ML20054D125
| ML20054D125 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/01/1982 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20054D120 | List: |
| References | |
| 50-346-82-03, 50-346-82-3, TAC-48364, NUDOCS 8204220363 | |
| Download: ML20054D125 (4) | |
Text
. _ _ _. _ _
l l
Appendix i
l l
Toledo Edison Company Docket No. 50-346 t
As a result of the inspection conducted on January 11-15, 1982, and in
{
accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, i
1980), the following violations were identified:
l 1
1.
Technical Specification Limiting Condition for Operation 3.7.10 requires i
that all penetration fire barriers protecting safety-related areas be i
functional at all times.
If a penetration fire barrie. is nonfunctional, a continuous fire watch must be established within one hour on at least one side of the affected barrier.
i l
Contrary to the above, on January 14 and 15, 1982, Fire Door Nos. 312, 319A, and 400 were observed in a nonfunctional condition due either to obstruction or inoperable closure mechanism.
Although these fire doors protect areas containing cabling and/or equipment necessary for safe shutdown of the plant, no continuous fire watch was established on either side of the affected fire barrier.
I l
This is a Severity Level IV violation (Supplement I.D.2).
I 2.
Technical Specification 6.8.1.f requires that written procedures be established, implemented and maintained covering the fire protection j
program.
a.
Administrative Procedure AD 1810.01, Control of Combustibles, requires that storage of combustible gases, lubricants, solvents, 2
fuels, and paints shall be prohibited in safety-related areas.
i Also, this procedure requires that all wood used in safety-related areas shall be treated with a flame retardant and that combustion waste, scrap, debris and oil resulting from a work activity shall be removed from the plant following the completion of the work i
activity or the end of the shift, whichever is sooner.
Contrary to the above, on January 13 and 14, 1982, between the hours of 1600 and 2000, the inspectors observed the following
{
violations of these requirements:
l (1) Accumulations of combustible materials including untreated wood, rags, trash, cardboard and paper in the following selected areas:
8204220363 020401 I
PDR ADOCK 05000346 G
(
Appendix 2
i l
No. 2 Diesel Generator Room and-Day Tank Room No. 1 Diesel Generator Room No. 1, No. 3 and No. 4 Penetration Rooms
{
j "B" Battery Room and Low Voltage Switchgear Room Auxiliary Shutdown Panel Room i
(2) Storage or accumulations of flammable liquids and/or gases in the following selected areas-l No. 1 Diesel Generator Room No. 4 Mechanical Penetration Room Diesel Generator Corridor b.
Administrative Procedure AD 1844.00, Maintenance, requires that l
a fire watch continuously monitor an area for a minimum of thirty minutes following open flame, cutting grinding or welding work.
Contrary to the above, on January 15, 1982, during the lunch break, the inspectors observed that no fire watch was posted in the No. 2 l
Diesel Generator Day Tank Room where welding operations had been j
taking place prior to the lunch break.
t c.
Administrative Procedure AD 1828.20, Fire Brigade Training, j
requires that each fire brigade team participate in at least one fire drill each calendar quarter.
Contrary to the above, fire brigade drills were not conducted in j
the first and third quarters of 1981 for any of the fire brigades.
t This is a Severity Level IV violation (Supplement I.D.3).
I 3.
10 CFR 50.48 states, in part, "Each operating nuclear power plant shall have a fire protection plan that satisfies Criterion 3 of Appendix A to this part... Appendix R to this part established fire protection features required to satisfy Criterion 3 of Appendix A to this part..."
l In areas of the plant where the protection of systems whose function is required for hot shutdown does not satisfy the requirements of Paragraph G-2 of Section III of Appendix R to 10 CFR 50, Paragraph G.3 requires that alternative shutdown capability be provided independent of the area and that fire detection and fixed fire suppression systems be installed in the area.
i l
Contrary to the above, the licensee did not provide a fixed fire suppression system in the control room which is an area that does not satisfy the hot shutdown protection requirements of 10 CFR 50, Appendix R, Section III.G.2, nor did the licensee submit a request for exemption from this requirement as permitted in 10 CFR 50.48(c)(6).
This is a Severity Level V violation (Supplement I.E.).
\\
4 Apper. dix -
3 4.
Amendment No. 18 to License No. NPF-3 issued July 26, 1979, requires that the fire protection administrative controls be upgraded to bring them into conformance with the NRC guidance documents, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance." The implementation.date for this modification was prior to startup after the 1980 refueling outage (approximately November 1, 1980).
Contrary to the above, the following fire protection administrative controls procedures have not been upgraded to bring them into con-formance with the NRC guidance document:
AD 18i0.00 - Fire Protection Program AD 1810.01 - Control of Combustibles AD 1844.00 - Maintenance AD 1828.20 - Fire Brigade Training This is a Severity Level V violation (Supplement I.E.).
5.
10 CFR 50, Appendix B, Criterion XVIII, requires that a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program.
Toledo Edison Company Nuclear Quality Assurance Procedure QAP 2180,
" Audits," states in part, "A comprehensive system of planned periodic audits to verify compliance with QA program requirements and to deter-mine QA program effectiveness shall be conducted...
The goals of the audit system are...to provide an objective assessment of compliance with established requirements."
Toledo Edison Company Nuclear Quality Assurance Manual, Volume I, Section 1.2.8, defines Audit Activity as " Documented QA/QC activities to determine, through investigation, the adequacy of, and adherence to... licensing requirements."
Contrary to the above, the quality assurance audits of the fire pro-tection program performed in June 19-26, 1979 (Audit No. 598),
April 21 - May 30, 1980 (Audit No. 666) and. March 23-25, 1981-(Audit No. 744), only reviewed the adequacy of implementation of the existing plant proceoures. Assessments were not made concerning the adequacy of those procedures utilizing the fire protection licensing require-i ments as inspection guidance. This narrow scope for the quality assurance audits permitted deficiencies in fire protection procedures to go undetected.
This is a Severity Level V violation (Supplement I.E.).
6.
10 CFR 50, Appendix B, Criterion XVI, requires that conditions adverse.
to quality be promptly corrected.
i
+
. _ _ _ -__ _ _ _ _ _ _ _l Appendix 4
Contrary to che above, the fire fighting practice training for the fire brigade was documented as being deficient in Toledo Edison Audit No. 729, dated August 20-22, 1980, and in Toledo Edison Audit No. 781, dated July 20-22, 1981, but the necessary corrective action had not been taken at the time of this inspection to upgrade the fire fighting-practice training program to satisfy the requirements in Paragraph 2.0 of Attachment No. 2 to " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance."
This is a Severity Level V violation (Supplement I.E.).
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 state-ment or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full com-pliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Consideration may be given to extending your response time for good cause shown.
APR 1 332 l6l-gn Ld / UJCCk Dated c coC. E. Norelius, Director Division of Engineering and Technical Programs t
a