ML20140D332

Notice of Violation from Insp on 970201-0319.Violation Noted:Inspectors Identified That Licensee Did Not Have Prepared Instructions for Energizing & Startup of Bus 302 in Offsite Electrical Sys

ML20140D332
Person / Time
Site:	Fermi
Issue date:	06/02/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20140D327	List: ML20140D320 ML20140D332 ML20140D352
References
50-341-97-02, 50-341-97-2, NUDOCS 9706100350
Download: ML20140D332 (3)

Text

l NOTICE OF VIOLATION Detroit Edison Company Docket No. 050-341 Fermi 2 License No. NPF-43 During an NRC inspection conducted on February 1 through March 19,1997, one violations 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:

F 1. Technical Specification 6.8.1 requires that procedures shall be established, )

implemented, and maintained covering applicable activities listed in Appendix A of  !

Regulatory Guide 1.33, Revision 2.

Regulatory Guide 1.33, Revision 2,, Appendix A, Section 4.w states that instructions for energizing, startup, shutdown, and changing modes of operation ,

should be prepared for Offsite Electrical Systems (access circuits). )

l Contrary to the above, on February 3,1997, the inspectors identified that the

'l licensee did not have prepared instructions for energizing and startup of Bus 302 in the Offsite Electrical System.

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

During an inspection conducted August 21 through 30,1996, and September 9 through 11,1996, violations of NRC requirements were identified. In accordance with the NRC i " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG l 1600, the violations are listed below

2. 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

l Contrary to the above, as of September 11,1996, the inspectors identified the  !

l following examples of inappropriate quantitative acceptance criteria:

l a .- An inappropriate quantitative acceptance criteria of 0.033 standard cubic feet per minute (scfm) air leakage for the accumulators on the automatic ,

i depressurization system (ADS) was'used in Surveillance Procedure i l 43.137.002, Revision 21, "SRV Accumulator Check Valve Test." The i designed calculated acceptance leakage rate was 0.002 scfm. Thus the L accumulators could have been depressurized such that they would not have ,

I allowed for 5 actuations of the ADS in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in accordance with the l original design. I l

[ b. An inappropriate quantitative acceptance criteria of 25 standard cubic feet

. per minute (scfm) air leakage rate for air operated valve P50-F440, and  ;

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9706100350 970602 P PDR ADOCK 05000341 G PDR g

h Notice of Violation 20 scfm air leak rate for air operated valve P50-F441 were used in Surveillance Procedure 24.129.04, Revision 26, " Control Air Isolation Integrity." This leakage rate would have made the non-interruptible Control Air System inoperable due to not being able to provide sufficient air supply '

during accident conditions.

c. An inappropriate quantative acceptance criteria for open coil contactor pickup voltage (104v) was used in Maintenance Procedure 35.300.008,

" Motor Control Load Compartment," for High Pressure Core injection Valve E4150-F059. The correct calculated available voltage was 102.9v. Thus "

the available voltage could have been such that the valve would not have  ;

opened under accident conditions.

l This is a Severity Level IV violation (Supplement 1)

3. 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting ,

L quality shell be prescribed by documented instructions of a type appropriate to the l circumstances and shall be accomplished in accordance with these instructions.

l Quality Assurance Manual, MOA02, Revision 3, Section 4.8, " Internal Audits and Surveillances," requires that Deviation Event Reports (DER) be issued for findings identified in quality assurance audits and surveillances.

Quality Assurance Manual MOA02, Revision 3, Section 3.6.5, requires that repetitive problems identified through the audits / surveillance be escalated to management attention through the Management Action Request (MAR) process.

Contrary to the above, as of September 11,1996, the inspector identified the following examples of failure to accomplish an activity in accordance with instructions:

a. A Quality Assurance (QA) inspector failed to issue a DER for three findings identified in Audit NOA 96-0106 in accordance with MOA02, Section 4.8.

b. A QA inspector failed to escalate to management a repetitive problem with inappropriate transfer of corrective actions from old DERs to new DERs in accordance with MOA02 Section 3.6.5. The problem was originally  !

identified in Audit NOA 95-0133 and was again noted in Audit NQA 96-0106.

This is a Severity Level IV violation (Supplement 1)

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l Notice of Violation -

3-Pursuant to the provisions of 10 CFR 2.201, the Detroit Edison Company is hereby l

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 l Regional Administrator, Region lil, and a copy to the NRC Resident inspector at the facility l that is 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. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notico, 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.

t Because your response will be placed in the NRC Public Document Room (PDR), to the  !

. extent possible, it should not include any personal privacy, proprietary, or safeguards

! information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please ,

provide a bracketed copy of your response that identifies the information that should be  !

- protected and a redacted copy of your response that deletes such information. If you j request withholding of such material, you muil specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation). If j safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

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{ Dated at this 2nd day of June 1997 i

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