ML20217C643
| ML20217C643 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/23/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217C640 | List: |
| References | |
| 50-346-97-08, 50-346-97-8, NUDOCS 9710020003 | |
| Download: ML20217C643 (2) | |
Text
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i 4 NOTICE OF VIOLATION 4
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_ Toledo Edison Company Davis-Besse NPS Docket No. 50 346 -
- Licensa No. NPF-3 During an NRC insper; tion conducted on May 27 through July 7,1997, violations of NRC r
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requirements were identified. In accordance with the " General Statement of Policy and L
Procedure for NRC Enforcement Actions," NUREG-1600, the violations rb listed below:
1-3:
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10 CFR Part 50, Appendix B, Criterion VI, " Document Control," specifies, in part.
that " Measures be established to control the issuance of documents such as
- instructions, procedures, and drawings, including changes thereto, which prescribe i
activities affecting quality.- These measures shall assure that documents, including j-changes, are reviewed for adequacy and approved for release by authorized personnel.."
Procedure C8-OP-00005, Revision 06, " Operator Logs and Rounds," Step 6.4.3.d.
required that ", Superintendent, Operations or designee approval shall be obtained prior to any changes being made to a Rounds package. _ This approval shall be 1
indicated by the Superintendent, Operations or designee signature on an approval i
page attached to the master reading sheets,"
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Contrary to the above, on June 13,1997, an operator rounds package change was issued for use without the Superintendent, Operations or designee signature on an approval page attached to the master reading sheets.
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' This is a Severity Level IV violation (Supplement 1).
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Technical Specification 6.8.1.a specifies, in part, that written procedures be
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established, implemented and maintained covering the activities referenced in the j.
_ applicable proceduras recommended in Appendix "A" of Reg 9atory Guide 1.33 i
(November 1972),
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_ Appendix "A" of NRC Regulatory Guide 1.33 (November 1972), speculed that procedures for startup, operation, and shutdown of safety related pressurized water
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reactor systems including the instructions for energizing, filling, venting, draining,
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stariup, shutdown and changing modes of operation be prepared, as appropriate, for i
certain systems, included in this list of systems were the containment isolation, and i
pressurizer pressure and spray control systems.
4 Procedure NG-NA-00115, Revision 02, " Control of Procedures," specified, in part,
' that:
- 1) the approval authority for non-administrative plant procedures shall be
- delegated only to individuals holding or acting in positions no lower than one management position below the plant manager: 2) a review of interfacing j
.' documents, such as Technical Specifications, USAR, drawings, proceduras, etc., be
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performed to ensure the procedure was in compliance and to determine which documents would require alteration to be compatible with the procedure or j
procedure change; 3) cross-disciplinary reviews by affected departments be 9710020003 970923 PDR ADOCK 05000346 g
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performed; and 4) a qualified reviewer, who was not the procedure preparer, review tha final procedure package for technical correctness and accuracy.
2 Contrary to ths above, on several occasions between May 23 and June g,1997, operations personnel drained piping segments in the containment isolation boundary 1
- for the pressurizer auxiliary spray line and the reactor coolant drain line without i
approved procedures. " Action plans" which: 1) were not approved by an individual-1.
' holding or acting in a position no more than one level below the plant manager, 4'
- 2) had not undergone an interfacing document review, 3) had not undergone cross-disciplinary review, or 4) were not documented as having been reviewed by a j
' separate quali.fied reviewer, were used for the draining process.
This is a Severity Level IV violation (Supplement 1).
4 Pursuant to the provisions of 10 CFR 2.201, Toledo Edison is hereby required to submit n'
. written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington D.C. 20555 with_ a copy to the Regional Administrator, Region 111, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clectly marked as a " Reply to a Notice of Violation" s
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 i
results achieved, (3) the correctivu steps that will be taken to avoid further violations, and
. (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, 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 4
action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
D L Because your response will be placed in the NRC Public Document Room (), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the without redaction. However, if you find it necessary to include such information, you should clearly indicate the speclfic information that you desire -
not to be placed in the, and provide the legal basis to support your request for withholding the information from the public.
Dated at Lisle, Illinois this 23rd day of September 1997