ML20216D881

Notice of Violation from Insp on 980107-0218.Violation Noted:On 980106,during Performance of Procedure DB-SP-03357, Rev 01, RCS Water Inventory Balance, Step 4.1.10,RO Erroneously Closed RCP Seal Return Valve MU-38

ML20216D881
Person / Time
Site:	Davis Besse
Issue date:	03/10/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20216D875	List: ML20216D871 ML20216D881 ML20216D886
References
50-346-98-02, 50-346-98-2, EA-98-080, EA-98-80, NUDOCS 9803170329
Download: ML20216D881 (2)

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NOTICE OF VIOLATION Toledo Edison Company '

Docket No.: 50 346 Davis-Besse NPS Ucense No.: NPF-3

EA 98-80 l .

l During an NRC inspection conducted on January 7 through February 18,1998, two violations of l NRC requirements were identified. In accordance with the " General Statement of Policy and l Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

1. Technical Specification 6.8.1 states, in part, that written procedures be established, implemented and maintained covering surveillance and test activities of safety-related equipment and that written procedures be established, implemented and maintained l covering the applicable procedures recommended in Appendix A of Regulatory l Guide (RG) 1.33, November 1972.

A. Technical Speafication Surveillance Requirement 4.4.6.2.1.d states, in part, that a reactor coolant system water inventory balance be performed at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during steady state operation.

l Procedure DB-SP-03357, Revision 01, "RCS Water Inventory Balance," l l implements Technical Specification Surveillance Requirement 4.4.6.2.1.d.

Step 4.1.10 of Procedure DB-SP-03357 requires that Domineralized Water Isolation Valve DW-68318 be opened.

B. Appendix A of RG 1.33, November 1972, Section A. 4, requires administrative procedures for procedure adherence. Procedure NG-DB-00225, " Procedure Use and Adherence," implements RG 1.33, to establish and implement procedures covering adherence.

i Step 6.8.1 of Procedure NG-DB-00225 requires, in part, that procedures M l performed as numerically sequenced in the body of the procedure.

Contrary to the above:

l A. On January 6,1998, during performance of Procedure DB-SP-03357, l Revision 01, "RCS Water inventory Balance," Step 4.1.10, a reactor operator erroneously closed Reactor Coolant Pump Seal Retum Valve MU-38 instead of opening Domineralized Water Isolation Valve DW-6831B.

B. On February 11,1998, the licensee did not property perform the sequence of steps in Procedure DB-OP-06001,

• Boron Concentration Control," in that a reactor operator failed to complete Step 3.5.18 to open Booster System Bypass Valve WC-3526 while performing Procedure Steps 3.5.17 through 3.5.19.

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

2. 10 CFR 50.72 (b)(1)(ii)(B), "Non-Emergency Events - one-hour reports," requires, in part, that the licensee notify the NRC as soon as practical and in all cases within one hour of the occurrence of a condition that is outside the design basis of the plant.

9003170329 980310 i; PDR ADOCK 05000346 G PDR 3

Notice of Violation Contrary to the above, on December 12,1997, the licensee did not notify the NRC within one hour of the discovery that the speed sensing circuitry for EDG #1, equipment required for safe shutdown of the plant during a postulated fire, was not designed in accordance with 10 CFR Part 50, Appendix R, design criteria for hot short protection. The design deficiency of the speed sensing circuit is a condition outside the design basis of the plant.

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 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 lil, 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 clearty marksd 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 i have been taken and the results achieved, (3) the corrective steps that will be taken to avoid I further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately -

addresses the required response. 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.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

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. If personal privacy or proprieta y information is ,

I necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your i response that deletes such information, if you request withholding of such material, you mus.1 specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will .

create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois this 10th day of March 398