ML20217D074

Notice of Violation from Insp on 910429-0510,23,31 & 0603. Violation Noted:Surveillance Procedures for RPS Electrical Protection Assembly Calibr/Functional Tests Did Not Include Appropriate Quantitative or Qualitative Acceptance Criteria

ML20217D074
Person / Time
Site:	Fermi
Issue date:	07/11/1991
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217D004	List: IR 05000341/1991002 ML20217D002 ML20217D074
References
50-341-91-02, 50-341-91-2, NUDOCS 9107220046
Download: ML20217D074 (4)

Text

l NOTICE OF VIOLATION Detroit-Edison Company Docket No. 50-341 Fermi-2 License No. NPF-43 During an NRC inspection conducted on April 29 through June 3, 1991 violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991),theviolationsarelistedbelow:

1. 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions, procedures, and drawings, and those activities be accomplished in accordance with those instructions, procedures, and drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Fermi Management Directive, FMD CT1, Revision 1, " Calibration, Testing, and Surveillance," Section 4.5.3.12, an instruction requires, in part, that the calibration, test or surveillance procedure provide a sequence of operations, including inspections, functional checks, and measurements, as applicable, and the acceptance criteria and the means by which the response is to be observed for each.

Under " Definitions" of Appendix A, Revision 3, to the Fermi Management Policy and Directives Manual, acceptance criteria is defined as a limit or limits placed on the variation permitted in the characteristics of an item expressed in definitive engineering terms such as dimensional tolerances, chensical composition limits, density and size of defects, temperature ranges, time limits, operating parameters, and other similar characteristics. "

Contrary to the above, surveillance procedures for the reactor protection system electrical protection assembly calibration / functional tests, 42.610.02 (Division I) and 42.610.04 (Division II) did not include appropriate quantitative or qualitative acceptance criteria for the EPA breakers in that the undervoltage time delay limits were not acceptance criteria. (341/91002-01(DRP))

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

2. Technical Specification 6.8.1 requires that written procedures shall be: established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A of Regulatory Guide l'.33, Revision 2, February 1978, Section 9, recommends procedures for performing maintenance.

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Notice of Violation 2

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'l Procedure NPP-mal-04, Revision 7 " Conduct of Maintenance", Section 5.2.3 requires that actual work instructions be included on the work request i planning form. Instructions are to be followed sequentially unless so '

indicated within the body of the instructions.

Contrary to the above, on nunerous occasions (work requests 0030900322, 010C890814, 011C890814, 005C890814, 0200900724, 009D901129, 0100901129, 008D901129,0070901129,0100901112) maintenance work instructions were not followed sequentially and this was not indicated in the body of the work instructions. (341/91002-02(DRP))

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

3. Technical 5)ecification 6.8.1 requires that written procedures shall be establisaed, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

fppendix A of Regulatory Guide 1.33, Revision 2, Febr ry 1978, Section 7 recanended procedures for control of radioactivity ' lmiting materials released to the environment and limiting .ie,sonnel exposure).

a. Procedure FIP-RCl-01, Revision 2. " Accessing Ana Working In Radiologically Controlled Areas", Sectic 5.1 1 required written instructions on appropriate radiation wo"k L.rmits(RWP)alwaysbe followed.

RWP No. 91-1155, Special Instruction -2. A. required on May 1,1991, that coveralls be worn for entry into the contaminated work area for EDP 08321, on the second floor of the Turbine-building.

Contrary to the above, on May 1,1991, a cor. tractor welder, while working inside a contaminated area controlled by RWP 91-1155, improperly wore radiatior, protection coveralls in that the coveralls were unzipped while in the contaminated area to use a pen. This is an example of a violation. (341/91002-03a(DRP))

b. Procedure FIP-RCl-01, Revision 2, " Accessing And Working in Radiologically Controlled Areas", Section 5.1.1 required that written instructions on appropriate RWPs always be followed.

RWP 91-1155, Special Instruction 7, required that a whole body frisk be performed at the nearest frisker location immediately upon exiting the contaminated work area for EDP 08321.

Contrary to the above, on May 1,1991, a contractor carpenter failed to perform _ a whole body frisk at the nearest frisker location immediately upon exiting the contaminated area for EDP 08321.

This is an example of a violation. (341/91002-03b(DRP))

Notice of Violation 3

c. Procedure flP-RCl-01, Revision 2, " Accessing and Work'ing in Radiologically Controlled Areas", Section 5.1.1 required that radiological postings never be violated.

Contrary to the above, on May 2,1991, a contractor violated a radiological posting by climbing above a contamination boundary area posting affixed to a ladder on the south side of the drywell, of the Reactor Building. This is an example of a violation.

(341/91002-03c(DRP))

d. Procedure FIP-RCl-01, Revision 2, " Accessing And Working in Radiologically Controlled Areas", Section 5.1.1 required that written instructions on appropriate RWPs always be followed.

RWP 91-1151, Specia,l' Instruction 4, required that workers bag all tools and equipment or have radiation protection personnel survey items prior to removal from the contaminated work areas for EDP 11300.

Contrary to the above, on May 6,1991, contractor workers passea tools and equipment tiirough piping penetration P-17171 on the first floor of the Turbine Building steam tunnel (a contaminated work area for EDP 11300) to the second floor of the steam tunnci (a radiologically clean area) without bagging or performing surveys of the tools and equipment. This is an example of.a violation.

(341/91002-03d(DRP))

This is o Severity Level IV violation (Supplement IV).

' Pursuant to the provisions of 10 CFR 2.201, Detroit Edison Company is hereby required to submit a 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 III, 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 Not. ice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of-Violation" and should include for each violation: (1)thereasonforthe violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective 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 may be issued to show cause why the license should not be modified, suspended, or revoked, or l

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1-Notice of Violation 4 why. such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the res onse time. Under  ;

the authority of Section 182 of the Act, 42 U.S.C. 2232, t iis response shall be submitted under oath of affirmation, Dated at Glen Ellyn, Illinois f6)k.

Edward G. Greenman, Director

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this jL day of July,1991 Division of Reactor Projects n

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