ML20234C686
| ML20234C686 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/24/1987 |
| From: | Guldemond W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20234C685 | List: |
| References | |
| 50-346-87-08, 50-346-87-8, NUDOCS 8707060615 | |
| Download: ML20234C686 (3) | |
Text
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NOTICE OF VIOLATION Toledo Edison Company Docket No. 50-346 As a result of the inspection conducted on April 1 through May 31, 1987, and in accordance with the " General Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C (1985), the following violations were identified:
1.
Technical Specification 6.8.1.f requires that written procedures shall be established, implemented and maintained covering fire protection plan implementation.
Davis-Besse Generic Guidance Memorandum POL-22 requires that a safety related fire door not be blocked open without first obtaining the shift supervisor's permission.
Contrary to the above on April 27, 1987, the licensee blocked open the safety-related fire door between the auxiliary feedwater pump rooms without first obtaining the shift supervisor's permission.
This is a Severity Level IV, violation (Supplement I).
2.
Technical Specification (TS) 6.2.3 requires that administrative procedures be developed and implemented to limit the working hours of facility staff who perform safety-related functions.
Senior reactor operators (SR0's) are members of the facility staff who perform safety-related functions.
The licensee's shift supervisors and assistant shift supervisors are licensed SR0's.
The TS requires that adequate shift coverage be maintained without routine heavy use of overtime.
The TS also requires that, if overtime is required on a temporary basis due to unforeseen problems, four guidelines shall be used.
Guideline b.
states that an individual should not be permitted to work more than seventy two hours in any seven-day period, excluding shift turnover time.
The TS requires that any deviation from the guideline be authorized by the Plant Manager, his designee, or higher levels of management, in act.ordance with established procedures and with documentation of the basis for granting the deviation.
Contrary to the above from March 26 through May 8,1987, the licensee made routine heavy use of overtime to maintain adequate shift coverage in that during eleven different seven-day periods seven different SR0's worked as shift supervisors and assistant shift supervisors for sixty four or more hours, excluding turnover time.
s707060615 870624 PDR ADOCK 05000346 G
PDR 1
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Contrary.to the above, the licensee allowed unauthorized deviations from TS Guideline b. by permitting one SRO to work 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br />, excluding turnover time, in a seven-day period from April 5-11, 1987, and by permitting one SR0 to work eighty hours, excluding turnover time and one SR0 to work 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br />, excluding turnover time, in a seven-day period from April 23-29, 1987.
This is a Severity Level IV violation (Supplement I).
3.
10 CFR 50, Appendix B, Criterion II requires that the-quality assurance program shall provide control over activities affecting the quality of systems and components consistent with their importance to safety.
The licensee implements this requirement through the Nuclear Quality Assurance Manual (NQAM).
Section 22.4.1.1 of the NQAM requires that maintenance practices shall not compromise the safety-related features of the plant.
Exposing safety-related equipment to hazards for which it is not designed compromises safety related features of the plant.
The Emergency Diesel Generator (EDG) Ventilation System is safety-related equipment.
Rags and plastic are hazards to a ventilation system if they enter the system.
The EDG Ventilation System is not designed to function with rags and plastic passing through it.
Contrary to the above, on May 6, 1987, the licensee's poor housekeeping practices resulted in the EDG 1-2 being declared inoperable because of rags and plastic being ingested by the Emergency Diesel Generator (EDG)
Ventilation System.
This is a Severity Level IV violation (Supplement I).
4.
10 CFR 50, Appendix B, Criterion II requires that a quality assurance program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures or instructions.
Toledo Edison Nuclear Quality Assurance Manual states, "All maintenance shall be prescribed and controlled by a Maintenance Work Order (MWO) and associated documents."
Contrary to the above, on April 16, 1987, a system engineer performed maintenance on the component cooling water ventilation system without a MWD.
This is a Severity Level IV violation (Supplement I).
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~With respect to Violations 1 and 2, the inspection showed that action had been taken to correct the identified violations and to prevent recurrence.
Consequently, no reply to those violations is required and we have no further questions regarding these matters.
With respect to Violations 3 and 4, 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 i
shown.
h)Yh f
Dated
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W. G. Guldemond, 01ief
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.7 -Reactor Projects Branch 2 i
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