ML20207S535
| ML20207S535 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/13/1987 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20207S534 | List: |
| References | |
| 50-346-86-32, NUDOCS 8703190641 | |
| Download: ML20207S535 (2) | |
Text
.
a NOTICE OF VIOLATION Toledo Edison Company-Docket No. 50-346 As a.. result of the inspection conducted on. December 1, 1986, through
,iJanuary 31, 1987,.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 (TS) Limiting Condition for Operation-(LCO)
.3.3.2.1 requires that Safety Features Actuation System (SFAS) functional units shown in Table 3.3-3 be operable with the plant in the Modes shown in Table 3.3-3.
Table 3.3-3 shows that the " Instrument String for Containment Radiation-- High Total Number of Units" is four and " Minimum
-Units.0perable" is three with the plant in Modes 1, 2, 3, 4 or 6.
Table 3.3-3 shows action statement 9 as the action to be taken with an Instrument String, Containment Radiation - High, SFAS functional unit inoperable.. Action 9 requires that if power operation is to proceed and if the number of operable units is one less than the total number of-3 units, then the inoperable functional unit must be placed in the tripped condition within one hour.
TS LCO 3.0.3 requires that when an LCO is not met, except as provided in
~
the associated action requirements, action shall be initiated within one hour to place the unit in at least hot standby within six hours, at least hot shutdown within the following six hours and cold shutdown within the subsequent twenty four hours, as applicable.
Contrary to the above, from 11:52 p.m. on January 7, 1987, until 8:20 a.m.
on January 8, 1987, (a period of eight hours and twenty eight minutes) the Instrument String for Containment Radiation - High, an SFAS func-tional unit, was inoperable, reducing the number of operable units to one less than the total number of units; the affected functional unit had part of its trip functions bypassed; and action was not initiated within one hour to place the unit'in hot standby within six hours, at least hot shutdown within the following six hours and cold shutdown within the subsequent twenty four hours.
i This is a Severity Level IV violation (Supplement I).
2.
Technical Specification 6.8.1 states in part, ".
. written procedures shall be established, implemented, and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33, November 1972."
Section 1 of Appendix A of Regulatory Guide 1.33, November 1972, is Administrative and Operational Procedures.
Contrary to the above, Administrative and Operational Procedures wer not adhered to in that:
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2 a.
On January 20, 1987, when the Auxiliary Feedwater System (AFWS) was made inoperable, the AFWS " Manual System Bypass" indicating light was not-illuminated as required by~ System Operating Procedure SP 1106.0C, " Auxiliary Feedwater System," Section 1.1.
b.
Between December 20,:1986, and January 3, 1987, seven mode changes were made'while containment air. cooler service water discharge valve SW 1357 was listed as inoperable and Technical Specification Limiting Condition for Operation action statement 3.6.3.1 was listed as applicable. This is contrary to the requirements of Plant Procedure PP No. 1102.01, " Pre-Startup
~ Checklist."
c.
From December-7 through 16, 1986, the inoperability of the meteorological tower was-not ' reported to the shift ' supervisor.
during the performance of Surveillance Test Procedure (ST)
No. 5035.01 as required by Administrative Procedure (AD)
No. 1839.00, " Station Operations," Section 6.8.3.
In combination these are considered 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 er 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.
MAR 131987 g
gy Dated Charles E. Norelius, Director Division of Reactor Projects