ML20140C533

Notice of Violation from Insp on 970118-0307.Violation Noted:Nrc Identified That When Nuclear Instrument NI-6 Was Declared Inoperable,One Channel of Reactor Protection Sys Associated W/High Flux Was Also Inoperable

ML20140C533
Person / Time
Site:	Davis Besse
Issue date:	04/07/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20140C531	List: ML20140C528 ML20140C533 ML20140C538
References
50-346-97-03, 50-346-97-3, NUDOCS 9704170083
Download: ML20140C533 (3)

Text

. - .

NOTICE OF VIOLATION Toledo Edison Company Davis-Besse NPS Docket No. 50-346 License No. NPF-3 During an NRC inspection conducted January 18,1997 through March 3,1997, violations of NRC requirements were identified. In accordance 'with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

1.

10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

states in part that, " Activities affecting~ quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstance's' and shall be accomplished in accordance with these instructions, procedures, or drawings "

Davis-Besse Technical Specification 3.3.1.1 stated that, "As a minimum, the reactor protection system instrumentation channels and bypasses of Table 3.3-1 shall be operable . . . ". Technical Specification Table 3.3-1 Item 8, "High Flux / Number of Reactor Coolant Pumps On," required that with one channel inoperable, associated action statement 3 be invoked. Administrative procedure DB-OP-00005 (Revision 05), " Operator Logs and Rounds," Section 6.2.2.d stated in part that, "The following are entries which shall be recorded in the Unit Log: . . .

Entering / Exiting a Technical Specification Action Statemern."

i Maintenance Work Order (MWO) 1-96-0708-00, " Replace DH-100, Leak Test Valve for Pressurizer Auxiliary Spray Line," specified in step 3 to " Refill, pressurize, inspect and verify no leaks." In addition, step 1 of the MWO specified, in part, to "Tagout and drain piping using . . . DH ,2736 along with DH-2735 to isolate the RCS."

Davis-Besse administrative procedure DB-DP-00013 (Revision 04), " Surveillance and Periodic Test Program," Section 6.3.7.h stated in part that, " Test prerequisites and procedure steps shall be performed in numerical sequence . . . unless optional sequencing is allowed by the procedure . . ."

Contrary to the above:

a.

The NRC identified that when nuclear instrument NI-6 was declared inoperable on Januar/ 31,1997, one channel of the reactor protection system associated with the high flux / number of reactor coolant pumps on trip was inoperable as well. However, no unit log entry was made to record entry into Technical Specification 3.3.1.1 action statement 3.

b. On February 19,1997, the NRC identified that personnel performed work outside the scope of the MWO in that the tagout establishing the isolation boundary was changed from that stated in the MWO and the auxiliary spray line was not rofilled upon completion of the maintenance activity as required by the MWO.

9704170003 970407 PDR G ADOCK 05000346 PDR ,

Notice of Violation c. On February 24,1997, the NRC identified that surveillance procedure DB-PF-03030 (Revision 00), " Service Water Pump 3 Quarterly Test,* steps 4.7.2 through 4.7.5, i are completed before stop 4.7.1, with no optional sequencing provision allowed in the procedure.

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

II. Technical Specification 3.5.2 required, in part, that "Two independent ECCS subsystems shall be operable . . ."

i Technical Specification 4.5.2.f required, in part, that "Each ECCS subsystem shall be demonstrated operable by performing a vacuum leakage rate test of the watertight enclosure for valves DH 11 and DH-12 that assures the motor operators on valves DH-11 and DH-12 will not flood for at least seven days following a LOCA: . 2. After each opening of the watertight enclosure."

Contrary to the above, the licensee identified that, on May 24,1997, the inspection port on the watertight enclosure was opened, the vacuum leakage rate test was not thereafter performed, and the associated emergency core cooling system (ECCS) subsystems were not declared inoperable.

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

Pursuant to the provisions of 10 CFR 2.201, Toledo Edison is hereby required to submit a I j

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 lit, 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 Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the 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 or a Demand for Information may be issued as to why the license should not be modified, suspended or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information

- . .. . . . ~ . ~ . . - . . . - ~ . - . . . . . - -.- - . . .

Notice of Violation '

~

\

i that you desire not to be placed in the PDR, and provide the legal basis to support your I

. request for withholding the information from the public.

i, Dated at Lisle, Illinois this _7 th day of April 1997 i

l l

l

- i

-l l

l l

l i

1 I

i l

I l

i