ML20206C671

Notice of Violation from Insp on 871018-880826.Violations Noted:Div 1 Portion of Procedure 24.413.01 Not Accomplished within 92 Day Time Interval & Failure to Perform Channel Check on Reactor Protection Sys

ML20206C671
Person / Time
Site:	Fermi
Issue date:	11/04/1988
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206C652	List: ML20206C648 ML20206C671
References
50-341-87-48-01, 50-341-87-48-1, 50-341-88-06, 50-341-88-6, NUDOCS 8811160367
Download: ML20206C671 (2)

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NOTICE OF VIOLATION

Detroit Edison Company Docket No. 50-341 i n

.f kh h-As a result of the inspection conducted on October 18, 1987 to August 26, 1988

'l, y and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy yl y and Procedure for NRC Enforcement Actions (1988), the following violations were g;b identified:

1. Technical Specification 4.0.5 requires in part that inservice inspect 0 and testing of ASME Code Class 1, 2, and 3 components shall be acenmplished with quarterly testing being done at least once per 92 days.

Procedure NE 5.06, "Inservice Inspection Programs," page A-3-4, identified the heating ventilation and air conditioning (HVAC) chiller  ;

pumps as requiring pump tests quarterly in accordance with surveillance  !

procedure 24.413.01, "Division I and II Control Center C(,illed Water Pump i and Valve Operability Test."

Contrary to the above, the Divistor: I portion of Procedure 24.413.01 was )

not accomplished within the required 92 day time interval including the grace period on September 9, 1987.

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

2. Fermi Unit 2 Technical Specifications, Section 4.3.1.1, requires that the Reactor Protection System Crywell High Pressure Instrumentation be demonstrated OPERABLE by the performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when in OPERATIONAL CONDITIONS 1 and 2.

~ Farmi Unit 2 Technical Specifications, Section 4.3.2.1, requires that the Isolation Actuation Drywell High Pressure Instrumentation be oemonstrated OPERABLE by the performa,nce of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ,

when in OPERATIONAL CONDITIONS 1, 2 and 3.

Contrary to the above, during the period from March 20, 1985 (license ,

issuance), to October 8, 1987, while in Modes 1, 2 and 3, the licensee did not perform a CHANNEL CHECK on the Reactor Protection System and Isolation Actuation Drywell High Pressure Instrumentation.

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

3. Technical Specification 3.3.1 states, as a minimum, the reactor protection system instrumentation channels shown in Table 3.3.1-1 shall be operable. Technical Specification 3.3.2 states the isulation '.

' actuation instrumentation channels shown in Table 3.3.2-1 shall be operable, t

Technical Specifications 3.3.1.a and 3.3.2.b state with the number of <

operable channels less than required by the minimum operable channels per trip system requirement for one trip system, place the inoperable i I

' 8811160367 881104 l PDR ADOCK 05000341 '

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Notice of Violation 9 channel (s) and/or that trip system in the tripped condition within one hour. The minimum number of operable channels for Drywell High Pressure is two.

Technical Specification Tables 3.3.1-1 and 3.3.2-1, Table Notation (a) states a channel may be placed in an inoperable status for up to two hours for required surveillance testing without placing the trip system in the tripped condition provided at least one operable channel in the same trip system is monitoring that parameter.

Contrary to the above, on October 24, 1987, with the reactor in Opera-tional Condition 1, Drywell High Pressure Division I, Channel "A" was bypassed during surveillance testing from 12:25 p.m. until 3:37 p.m.

without placing the channel in the tripped condition after two hours had elapsed.

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

4. Technical Specification 6.8.1.d requires that written procedures shall be established, implemented, and maintained covering surveillance and test activities of safety-related equipment.

Contrary to the above, on February 17, 1988, the inspector determined that OSR0 epproved Drywell Pressure Response Time Test Procedures 44.020.015, 44.020.016, 44.020.017, and 44.020.018 failed to properly implement the requirements of Technical Specifications 3.3.1 and 3.3.2 in that they allowed a channel to be inoperable for up to three hours without placing the channel in a tripped condition.

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

5. Technical Specification Surveillance Requirement 4.5.3.1.b requires that the suppression chamber be determined OPERABLE by verifying the water level to be greater than or equal to 9'0" (-66 inch indication) at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Technical Specification Surveillance Requirement 4.4.9.2.1 states, "At least one shutdown cooling mode loop of the residual heat removal system or at least one recirculation pump shall be determined to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

Technical Specification Surveillance Requirement 4.4.9.2.2 states, "Verify reactor water level to be greater than or equal to 214 inches at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

Technical Specification Surveillance Requirement 4.4.9.2.3 states, "At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> verify the required RHR shutdown cooling mode luop(s) are capable of taking suction from the reactor vessel and discharging back to the reactor vessel through the RHR heat exchanger (s) with their associated cooling water available."

. . * . o-Notice of Violation 3 i

> i Technical Specification Surveillanco Requirement 4.4.6.1.4 requires the  !

reactor vessel flange and head flange temperature shall be verified to ,

be greater than or equal to 71 degrees when the reactor coolant system '

temperature is less than or equal to 100 degrees at least once per i 12 hoars, t

Technical Specification Surveillance Requirement 4.7.2.a. requires the  !

control room emergency filtration system be demonstrated OPERABLE by verifying the control room air temperature is less than or equal to 95 degrees at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Contrary to the above on March 13, 1988, and on May 3,1988, numerous Technical Specification Surveillance channel checks required to be performed by 2330 were not accomplished.

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) th;.

l' corrective actions that have been taken and the results achieved; (2) th! l corrective actions that will 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.

i Dated Edward G. Greenman, Director Div;sion of Reactor Projects l

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