ML20154E261

Notice of Violation from Insp on 870413-1019.Violation Noted:Written Safety Evaluation Not Conducted for Condition Outside Analyzed Licensing Basis of Facility & License Amend Not Sought for Unreviewed Safety Question/Tech Spec Change

ML20154E261
Person / Time
Site:	Fermi
Issue date:	05/12/1988
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154E253	List: ML20154E251 ML20154E261
References
50-341-87-21, NUDOCS 8805200149
Download: ML20154E261 (2)

Text

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NOTICE OF VIOLATION Detroit Edison Company Docket No. 50-341

' As a result of the inspection conducted on April 13 through October 19, 1987, and in accordance with the "General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the following violation was identified:

10 CFR 50.59(a)(1) requires, in part, that the holder of a license authorizing operation of a utilization facility may make changes in the facility as described in the safety analysis report, make changes in the procedures as described in the safety analysis report, and conduct tests or. experiments not described in the safety analysis report without prior Commission approval, unless the proposed change, test or experiment involves a change in the technical specifications incorporated in the license or an unreviewed safety question.

10 CFR 50.59(b)(1) requires, in part, that the licensee shall maintain records of changes in the facility and of changes, tests, and experiments. These records must include a written safety evaluation which provides the bases for the determination that the change, test, or experiment does not involve an

, unreviewed safety question.

10 CFR 50.59(c) requires, in part, that the holder of a license authorizing operation of a utilization facility who desires a change in technical specifications or to make a change in the facility or procedures described in the safety analysis report or to conduct tests or experiments not described in the safety analysis report, which involve an unreviewed safety question or a change in technical specifications, shall 5,ubmit an application for amendment of his license.

• Contrary to the above, A. On April 9, 1987,

1. A written safety evaluation was not conducted for a condition outside

, the analyzed licensing basis of the facility in that the moisture separator reheaters (MSRs) were removed from service at approximately i 30% power when this equipment was assumed to be in service in the i safety analysis that generated the curves of Technical Specification

, Table 3.2.3-1.

2. A license amendment was not sought for an unreviewed safety question / technical specification change in that a Technical Specification change to the Table 3.2.3-1 curves is necessary for the MSRs out of service, and the circumstances of having the MSRs out of service had not been previously evaluated in the safety analysis report.

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8805200149 880512 PDR ADOCK 05000341 Q DCD r

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Notice of Violation 2

'N B. From March 4, 1987 through March 12, 1987, a change to facility operation was made by removing feedwater heating while at 50% reactor power without performing a written safety evaluation to provide the bases for the determination that the change did not involve an unreviewed safety question.

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

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) corrective action taken and the results achieved; (2) corrective action to 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, 5/l1lf\

Datedi

' ds b J/r i EdwardG.;6reehman,lqirector Division o'f Reactor Projects I

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