ML20246C461

Notice of Violation from Insp on 890605-0716 & 24.Violations Noted:Failure to Follow Provisions of Tech Spec 3.0.3 While Both Trains of Control Room Emergency Ventilation Sys Inoperable During Mode 1

ML20246C461
Person / Time
Site:	Davis Besse
Issue date:	08/17/1989
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246C458	List: IR 05000346/1989016 ML20246C456 ML20246C461
References
50-346-89-16, NUDOCS 8908240392
Download: ML20246C461 (3)

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.. N NOTICE OF VIOLATION I

Toledo Edison Company Docket No. 50-346 As a result'of the' inspection conducted between June 5 and July 16 and 24, 1989, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the following violations were identified:

, 1. Technical Specification (TS) Limiting Condition for Operation (LCO) 3.7.6.1 requires that two independent control room emergency ventilation systems (CREVS) be operable in Modes 1, 2, 3 and 4.

1 Contrary to the above, from 5:42 a.m. until 2:55 p.m. on June 12, 1989,-

while the unit was in Mode 1, both trains of CREVS were inoperable and the provisions of Technical Specification 3.0.3 were not followed.

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

2. endix A, " General Design Criteria for Nuclear Power Plants,"

10 CFR 50, Criterion 4, App' Environmental and dynamic effects design bases" requires that components important to safety be protected from the effects of discharging fluids which may result from equipment failures.

The Service Water Pumps are components important to safety. Flooding of the Service Water Pumps is an effect of discharging fluids from which they must be protected. Rupture of the Circulating Water System piping is an equipment failure which discharges fluids.

Contrary to the above, from April 22, 1977, until February 10, 1989, the Service Water (SW) Pumps were not protected from flooding which could have resulted from rupture of the Circulating Water System due to a hole in the wall between the condenser pit and the SW tunnel.

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 8.4.1.1 of the NQAM requires that housekeeping encompasses all activities related to the control of cleanliness of facilities and equipment including protection of equipment.

Procedure DB-MN-00015, " Plant Cleanliness and Material Readiness Inspection Programs," delineates these requirements and Item 4 of Attachment 1,

" Cleanliness Inspection Guidelines," requires that tops of panels, electrical boxes and equipment are free from dust or other items.

8908240392 890817 PDR ADOCK 05000346 PDC Q

Notice of Violation 2 Contrary to the above, on June E7 end on July 14, 1989, the inspectors observed dirt and other items including pieces of metal on the tops of motor control centers which are in violation of housekeeping requirements.

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

4. Technical Specification 6.8.1.a requires that written procedures shall be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, November 1972.

Regulatory Guide 1.33 specifies that procedures are required for the operation of the Service Water system.

Contrary to the above the licensee failed to implement procedures for the Service Water System which are recommended by Appendix "A" of Regulatory Guide 1.33 as shown by the following exumples:

a. On July 9, 1989, at 1:40 a.m. the licensee did not declare Emergency Diesel Generator 1-1 inoperable as required by Section 2.9 of Procedure SP1104.11, " Service Water System Operating Procedure."

b. On July 9, 1989, the licensee did not electrically align the Service Water Pump 1-3 strainer and blowdown valve to Bus E12C when aligning Service Water Pump 1-3 to Service Water Loop No. 1 as required by Procedure SP1104.ll.

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

5. 10 CFR 50.73(a), requires that the holder of an operating license submit a Licensee Event Report for any event described in Paragraph 50.73 within 30 days after the discovery of the event. The occurrence of any condition or event that results in the nuclear power plant being in a condition cutside the design basis of the plant is an event described in Paragraph 50.73. The design basis of the plant includes adherence to 10 CFR 50, Appendix A. " General Design Criteria for Nuclear Power Plants," Criterion 4, " Environmental and dynamic effects design bases."

Flooding of the Service Water Pumps with circulating water is a dyntaic effect from which the Service Water Pumps were not protected.

Contrary to the above, on February 7, 1988, the licensee identified that the plant had been operated outside the design basis from April 22, 1977, until February 7,1988, anc' did not submit an LER for the event until May 10, 1989; more than 30 days after the discovery of the event.

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

6. 10 CFR 50, Appendix 8, Criterion V, requires that activities affecting quality shall be prescribed by procedures appropriate to the circumstances.

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Notice of Violation 3 l Contrary to the above the licensee knowingly issued a fire protection procedure which contained errors which is not appropriate to the circumstances.

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

7. Technical Specification 3.7.9.1 requires that the NRC be notified by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of an inoperable. fire suppression system.

I Contrary to the above the licensee determined on July 8, 1989, that a fire suppression operability surveillance which is required to be performed at least every 31 days had not been performed since May 3, 1989. lhe licensee reported this event to the NRC on July 11, 1989, which was in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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

8. Technical Specification 4.7.9.1.1.c requires the fire suppression water system be demonstrated operable by verifying that each valve in the flow path is in its correct position at least every 31 days.

Contrary to the above the licensee verified the fire suppression water system valve positions on May 3, 1989, and did not verify their position again until July 8, 1989, which is in excess of 31 days.

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

9. Technical Specification 4.11.1.1.1 requires radioactive liquid wastes shall be sampled and analyzed prior to the release of each batch.

Contrary to the above, on July 14, 1989, the licensee released approximately 1700 gallons of liquid radioactive waste from Clean Waste Monitor Tank 1-1 prior to sampling the contents of the tank.

This is a Severity Level V 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 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.

i Dated

% uit 17,/ Wf 6

YY R. C. Knop, Chief U Reactor Projects Branch 3 l

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