IR 05000341/1988024
| ML20247M303 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/24/1989 |
| From: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Sylvia B DETROIT EDISON CO. |
| References | |
| NUDOCS 8906050017 | |
| Download: ML20247M303 (1) | |
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P MAY 2 41989
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D6bketNo'.:50-341'
tThe' Detroit-Edison Company.
ATTN: iB. Ralph Sylvia.
Senior Vice President-Nuclear Operations 6400 North Dixie Highway Newport, MI.48166 '
Gentlemen:
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27, 1988 and March 2, 1989, concerning'
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Thank you forfyour letters' dated October
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- the' violation which we brought'to your attention in our.. letter dated
' September: 27L1988. 'In your. letters,' you provided a response to the' Notice of '
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' Violation contained in NRC Inspection Report No.. 50-341/88024.
Based on our review of.your. revised response dated March 2, 1989, we have decided to withdraw the subject violation.
- If'you have.anyiquestions, please contact Mr. John H. Neisler of my staff at (312) 790-5141..
Sincerely,
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'Oridncl W?nad by il W. Cooper II"-
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R. W. Cooper, II, Chief Engineering Branch
' Enclosures:.
10/27/88 l'
Letter dated
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.2.: Letter dated 03/02/89
- cc': Patricia Anthony, Licensing P. A. Marquardt, Corporate Legal Department-cc:w/ enclosures:
LDCD/DCB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission Harry H. Voight, Esq.
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- Michigan Department of 89o6050o1789g0
- 2 Public Health PDR ADOCK O 341 pg-Monroe' County Office of G
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Civil Preparedness'
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05/17/89 05/p/89 05/i7 /89 05/19/89 f4
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. B Ralph SyMa
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6430 North oise Highway
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lg' h Neoport. Michsgen 48166 4-r 5w%#
' (313) 68E4150 Oct ob e r 27, 1988 NRC-88-0220 U.
S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.
C.
20555 Referenes:
(1)
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 (2)
NRC Inspection Report No. 50-341/88024 da ted September 27, 1988 Subject:
Response t o Notice of Violation.
Attached is the reply to the Notice of Violation contained in NRC Inspection Report 88024.
The violation was issued f or perceived procedural inadequacies in the controls for vendor technical information.
The inspector did not cite any specific instances where the perceived procedural inadequacies led to safety related work being performed using unreviewed vendor information.
Therefore, Detroit Edison denies this violation.
If you have any question, contact Fatricia Anthony at (313) 586-1617.
Sin ce rely.
Y's.
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cc A. B. Davis R. C. Knop N. G.
Rogers J. F.
Stang Region III
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U.
S.~ Nucloor Rogulotory Ceonicoien
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Octobor 27 1988-
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NRC-80-0220 P-age 2
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bec:
C.
Borr. (WPSC, Inc)
S. G. Catola G.
Cranston P.-Fessler J.
E. Flynn D.
R. Gipson L.
S. Goodman o
D. Hahn '(Michigan Dept /Public Health)
C. A. Naegeli D. J. Odland W.
S. Orser G.
R. Overbeck C.
Settles R.
B.
Stafford F.
J.
Svetkovich B.
R.
Sylvia R. J.
Szkotnicki G. M. Trahey W.
M. Tucker H.
C. Whitcomb INFORMATION MGT. (140 NOC)
NRC Chron
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NSRG Secretary RACTS Coordinator UFSAR Coordinator Routing Copy Secretary's office (2412 WCB)
E.T.S.
(205 TAC)
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RESPONSE TO NRC' INSPECTION REPORT 50-341/88024
,o Statement.of Violation 50-341/88024-01
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e During the course of a routine _ safety inspection,which examined implementation of commitments to Generic Letter 83-28, an apparent violation was identified in the_ area of control of vendor technical information.
The Notice of Violation states:
"10 CFR 50, Appendix B, criterion VI, requires that measures shall be established to control the issuance of documents and shall assure that documents, including changes, are reviewed and approved and used at the location where the activity is performed.
The Fermi 2' Updated Safety Analysis Report, Chapter 17.2.6 requires that documents defining the performance of quality reisted activities are controlled to'
ensure that only current and correct information is used at the work location.
Contrary to the above, procedures established to control vendor equipment technical information were not adequate to ensure that only reviewed, approved, and current vendor technical information is used at the work location."
This violation addressed two concerns:
1)
Procedures FMD DC1, Revision 0,
" Document Control", and NE 2.5.10 Revision 3
" Vendor Manuals", h ave n o requirement to collect.-review. and control existing vendor technical inf ormation pertaining to plant saf e ty-relat ed st ructures, systems, and components that are in possession of individuals, shops, or departments onsite.
The inspector observed vendor information in each building visited but there was no indication that the inf ormation had been reviewed to determine its applicability to plant components.
2)
One of the manuals the inspector selected f or review was the vendor manual for the core spray pump discharge check valve, a safety-related code valve that was included in the licensee's inservice inspection program.
The inspection report states that the inspector was inf ormed by personnel in the Production f
Information~ Center (PIC) that the manual was in use and-had not been reviewed and approved.
j Responses Af ter an extensive review of the f acts and interviews with all personnel involved. Detroit Edison does not agree that a vioistion exists on this matter.
In FMD DC1, step 4.6.4 states:
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RESPONSE.TO NRC INSPECTION REPORT 50-341/88024
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i Response (con't)
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" Uncontrolled copies may be provided for general reference u s e.-
Recipients shall ensure that such copies are not used to perf orm any activity f or which knowledge of the most current revision of the document is required.
Uncontrolled copies of documents.shall not require a control level stamp."
During his inspection, the inspector did not
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identify any instances where this was not adhered to.
t The requested vendor manual for the core spray pump discharge check valve was classified as informational use only and the New Automated Record Management System (NARMS) database correctly reflected the designated control level.
Prior to the use of this manual in safety related activities, the existing program requires'that the manual be' processed q
through the Vendor Manual Review Group.
Although the i
individual manuals are reviewed on a pre-established schedule, the priority of a specific manual-review can be increased on an as needed basis.
In the case of the core spray pump discharge check valve vendor manual, high priority f or review was not considered necessary since use of this manual for safety-related activities was not yet required.
10CFR50. Appendix B.
Criterion VI, requires that controlled documents be used for performance of safety-related activities.
By procedure FHD DC1 step 4.11.6. Detroit Edison's program requires the following:
"Only CONTROLLED or VASD [ CONTROLLED - VOID AFTER STAMPED DATE] copies of vendor instructions and manuals that have been approved by Nuclear Engineering shall be used to perf orm safety-related work or to develop safety-related procedures".
Therefore. Deco's
procedures fullfill the requirements of Appendix B.
Crit e rio n VI.
The results of our investigation into this matter will be documented and made available at the site for the inspector's review if you have any further questiens on this.
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O. Ralph sevb Senior WCe Presioent
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6400 North omie Heghway
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Newport. Mschegan 48166
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(313) 58 & 4150 March 2 1989 NRC-89-0023 U.
S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.
C.
20555 References: (1)
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 (2)
NRC Inspection Report No. 50-341/88-024-01 dated September 27, 1988 (3)
Detroit Edison Response to Notice of Violation. NRC-88-0220, dated October 27, 1988 Subject:
Revised Response to Notice of Violation 50-341/88-024-01 Attached is our revised response to the Notice of Violation (NOV) contained in NRC Inspection Report 88024 (Reference 2)
The. violation was issued for perceived procedural inadequacies in the controls for vendor technical information.
In Reference 3. Detroit Edison Company (DECO) provided our original response to thelNOV.
In Reference 3, DECO denied the violation on the basis that'there was ne_ specific instance where the_perce.ived-procedural inadequacies led to safety related_ work being performed ^using~unreviewed vendor ^information.
Subsequently, in telephone conversations between L.
S. Goodman and T. L.
Riley of my staff and J. J. Harrison and J. H.
Neisler of Region III, it was determined that additional information was needed by the NRC to finalize your review of the violation.
Enclosed is a revised response to the NOV which incorporates the requested information.
Although Deco still does not consider the circumstances involved to be a violation.
- management recognizes the need to ensure that unapproved vendor manual information is not used for safety-related applications.
Based on further review of this matter, the revised NOV response includes additional training of personnel on the programmatic requirements for use of only controlled information and a discussion of our plan to stamp unreviewed
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Nuclear Regulatory Commission March 2 1989
NRC-89-0023 Page 2 vendor manuals to not be used f or saf ety related work, to the extent practicable.
DECO considers these actions as enhancements'to ensure proper implementation of the program requirements already in place at Fermi 2.
If you have any questions, contact Terry L.
Riley. Supe rvis o r of Compliance and Special Proj ec t s, at (313) 586-4041 or 586-1684.
Sincerely
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i cc:
A. B.
Davis R.
C. Knop W.
G.
Rogers J.
F.
Stang Region _III
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REVISED RESPONSE TO NRC VIOLATION 88-024-01
Statement of Violation 50-341/88024-01
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During the course of a routine safety inspection which examined implementation of commitments to Generic Letter 83-28, an= apparent violation was-identified in the area of control of vendor technical information.
The Notice of Violation states:
Criterion VI, requires that measures
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shall be established to control.the issuance of documents and shall assure that documents, including changes, are reviewed and approved and used at the location where the activity is performed.
The Fermi 2 Updated Safety Analysis Report, Chapter 17.2.6 requires that documents defining the performance of quality related activities are controlled to j
i ensure.that only current and correct information is used at
.
the work location.
Contrary to the above, procedures established to control vendor equipment technical information were not adequate to ensure that only reviewed, approved, and current vendor technical information is used at the work location."
This violation addressed two concerns:
1)
Procedures FMD DC1 Revision O.
" Document Control", and NE 2.5.10 Revision 3
" Vendor Manuals", have no requirement to collect, review, and control existing vendor technical information pertsining to plant
,
safety-related structures, systems, and components that l
l are in possession of indiv id u al s, shops, or departments onsite.
The inspector observed vendor information in each building visited but there was no indication that the information had been reviewed to determine its applicability to plant components.
2)
One of the manuals the inspector selected for review was the vendor manual for the core spray pump discharge
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l check valve, a safety-related code valve that was l
included in the licensee's inservice inspection l
program.
The inspection report states that the inspector was informed by personnel in the Production Information Center (PIC) that the manual was in use and had not been reviewed and approved.
Response:
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Af ter an extensive review of the facts and interviews with all personnel involved, Detroit Edison does not agree that a violation exists on this matter.
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REVISED RESPONSE TO NRC VIOLATION 88-024-01
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In FMD DC1, step ).6.4 states:
" Uncontrolled copies may be provided for general reference use.
Recipients shall ensure that such copies are not used to perform any activity f or which knowledge of the most current revision of the document is required".
During his inspection, the NRC inspector did not identify any instances where this was not adhered to.
-The requested vendor manual for the core spray pump discharge check valve was classified for informational use only and.the New Automated Record Management System (NARMS) database correctly reflected the designated control level.
Prior to the use of this manual in safety-related activities, the existing program requires that the manual be processed through the Vendor Manual Review Group in Nuclear Engineering.
Although the individual manuals are reviewed on a pre-established schedule, the priority of a specific manual review can be increased on an as-needed basis.
In the case of the core spray pump discharge check valve vendor manual -
high priority for review was not considered necessary since use of this manual for safety-related activities was not-yet
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required.
It is noted.that this manual has now been approved by Nuclear Engineering.
10CFR50, Appendix B, criterion VI, requires that controlled documents be used for performance of safety-related activities.
By procedure FMD DC1, step 4.11.6 Detroit Edison's program requires the following:
"Only CONTROLLED or VASD [ CONTROLLED - VOID AFTER STAMPED DATE] copies of vendor instructions and manuals that have been approved by Nuclear Engineering shall be used to perform safety-related work or to develop aafety-related procedures".
Therefore, DECO's current procedures fulfill the requirements of Appendix B.
Criterion VI.
The Quality Assurance organization reviews work packages and i
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other documents, as well as performs periodic audits, to ensure these requirements are met.
During the Maintenance Procedure upgrade, a review was performed to check that all vendor manuals referenced in safety-related procedures have been reviewed.
However, after further discussions with NRC Region III personnel on this matter. DECO management has re-reviewed the circumstances surrounding this potential violation.
Although DECO still considers the basic elements of a proper vendor manual control program are already in place, enhancements will be made to ensure safety-related work is performed using only approved vendor manual ?nformation.
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P.EVISED RESPONSE TO NRC VIOLATION 88-024-01
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Additional train'ing and information dissemination will be conducted on the Fermi program and the procedural requirements associated with the use of controlled vendor information in the performance of safety-releted work.
Maintenance personnel will receive specific training on the requirements of FMD DCI and FIP-DC1-02 associated with the control, review and approval of vendor manual information.
This training will be completed by June 30, 1989.
(Note that procedure FIP-DCl-02 Rev.
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entitled " Vendor Manuals". has superseded NE-2.5.10 cited in the NRC Violation).
Step 5.2 of FIP-DC1-02 states " Vendor Manuals received by Nuclear Generation organizations or personnel shall be directed to Engineering Support Nuclear Engineering for processing and control".
FIP-DC1-02, which was approved December 16 1988, prescribes the methods for review, approval and control of vendor manuals, and changes to vendor manuals.
An article on the use of vendor manual information will be issued in the site newsletter, the Fermi 2 Moderator, which receives s i't ew id e distribution.
This article will focus on DECO's program requirements as they relate to all personnel and will be published by June 30, 1989.
Finally, as committed in our discussions with Region III personnel. DECO will stamp uncontrolled vendor manuals "Do Not Use for Safety Related Work".
This action will be done to the extent practicable since DECO considers this an
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enhancement to the existing program controls.
In addition.
this a departure from the existing program for control of all documents on site.
Uncontrolled copies of documents other than vendor manuals will not be so stamped.
Stamping of uncontrolled copies of vendor manuals will be completed by June 30, 1989.
FHD DC1 and FIP-DC1-02 will be revised by June 30, 1989, to reflect the new stamping requirements for vendor manuals.
Based on our discussions with Region III personnel, we trust that the above enhancements will be sufficient to allow the NRC to complete their review of DECO's denial of Violation 88-024-01.
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