ML20024A673
| ML20024A673 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/07/1983 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024A669 | List: |
| References | |
| 50-346-83-05, 50-346-83-5, NUDOCS 8306220041 | |
| Download: ML20024A673 (2) | |
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Appendix NOTICE OF VIOLATION Toledo Edison-Company Docket No. 50-346 As a result of the inspection conducted on February 1 through April 29, 1983, and in accordance with the'NRC Enforcement Policy, 47 FR 9987 (March 9, 1982),
-the following violations were identified:
l.
-Technical Specification.6.8.2 requires that required procedures and changes thereto shall be' reviewed and approved prior to implementation and reviewed periodically as set forth in administrative procedures.
10 CFR 50, Appendix B, Criterion VI, requires that measures shall assure that document, including changes,Lare reviewed for adequacy _and approved for release.
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O Contrary to the above, the following procedures do not require that documents be reviewed:
a.
The Toledo Edison Nuclear Quality Assurance Manual dated January 3, 1983,~ Criterion VI, does not require that documents, including changes, be reviewed for adequacy.
b.
Administrative Procedure, AD 1805.00.18, Procedure Preparation and Maintenance, Section 7 Addition, Deletion or Modification, does not require a review for adequacy of the procedure including changes.
In addition,' Administrative Procedure, AD 1805.02.7, Periodic Review of Station Procedures, requires periodic reviews to help assure that procedures are understandable. However, this requirement was inadequate to preclude the following procedures from becoming difficult to use:
System Procedure,.SP 1107.09.05, Instrument AC System was referred 3
to'on January'25, 1989, during switching of buses and when an essential AC Instrument bus was lost, but was found difficult to use.by the control room operator.
It had 12 temporary modifications attached'(5 from 1980), and the control room operator could not use it to recover the bus in a timely manner.
Plant Protection Procedure, PP 1102.02.14, Plant Start-Up Procedure with 9 temporary modifications was used during the start-up the week of January 24, 1983. This procedure was also found difficult to use
.by station operators.
This is a Severity Level IV violation (Supplement I).
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Appendix'
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22.
10 CFR 50, Appendix B, Criterion XVI, requires that measures be estab-lished to assure that conditions adverse to quality such as malfunctions are identified and corrected and, in thfe case of significant conditions adverse to quality, the measures shall assure that.the cause of the condition is determined and corrective action taken to preclude repetition.
ANSI ~N18.7 requires that th$ cause of malfunctions be analyzed and similar. components be reviewed to determine whether a replacement component of the same type can be expected to perform its function reliably.
Contrary to the_above, on October 26, 1981 the "B" CROM Trip Breaker.
failed to operate and the cause of the malfunction was not promptly identified.
In addition, when the failure was finally analyzed in
' August 1982, a supplemental report was not-issued to the NRC to fully
' describe the final resolution of the occurrence.
~This is a Severity Level IV_ violation (Supplement I).
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- 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 item of noncompliance:
(1) cor-i rective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full complianer.
will be achieved. Consideration may be given to extending your response time for good cause shown.
rJUN 7 983 gyg-Dated
'C. E. Norelius, Director Division of Project and Resident Programs e
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