ML20246K457

Notice of Violation from Insp on 890411-0605.Violations Noted:Testing of 16 air-operated Containment Isolation Valves Was Not Adequate to Properly Demonstrate Operability

ML20246K457
Person / Time
Site:	Fermi
Issue date:	07/11/1989
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246K438	List: IR 05000341/1989011 ML20246K435 ML20246K457
References
50-341-89-11, NUDOCS 8907180181
Download: ML20246K457 (3)

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NOTICE OF VIOLATION Detroit Edison Company Docket No. 50-341 4 Fermi 2 License No. NPF-43 i As a result of the inspection conducted on April 11 through June 5, 1989 and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedures for NRC Enforcement Actions (1988), the following violations were identified:

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1. 10 CFR 50, Appendix B, Criterion XI states in part, "A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. . ."

Contrary to the above: '

a. Testing of sixteen air-operated containment isolation valves (CIVs) was not adequate to properly demonstrate their operability. The design of the subject CIVs included both a safety-related solenoid as well as a nonsafety-related solenoid capable of venting each ClV air supply upon receipt of a containment isolation signal. No differentiation was made during testing as to which solenoid valve operated to close the individual CIVs.

b. The post maintenance testing amperage acceptance criterion, 115% of nameplate rating, following repair of the division II CCHVAC supply fan on February 12, 1989, was inadequate in that it was greater than the maximum acceptable amperage, 110% uf design calculation 4322.

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

2. 10 CFR 50, Appendix B, Criterion V, 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 shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

Procedure NPP-0P1-11, " System and Equipment Status," Rev. 3, Step 5.3.2, requires that a Limiting Condition for Operation (LCO) Sheet shall be completed for til Technical Specification systems and components determined to be inoperable regardless of the plant's operational condition.

Procedure NPP-0P1-11, " System and Eauipment Status," Rev. 3, Step 5.3.8, requires the LCtl action requirements and the actions to be taken be entered into the shift supervisor's and control room operator's log book for short term LCOs.

8907180181 890711 PDR ADOCK 05000341 G PNU

e-Notice of Violation 2 l

Contrary to above: I

a. On December 18, 1988, operations personnel failed a complete an LCO Sheet when temporary batteries were connected to supply the normal loads of 24/48 VDC battery R3200$001. The temporary batteries rendered SRM Channels A and C; IRM Channels A, C, E, and G; Radwaste Effluent Radiation Monitor RME-K604; and Fuel Pool Ventilation Exhaust Radiation Monitor Indicator and Trip Units, Channels A and C inoperable.

b. On April 12, 1989, the East Hydrogen Recombiner Fan Motor was reinstalled without appropriate acceptance criteria for a quality related activity in that the mounting torque values were not specified in the work package for Work Request No. 002C890408.

c. . On May 17, 1989, operations personnel failed to log that Technical Specification LC0 3.1.5.a.2, an eight hour LC0 action statement, was entered when the suction valve to the two standby liquid control pumps was closed rendering the system inoperable.

This is a Severity Level IV Violation (Supplement I),

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3. Technical Specification 6.8.2 states, "Each plant procedure . . . shall be reviewed periodically as set forth in administrative procedures."

Procedure FMD PR1, " Procedures, Manuals and Instructions, Section 4.14.1 states in part, "All Nuclear Production procedures . . . shall be reviewed

. . . at least once every 2 years. ..

Contrary to the above:

As of November 30, 1988, numerous nuclear production procedures (85) had not been r6 viewed within the last two years.

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

4. Technical Specification 6.5.1.6.f establishes the Onsite Review Organization (OSR0) as responsible for investigations of all violations of the Technical Specifications, including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence, to the Vice President-Nuclear Operations and to the Nuclear Safety Review Group.

Contrary to the above: ,

During 1988 and the first half of 1989 numerous violations of Section 6, Administrative Controls, of Technical Specifications were not reviewed by ]

1 OSR0 in that violations identified through a deviation event report were not forwarded to the OSRO.

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Notice of Violation 3 i I

i This is a Severity Level V Violation (Surplement I).

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5. 10 CFR 50, Appendix B, Criterion II, states in part, "The program shall i provide for indoctrination and treining of personnel performing  !

activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."

Contrary to above, on May 3,1989, two maintenance journeymen left two Technical Specification 3.7.8 fire barriers breached and did not fulfill all the requirements of transferring from a continuous fire watch to a hourly fire watch. This was due to inadequnte fire watch qualification training which did not include operability verification of the fire detectors on one side of the fire barrier when accomplishing such an activity.

This is a Severity Level IV Violation (Supplement I). '

With respect to Items 3 and 4, the inspection showed that actions had been taken to correct the identified violations and to prevent recurrence.

Consequently, no reply to the violations is required and we have no further questions regarding this natter. With respect to Items 1, 2, 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 i in reply, including for each violation: (1) the corrective actions that have been taken and the results achieved; (2) the corrective actions that will 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.

M l.I3 D89 4 w ...

Dated Edward G. Greenman, Jirector Division of Reactor Pro,)ects i

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