ML20133C943

Notice of Violation from Insp on 960815-1009.Violation Noted:Nrc Inspectors Identified That Operator Failed to Identify & Document Test Deficiencies

ML20133C943
Person / Time
Site:	Davis Besse
Issue date:	12/27/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133C936	List: ML20133C933 ML20133C943 ML20133C959
References
50-346-96-06, 50-346-96-6, NUDOCS 9701080151
Download: ML20133C943 (2)

Text

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NOTICE OF VIOLATION Toledo Edison Company Docket No. 50-346 Davis-Besse NPS Licerue No. NPF-3 During an NRC inspection conducted on August 15 through October 9, 1996, a '

violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

10 CFR Part 50, Appendix B, Criterion XI, " Test Control," states, in part, that, "A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. The test program shall include, as appropriate... operational tests during nuclear power plant... operation, of structures, systems, and components. Test procedures shall include provisions for assuring that all prerequisites for the given test are met...and the test is

)erformed under suitable environmental conditions. Test results shall 3e documented and evaluated to assure that test requirements have been satisfied."

a. Administrative procedure DB-DP-00013. " Surveillance and Periodic Test Program" (Revision 04), defined a test deficiency as, "Any deviation from a test procedure recuirement or acceptance criteria which is identified during the concuct of a test, or during the review of the test results."

Paragraph 6.3.8 of DB-DP-00013 stated, in part, that " Test deficiencies...shall be documented on the Test Deficiency List (Form) . . .

Contrary to the above, on September 25, 1996, while performing surveillance DB-SP-03161, " Auxiliary Feedwater Train 2 Level Control, Interlock, and Flow Test," (Revision 04), NRC inspectors 1 identified that an operator failed to identify and document test deficiencies when, on two occasions, he misoperated a stopwatch used to stroke time a valve.

b. Surveillance procedure DB-SP-03338, " Containment Spray Train 2 Quarterly Pump and Valve Test" (Revision 02), specified in notes preceding steps 4.11 and 4.27 that, "For valve CS1531...the stroke time will be measured with a stopwatch at the motor control center (MCC) while the valve is stroked from the Control Room."

Contrary to the above, on September 6,1996, during 3erformance of DB-SP-03338 NRC inspectors identified that the stroce time for valve CS1531 was measured from the control room and not at the MCC on two occasions.

9701000151 961227 PDR ADOCK 05000346 G PDR

Notice of Violation c. Contrary to the above NRC inspectors identified surveillance l procedures DB-SS-03254, " Emergency Ventilation System Train 1 18-Month SFAS Drawdown Test" (Revision 02), and DB-SS-03255,

" Emergency Ventilation System Train 2 18-Month SFAS Drawdown Test" (Revision 02), used to verify the integrity of the auxiliary building negative pressure boundary (NPB), failed to establish adequate test controls to confirm the proper functioning of NPB floor drain wafer check valves. Although soluble plastic material was routinely used to seal one or more floor drains in the auxiliary building (including floor drains within the NPB) for contamination control )urposes, placement / removal of the plastic was not otherwise trac;ed or controlled. DB-SS-03254 and DB-SS-03255 did not include prerequisites to verify the floor drains within the NPB were free of plastic prior to conducting drawdown testing.

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Toledo Edison is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region III, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation. (2) the corrective steps that have been taken and the results achieved (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Because your res)onse will be placed in the NRC Public Document Room (PDR), to the extent possi)le, it should not include any personal privacy, )roprietary, or safeguards information so that it can be placed in the PDR witlout redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

l Dated at Lisle, Illinois j this 27th day of December 1996 l