ML20237K007

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Notice of Violation from Insp on 870609-0720.Violation Noted:After Completion of HPCI Testing on 870604,test Return valve,E41-FOI,not Closed & Electrically Disabled Until Brought to Attention by Resident Inspector
ML20237K007
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 09/01/1987
From: Greenman E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20237J982 List:
References
50-341-87-26, NUDOCS 8709040158
Download: ML20237K007 (4)


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. NOTICE OF VIOLATION Detroit Edison Company.

Docket No. 50-341

~ As a result of the inspection conducted on June 9 through July 20, 1987, and in accordancs with the " General Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C (1985), the following violations were identified:

i 1.

License Condition of Section 2.c(9)(a) of the Fermi 2 Facility Operating License NPF-43, in the area of fire protection, states in part, " Detroit Edison shall implement and maintain in effect all provisions of the approved fire. protection program as described in its Final Safety Analysis Report (FSAR)' for.the facility through Amendment 60 and as approved in the SER Supplement No.

5."

In. approving the fire protection prognm as described in the FSAR',

Supplemental SER 5, Appendix E,Section VII, C requires in part, "The test return valve from the RCIC and HPCI systems to the CST will be electrically disabled, i.e., tagged out, during' normal plant operation....The return valve will only be operable during HPCI or RCIC testing periods."'

Contrary t-the above, after completion of HPCI testing on June 4,1987, at 3:00 a.m..EDT, the test return valve, E41-F01, was not closed and l

electrically disabled until brought to their attention by the resident inspector at approximately 11:00 p.m. EDT on June 4, 1987.

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

2.

10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings", states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a ' type. appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Instructions, procedures, or drawings s' hall include appropriate quantitative or qualitative ecceptance criteria for determining that important activities have been satisfactorily accomplished."

Plant Operations Manual (P0M) 21.000.01, " Conduct of Shift Operations,"

Revision 33, dated June 2,1987, states in Paragraph 8.3, Removal From or Return to Service of a System or Component, " Manipulations of any mechanical or electrical components during normal or emergency conditions shall not be made without prior authorization from the CRNSO.

This authorization should be as close to the actual. time of performing the manipulations as possible. An Abnormal Lineup Sheet, if required, shall be filled out as soon as practical after such manipulations." Paragraph 8.3.1.3 further states, "An Abnormal Lineup Sheet (ALS) shall be prepared for use by-the operator for the accomplishment of the isolation as l

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required by' General Administrative Procedure 12.000.12, ' Tagging and 1

Protective Barrier System.'"

P1 ant Operations Manual (POM) 12.000.080, " Conduct of Electrical Field Activities," Paragraph 7.5.1 states, "An independent second check of restoring to normal shall be. performed for all. interim alterations performed under work orders designated as Safety-Related on the Work

. Order Package Attachment A."

Plant Operations Manual (POM) 24.000.02, "Shiftly, Daily, Weekly and Situation Required Surveillance," states in Step 6.3.3,."A Check mark should be used only if no value.is available to be recorded such as observing an annunciator status.

In all cases where a value is observed to satisfy a numerical criterion of this procedure, it should be recorded."

Plant Operations Manual (P0M) 12.000.52, " Deviation and Corrective Action

, Reporting," in Paragraph 6.5 requires all Fermi 2 organizational unit supervisors and personnel be responsible for determining the need for initiating a deviation report and promptly notifying their immediate supervisor whenever they discover a condition adverse to quality.

Contrary to the above:

j a.

On June 4, 1987, the HPCI Turbine Exhaust Line Drain to the suppression chamber valve, E41-F022, was found in the closed position without an Abnormal Lineup Sheet identifying this abnormal position.

b'.

An independent second check was not performed when the post accident recorders were returned to normal following preventative maintenance on which the work order had been designated as Safety-Related.

c.

On June 12, 1987, Procedure P0M 24.000.02 was not properly.

implemented in that the numerical values specified in Attachment 9 Section 5 of POM 24.000.02 for electrical bus voltages were not recorded.

d.

On May 23, 1987, licensee personnel did not properly determine the need for initiating a deviation report and notifying their immediate supervisor when a design drawing was not consistent with the as-built condition of the plant, a condition adverse to quality, in that a deviation report was not initiated.

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

l 3.

Technical Specifications surveillance requirements Section 4.7.7.3.2.b.2 states that the required low pressure C02 systems shall be demonstrated operable "at least once per 18 months by verifying flow from each nozzle during a ' Puff Test.'"

l Notice of Violation 3

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Technical Specification 4.0.2 states, "Each surveillance requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance interval."

Contrary to the above, the licensee failed to verify flow from each low pressure CO2 nozzle within the required time interval plus the 25%

extension.

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

4.

Technical Specifications surveillance requirements 4.4.3.2.1. states in part, "The reactor coolant system leakage shall te demonstrated to be within each of the above limits by:

b. Monitoring the primary containment sump. flow rate at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and c. Monitoring the drywell floor drain sump level at least once per four hours.

Technical Specification 4.0.2 states, "Each surveillance requirement shall be performed within the specified time interval with a maximum

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allowable extension not to exceed 25% of the surveillance interval."

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Contrary to the above, on June 7,1987, the licensee failed to properly monitor the primary containment sump flow rate and drywell floor drain sump level within the specified time interval plus the 25% extension.

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

5.

Technical Specifications surveillance requirement Section 4.8.1.1.1 states, "Each of the required independent circuits between the offsite transmission network and the onsite Class 1E distribution system shall be determined operable at least once per seven days by verifying correct breaker alignments and indicated power availability."

Contrary to the above, at 0545 on June 12, 1987, actions taken to verify offsite power source availability were inadequate in that the dccument used, POM Procedure 24.000.02, did not prescribe all of the necessary breaker alignments and indicated power availabilities between the offsite transmission network and the onsite Class 1E distribution system.

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

6.

Technical Specification surveillance requirement 4.6.1.4.d.1 states, "Each MSIV leakage control system subsystem shall be demonstrated operable by verifying the pressure control instrumentation to be operable by performance of a channel check at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Technical Specification 4.0.2 states, "Each surveillance requirement shall be performed within the specified time interval with a maximum

. allowable extension not to exceed 25% of the surveillance interval."

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l Contrary to.the above, from June 13-18, 1987, the licensee failed to channel check the division II MSIV leakage control system subsystem pressure control instrumentation within the specified time interval of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> plus 25%.

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

With respect to Item 3, the inspection showed that action had been taken to correct the identified violation and to prevent recurrence. Consequently, no reply to this violation is required and we have no further questions regarding this matter.

With respect to Items 1, 2, 4, 5, and 5, 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 shown.

SEP 0 1 i987

[h Mm,d Dated E. G. Greenman, Deputy Director DivisionofReactorProjects