, 1989 without any reasonable tagging measure present to prohibit such an action even though the tagging records required the valve to be closed, b.
Operators failed to comply with the administrative tagging procedure when establishing and modifying the tagging boundary under Abnormal Lineup Sheet 89-1478 in that an independent valve position verification-was not present, a reactor operator authorization signature for a tagging boundary modification was not present, a senior reactor operator signature was not present for acknowledgement of a tagging boundary modification, and some notification stamps to maintenance personnel that the tagging boundary had been modified were not present.
This is a Severity Level IV violation (Supplement 1).
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, including for each violation:
(1) the corrective actions that have been taken and the results achieved; (2) the corrective actions that will 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, l% s 9 k Dated Edward G. Greenman, Director Division of Reactor Projects
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