ML20206A562

Notice of Violation from Insp on 860304-0430

ML20206A562
Person / Time
Site:	Davis Besse
Issue date:	06/05/1986
From:	Guldemond W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206A561	List: IR 05000346/1986012 ML20206A557 ML20206A562
References
50-346-86-12, NUDOCS 8606180249
Download: ML20206A562 (2)

Text

NOTICEOFVIOL& TION Toledo Edison Company Docket No. 50-346 As a result of the inspection conducted on March 4 through April 30, 1986, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1985), the following violations were identified:

1. Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained. In addition, 10 CFR 50, Appendix B Criterion V states in part, " Activities affecting quality shall be prescribed by . . . and shall be accomplished in accordance with these instructions, procedures, and drawings." Section 5.1.1 of the licensee's Nuclear Quality Assurance Manual (NQAM) states, " Division directors performing activities covered by this QA Manual shall ensure these activities are carried out in accordance with approved procedures."

The licensee failed to accomplish this, as demonstrated by the following examples:

a. Administrative Procedure AD 1845.03.0, " Facility Change Request (FCR)

Implementation", Section 7.1.7, states, " Operator training is coordinated and completed prior to equipment / system return to service."

Contrary to the above, an emergency diesel generator (EDG) was declared operable on, or about, March 11, 1986, when modification work performed under FCR 84-109 was completed; however, 27 licensed operators and 20 non-licensed operators had not completed training as of March 12, 1986.

b. The Design Review checklist (Item 5) in Nuclear Facility Engineering Procedures NFEP-Oll, " Conceptual Design," and NFEP-090, " Design Verification," requires that environmental design considerations be reviewed.

Contrary to the above, the licensec installed two Control Room Emergency Ventilation System control cabinets as a part of FCR 85-0265. The seismically qualified cabinets were installed under nonseismically supported water lines and the licensee did not consider the environmental conditions that would result from a waterline break.

c. Enclosure 2 of Administrative Procedure AD 1838.00.12, " Surveillance and Periodic Test Program," requires that test psrsonnel " Record all test deficiencies on test deficiency list." Section 4.2 of Administrative Procedure AD 1838.02.13, " Performance of Surveillance and Periodic Tests" states that "The Test Deficiency List is provided to ensure that all test deficiencies . . . are recorded . . .."

0606180249 860606 PDH ADOCK 05000346 G PDR

Notice of Violation 2 Contrary to the above, a test deficiency that occurred during the performance of Surveillance Test ST 5030.12.13, " Channel Functional Test of the Reactor Trip Module Logic and Control Rod Drive Trip Breakers", was not recorded on a Test Deficiency List.

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

2. 10 CFR 50.73(a)(1) states in part, "The . . . (licensee) shall submit a Licensee Event Report (LER) for any event of .the type described . . .

within 30 days of the discovery of the event."

Contrary to the above, following an event of the type described in 10 CFR 50.73, the licensee did not submit LER 86-15 until April 18, 1986, 68 days after the discovery of the event.

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

With respect to Item 1. c., the inspection showed that action had been taken to correct the identified violation and to prevent recurrence.

Consecuently, no reply to the violation is required and we have no further questions regarding this matter. With respect to Items 1. a. and b., and 2, 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.

b h Dated W. G.Wuldemh#

Reactor Projects Branch 2