IR 05000341/1988033
| ML20244A727 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/04/1989 |
| From: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20244A717 | List: |
| References | |
| 50-341-88-33, NUDOCS 8904180163 | |
| Download: ML20244A727 (14) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION'III-Report No. 50-341/88033(DRP)
License No. NPF-43 Docket No. 50-341-Licensee: The Detroit Edison Company.
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6400 Nortn Dixie Highway Newport, MI 48166 Tecility Name: ~Enrico Fermi Nuclear Power Plant, Unit 2 Inspection At: Fermi 2 Site, Newport, Michigar Inspection Conducted: December 12-14, 1988, January 23-27, 1989 and-March 20-23, 1989-Inspector:
J. McCormick-Barger Approved By:
R. C. Knop, hief
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Reactor Projects Branch 3 Date
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I Inspe,c, tion Summary Inspection on December 12-14 1988, January 23-27, 1989 andMarch-20-21,_1989 (Report No. 30-341/88033(DRP))
Areas Inspected Special, unannounced safety inspection with regard to i
' licensee actions on previous inspection findings; and review of a series of allegations related to the operation of the Femi Facility.
Results: One violation was identified in paragraph 3.a.
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8904180163 890404 i
PDR ADOCK 05000341'
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DETAILS
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1.
Persons Contacted
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Detroit Edison Company
- D. Gipson, Plant Manager
- S. Catola, Vice President, Nuclear Engineering and Services
- P. Anthony,. Compliance Engineer
- R. McKeon, Superintendent Operations
- A. C. Settles, Technical Support
- D. Odland, Superintendent, Maintenance
- J. Walker, General Supervisor, Engineering
- L. Goodman, Director, Nuclear Licensing
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- R. Stafford, Director, NQA/PS
- G. Cranston, General Director,. Nuclear Engineering
- P. Fessler. Director Plant Systems
- W. Gilbert,' Superintendent, Maintenance
- J. Tibai, NSRG Staff Engineer b.
NRC Staff
- W. Rogers, Senior Resident Inspector, Femi
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-*S. Stasek, Resident Inspector, Fermi
- J. McCormick-Barger, Reactor Engineer, RIII Other Fermi staff members were contacted during the inspection.
- Denotes those attending the March 23, 1989, exit.
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Action on P,revious Inspection Findings (92701 and 92702)
-(Closed) Unresolved item (341/88030-07): Review of the disposition of-
' DER 88-3134 concerning deficiencies with the control of Measuring and-TestEquipment-(M&TE). As'part of the review of allegation RIII-88-A-0172 documented in paragraph 3.c. of this-report, the inspector reviewed the disposition and bases for closure of DER 88-1134.
In addition, the inspector performed an implementation review of the M&TE t
calibration and control program. From the above reviews, the inspector
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determined that the licensee has taken extensive actions to successfully improve the M&TE program. Based on the favorable findings that indicate
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that Fermi's METE program meets regulatory requirements this unresolved item is closed.
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Allegation Reviews (92701)
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AllegationNo.RIII-88-A-00110(Closedl i
The follcwing anonymous allegation was received by an NRC inspector at the Femi site on August 10, 1988.
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('oncern No.1
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The licensee is administratively closing out Deviation Event l
Reports (DER) without assuring that proper corrective actions are being performed to address the concerns. The alleger stated that DER 87-138 was administratively closed without resolving the ider.tified problems or referencing other plant programs that might resclve the problems.
For example, the Rod Sequence Ccntrol System j
(RSCS) is not designated as Quality Assurance Class 1 (QA-1) in
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the Ceco dataLtse even though it should be. Also four dedicated l
hydrogen penetrations were designated as QA-1 but a fifth penetra-tion was not designated as QA-1.
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The alleger stated that the DER was closed based on a contract with an cutside organization which would resolve the issue in the future. The elleger stated that the outside crganizatien had run out of centract money and had discontinued issuing As-Built Notices (ABNs) which might have resolved the problems.
NRC Review The inspector obtained a copy of DER 87-138 which had an attached Administrative Closure Approval Form.
The form had the following
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typed information:
"This deviation has been reviewed by Management and has been determined to have no or very low safety significance to the plant. Any further resources used on this issue would detract from significant work. This deviation is herein administratively closed, nc further action is required."
The form is then signed by a responsible engineer and his supervisor, a justification is filled out, it is checked whether or not it is safety-related, and then is approved by the Director QA, Director
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Nuclear Engineering, and the Corrective Action Review Board Chairman.
The inspector reviewed Fermi Management Directive FMD CA1, i
" Evaluation and Corrective Action," revision 1, dated May 9, i
1988. This document established the requirements for the handling
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of events or nonconforming conditions but did not provide for
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administrative closure of DERs. Section 4.6.4 of the directive
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states that "DERs shcald not be considered complete until all j
related corrective actions have been completed."
Fermi Nuclear Organization interfacing procedure FIP-CA1-01,
" Deviation and Corrective Action Reporting," dated May 23, 1988, includes in its implementation plan, general guidance for the administrative closure of DERs initiated prior to the issuance ofrevisionCoftheprocedure(January 11,1988). The criteria for document closure included determining that the need for corrective action no longer appears to be warranted because the I
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signi.ficance' of the problem has not been. proven as demon'strated
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by the successful performance of the-affected system, structure,
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or component._ The interfacing procedure also instructs the plant to close DERs initiated under P0M 12.000.052,. Revision 3, using that procedure. Since DERs' initiated under Revision 3 of
.P0M 12.000.052 is a subset of DERs written prior to. January 11, 1988, the instruction provided in the' implementation. plan of F1P-CA1-01 sheuld have been included in POM 12.000.052.
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- P0M 12.000.052 does not allow administrative' closure of DERs.
-The PCM has a detailed review and closure process that requires in Section 8.8.1; verification of Corrective Action Review Board approved corrective actions. The administrative closure process
'used.by the licensee bypassed this'and other provisions of the~POK corrective action processing requirements..
Deviation Event Report No.87-138 concerned.the identification-of items that were not being tracked as safety related as required by Fermi FSAR Appendix E.
The licensee stated in the DER that although.
Appendix E of the FSAR was deleted in'the UFSAR the commitments provided in Appendix E were considered valid requirements. The administrative closure approval form had the following justification for closure of the DER:
" Responses to part 4 of DER 87-0138 have been. prepared ar.d some are related to ongoing work'on the Q-List improvement program. Tenera Corp. is performing work under contract administered by Nuclear Engineering to update and revise the'Q-List.
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DER 87-0138 concerns will have been satisfactorily responded to
'when the Q-List improvements have been completed which is expected L
to occur'at year end 1988."
-The' justification provided above to close the DER did not meet the criteria for administratively closing DERs as provided in the implementation plan of FIP-CA1-01 or other plant' instructions in that the need for the corrective action still existed.
From discussions with the licensee, the inspector was informed that the items identified by the alleger were not resolved as alleged.
Hcwever, contrary to what was alleged, the licensee infomed the--
inspector that the outside organization responsible for reviewing and updating the Q-List is still working on the project and is '
funded through 1989. Failure of the licensee to properly' implement its Femi Management Directive for reviewing and closing DERS is a violation (341/88033-01).
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The inspector obtained a list of the DERs that were administratively
closed. The list contained a combir.ed total of 86 DERs and NCRs.
The inspector selected 15 DERs from the list and requested copies
.for further review; however, prior to' performing the review, the licensee perfonned a QA audit of selected administrative 1y closed DERs and found several problems with the closure of some of the DERs reviewed. As a result of the audit, an audit observation
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(~Au'dit89-0002, Observation No. I-) and DER (DER 89-0144)were
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generated to. document the problems.' To resolve this audit
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observation, the licensee's QA department is conducting a final closure review of all previously administrative 1y closed DERs to assure that safety issues are appropriately addressed. Any issues identified will result in reopening the associated DER to assure
- that the issues are tracked to an adequate resolution. All DERs found to have.heen adequately resolved are being closed.in accordance with the licensee's administrative procedures. As of March 22, 1989, 26 administrative 1y closed DERs.had been reviewed by QA. Twenty _of these DERs were closed and six were returned to-plant safety for further action. The licensee has discontinued administrative 1y closing DERs.
Conclusion This concern was substantiated. To assure that no safety issues were inadvertently closed without proper resolution, the licensee is performing a final QA review of all of the DERs administrative 1y closed. Any DERs that cannot be closed based on the completion of adequate corrective actions are being' reopened. A violation of administrative procedures was identified for failure of the licensee to follow its approved Fermi Management Directive concerning the
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identification and processing of DERs.
Concern N,0. 2 The new perfonnance based QA program is being improperly used and is an excuse not to write audit findings when plant staff do not : follow procedures.
NRC Review The inspector met with the QA director to discuss the QA department's program of performance based inspections / audits. The director stated that the program was implemented after his arrival on site early in 1988, and was intended to focus his inspection and audit resources on the performance /results of activities rather than strictly on compliance to approved procedures or instructions. He believed that emphasizing this performance approach would result in more meaningful findings that would help improve plant performance. The director felt that his new program has improved the content of his staff's reports and has resulted in better plant staff acceptance of the
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QA findings and observations. He also believes that many.of his own staff have grown to' accept and even appreciate this new i
performance approach as a more useful technique to imprcve plant performance. The director was adamant that this approach would not prevent the identification of compliance findings. The inspector
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supervisors and received similar coments as were provided by the QA
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director. The supervisors were very insistent that all findings, either performance or compliance related, were documented as required.
Examples of clearly compliance related QA findings were provided to the inspector as proof of their statements. The inspector ra'ndomly selected several QA audit reports and reviewed them. The reports
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identified many significant " findings" that fell in both performance and compliance related areas. Most " observations" identified tended
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toward the performance area mainly because of their lack of program violations. It appeared that the audit reports were providing significant independent verification functions and that the findings were identifying areas that needed improvement from both a compliance and prograniatic view point.
The inspector interviewed QA auditors and inspectors selected l
randomly from an organizational chart. Questions asked of the QA staff focussed around the allegation to determine if findings were being reported and if the inspection activities adequately covered the areas being reviewed. From the interviews the inspector
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determined that there was a definite division of opinion as to the effectiveness of the inspection-for-performance program. Approxi-mately one half of the staff interviewed thought that the approach
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was good and was resulting in useful findings. Some of these individuals felt that they had always inspected-for-performance, but with this added emphasis, the reports are focusing more on performance and, therefore, better received by plant staff. Other staff members were less accepting of the program and felt that it
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detracted from the QA function (as they saw it) of assuring compliance with plant commitments. Some staff members provided examples of findings that they. identified that were not allowed to be identified in their reports as findings but rather as observations. The inspector reviewed these issues and determined that management's classification of the issues as observations was acceptable. The inspector re-reviewed the selected audit reports'
observations and determined that the observations appeared to be properly classified.
In general all of the QA staff interviewed stated that their issues
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were being identified.
In some cases there were differences of opinion between staff and management concerning the classification of the issue as " findings" or " observations." However, the inspector was not provided an example of an issue that was clearly l
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inappropriately classified. There did appear to be a minor morale
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problem within the QA organization as a result of QA management changes and changes in the inspection approach.
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i Conclusion This concern was not substantiated.
Interviews with QA management and staff did not reveal that the new performance based QA program
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audit reports.. From this limited review it appears that the QA organization it functioning acceptably.
Concern No. 3 l
The alleger felt that since the QA Manager was a scod friend of the Plant Manager (both previously worked at the River Bend Nuclear Power' Plant), this did not represent independence of QA and Production. The alleger also felt that stronger people in QA have i
be.en moved out while weaker people have been moved in. Apparently I
twc "A-Grades" are in charge of v.he QC surveillance Group rather thaa more qualified "M-Grades." The alleger also stated that the i
Production QA supervisor was from River Bend.
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Personal relations between the QA manager and the Plant Manager should not in itself effect the required independence of the QA organization and plant operations. To satisfy the independence requirement the QA manager must report at a management level above the staff and management directly responsible for the operation of the plant.
In the case of the Fermi QA Manager, this individual reports to the Senior Vice President, Nuclear. This is two levels of management above the Plant Manager. From interviews with QA management and staff, the inspector was not able to obtain information that would substantiate the lack of independence alleged but_rather supported the contention that QA was in fact independent'of plant production. A review of selected QA audit reports also did not support the alleged lack of independence; audit findings were substantive and directed at improving plant performance.
The issue concerning the individuals mentioned above working previously at River Bend is not a safety concern and was not reviewed.
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To address the issue concerning QA staff qualifications (A-grades verses M-grades), the inspector reviewed the qualifications of selected QA staff and management and discussed the qualification issue with various QA staff members. The inspector was informed that the A verse M grade classification is used for pay considerations and is not directly related to worker position i
or level of responsibility. Staff position (i.e., lead auditor, etc.) is determined by the worker's qualifications, as documented in the worker's qualification file, and the worker's level of
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performance and interpersonal skills. A review of several
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personnel files of individuals that were listed on audit reports
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as lead auditors, indicated that they were well qualified for the positions. Management qualifications (supervisors) also were
'found to be adequate. The inspector noted that some QA management members had recently been moved from other plant organizations which could be viewed as either weakening the position's level of QA experience or strengthening the QA department's overall plant knowledge.
L Conclusion The inspector was not able to substantiate the concern that the QA department was not independent of plant production. The qualification concern was partially substantiated in that some individuals of responsibility have less QA experience than other i
individuals. However, these individuals were found to meet the requirements for the position and in some cases have substantial plant experience that should enhance the QA departments ability to identify problems and achieve effective corrective action programs.
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Allegation No. RIII-88-A-0135 (Closed)
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The following allegation was received by an NRC inspector at the Fermi site during September 1988.
Concern No. 1 In the Spring of 1987 a licensee employee lied to the NRC about how inputs are made to the Spare Parts Reference System (SPRS). When NRC personnel asked how inputs are made'into the SPRS, they were told that the inputs were done from procurement documents. The truth was that the input was from the Cardox file in the warehouse.
When this error was brought to licensee management's attention, nothing was done to rectify the erroneous information.
NRC Review The inspector contacted the alleger to obtain additional information. During this contact, the inspector learned from
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the alleger that the information contained in the Cardox file was orginally derived from procurement documents. The inspector
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informed the alleger that since the Cardox file information was generated from procurement documents the response to the NRC inspector's question concerning the inputs to the SPRS was essentially correct. The alleger agreed that technically this was true.
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Conclusion
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- This concern was not substantiated. The NRC inspector was not-lied-to concerning the ' source-of input to the SPRS since the alleger confirmed that the Cardox file information and procurement documents are technically one and the same.
It can be properly assumed that once manage m t was informed of the answer provided to the NRC, they; concluccd that the answer was acceptable and took no further actions.
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' Concern No. 2 The SPRS information is not supported by the controlled dccuments ir the referer:ce sections of SPRS and the system does not reflect proper parts for a given PIS Number.
NRC Review The concerns identified above were essentially the.same as concern Number 6 of' Allegation No'. RIII-88-A-0001. During the licensee's
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and the NRC's review of this previous allegation, the concern was substantiated and the licensee committed to discontinue using unvarified portions of the SPRS until a' validation effort was
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performed on the unvarified SPRS infonnation. The review of this issue was documented in Inspection Report No. 341/88008.
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Conclusion This concern was substantiated. The actions taken by the_NRC and the licensee are reported in Section 3.5 of Inspection Report No. 341/88008.
Concern No. 3
' During the Spring of'1988, Local' Leak Rete Test (LLRT) outage management directed workers to. forget procedures and get the job done on a particular LLRT test.
NRC Review
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The inspector contacted the alleger to obtain specific information.
The alleger stated that he/she had no first hand knowledge of the incident and suggested that the inspector contact a named individual
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who the alleger said was involved with LLRT testing during the Spring of 1988 and who would have knowledge of the inc'ident. The inspector contacted this same individual and was told that he/she
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Conc'lusion
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Due~to. limited non-specific information, the inspector was. unable to substantiate'the concern. The additional infomation provided.
by the alleger indicated that.the alleger did not have first hand'
knowledge of the incident and the named individual who was alleged-
.to have specific knowledge indicated,that he/sheLwas unaware'of the inciden Concern No. 4 A DER was written, but may not have ever been approved by management, that identified:the loss of control of safety related material.
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copy of the. unapproved DER form was provided.
,NRC Review The unapprov'ed DER' identified QA-1 ASME piping that wa: missing (i.e., not accounted for). This issue is similar to concern No.- 15 of Allegation No. RIII-88 A-0001. Beth cases involve missing'(unaccounted for) piping material. As documented in
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Inspection Report No. 341/88008 Section 3.14, licensee-personnel have stated that traceability requirements for safety-related material.
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only apply to that material used in safety-related applications.
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the case of_ Concern No. 15 of'A11egation No. RIII-88-A-0001, the; ~.
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licensee assumed;the missing material was used.in an application that-was not safety-related. This assumption was-based'on the fact-that'
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the licensee procures all. steel pipe safety-related-'and uses it for both: safety-related and nonsafety-related applications.- If the pipe is used in an. application. that'is-not safety-related, its traceability _
is not maintained. ' Based on the abovaA nformation the inspecto'r
'does'not'believe a DER would have been required; a safety issue does
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not exist. Therefore, no further review of this issue was warranted.
Conclusion This concern does not appear to be safety significant because loss of accountability of some safety-related p;pe is an expected event since safety-related pipe is used in non safety-related.
applications;'therefore, its traceability is not maintained.
Whether management received and/or processed the DER provided by the alleger was-not pursued due to the lack of safety significance
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of the proposed DER.
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Allegation No. RIII-88-A-0172 (Closed)
The following allegation was received by the Fermi Residers inspector in December 1988.
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Concern No. 1 Femi maintenance supervision have not followed established administrative controls for controlling Measuring and Test Eqtipment (M&TE) and were directing craft personnel to violate these sa.me administrative controls. Several nonspecific examples of incidents where management had directed nonqualified individuals ~ to check-out M&TE were identified.
NRC Review In preparation for this inspection, the inspector reviewed Fermi's administrative procedures and recent audit reports addressing the-M&TE area. Audit Report No. 88-0034, conducted May 22 thru June 7,
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1988, identified significant problems in the MATE area including problems similar tc those identitied ateve. DER 88-1134 was written on June 7, 1988 to document imprcper control of M&TE. The inspector obtained and reviewed the DER which was closed on March 4, 1989.
The audit report and associated DEp.s indicated that significant f
problems with M&TE existed at Fermi and that the concern identified by the alleger was valid. Because of the significance and repeat nature of the audit findings, licensee management attention in this
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area was intensified.
In addition, QA performed six followup surveillance of the area to review the licensee's progress in correcting the identified problems and improve the M&TE control f
program.
The QA department also moved up its M&TE audit schedule
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from 2 years to 1 year. The next audit is. scheduled for May 1989.
Due to this al'egation, the significance of the audit findings, and the apparent difficulty that licensee management had in improving the METE program following the 1987 M&TE audit, the inspector l
performed a detailed review of the licensee's corrective action program for M&TE and reviewed the current implementation of its l
program. From these reviews the inspector determined that the i
licensee performed several major activities that have resulted in
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substantial program improvements. These activities included:
(1) combining electrical, I&C, and mechanical M&TE under one program, improving M&TE issue control, building a new M&TE calibration Lab, establishing environmental monitoring of the M&TE Lab and issuing i
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stations, and improving the evaluations performed on lost or out of calibration investigation reports. The current M&TE program appears
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to be adequate and meets regulatory requirements. However, during l
the review the inspector noted that approval of the evalestions for
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M&TE found to be out-of-calibration is performed by the Responsible
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l Section Head. Due to the number and nature of the discrepant evaluations identified in the 1988 audit report, it appeared that
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I the controlling individual frcm the group responsible for the M&TE (The M&TE Lab Supervisor) should also be performing a technical review of the evaluation to assure that the evaluators'
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justifications, when concerning the operational characteristics of
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'the M&TE, are technically sound. When the_ inspector questioned the.
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M&TE Lab Supervisor concerning this matter, the supervisor indicated i
that he currently is only required to perform a line item review for i
completeness of the evaluation and not a technical review. The licensee informed the inspector that they would review the ma~tter and would consider including the M&TE Supervisor's technical review requirement in its' next procedure. revision which is currently in progress.
To'specifically address the problem concerning issuing M&TE to unqualified individuals and M&TE being used by nonqualified-l individuals, the licensee reviewed M&TE use records and identified
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several cases where individuals that did not have. specific training
checked out and used the M&TE. An evaluation was performed on each of the identified uses to assure that no safety concerns exist.
The licensee also performed training and strengthened the issuing requirements to preclude recurrence of this type of deficiency.
Currently, prior to issuing M&TE, the issuing facility clerk must verify that the user is qualified to use the equipment by checking the M&TE authorized listing. The inspector believes that the
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licensee's current implementation of its M&TE issue facility program is adequate to preclude recurrence of inappropriate issuance of M&TE
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to unqualified users in the magnitude identified by the alleger and the licensee's audit report. The scope of procedural, program, and implementation changes performed during the last year combined with training emphases and QA surveillance activities in this area have provide management confidence that craft and craft supervision are aware of the M&TE requirements and are following these requirements.
Conclusion This concern was substantiated. The licensee had previously identified this problem and has taken significant steps to improve in this_ area. The inspector has concluded that the licensee's implementation of its corrective actions have corrected the concern and is adequate to prevent recurrence.
Concern No. 2 f
It was comon practice to backdate M&TE checkout / return. Even though l
this was a common practice, a craft person was fired for such an i
action.
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NRC Review The inspector discussed this issue with the Superintendent, Maintenance and Modification. The Superintendent stated that he was
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aware of the incident where c craft person was fired for falsifying
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.M&TE use logs and provided the inspector with a copy of the DER (DER No. 88-0432) identifying the incident. The Superintendent did not believe that the practice was common.
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The inspector reviewed the DER addressing the falsification of M&TE
records.
From this review, the inspector learned that craft '
individuals performed a Technical Specification Surveillance for-Division I/II weekly 130/260 VDC Battery checks (POM 42.309.01, revision 7). During a subsequent review of the surveillance, a reviewer noted that the package did not include the identification
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of the M&TE used to verify the battery voltage. The package was returned to maintenance for it to correct the software deficiency. _
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One of.the craft workers that performed the surveillance went to the M&TE. issuing station, checked out a Fluke instrument on March 7,
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1988, entered the date, February 19, 1988, and the surveillance number, on the instrument use signout log and returned the instru-
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ment without using it. The individual also' entered the Fluke identification number on the surveillance package.
It was later determined that the above Fluke -instrument was not the instrument used to perform the surveillance and was in fact out of calibration
.during the'date that the individual entered on the log. During a
I licensee investigation of the incident, the individual admitted.
falsifying the record. The licensee subsequently fired the
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individual and performed a review of the use logs to determine if this sort of activity had occurred previously.
Based on its review, the licensee was not able to determine if M&TE falsification.had occurred in the past.
The actions taken by the licensee to resolve the problems discussed in concern number 1 above and the corrective and disciplinary actions taken to' resolve this falsification issue should be adequata to prevent recurrence. The concern that backdating M&TE checkout / return is a common practice could not be substantiated. However, based on the licensee's current program, which requires the M&TE use log to be filled out during the checkout of M&TE, there should be no conceivable reason for a Fermi worker to backdate the use log.
Conclusion
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This allegation was partially substantiated. At least one case of an individual backdating an M&TE checkout / return log was identified.
The concern that this activity was common practice could not be
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verified. The actions taken by the licensee appear to have adequately resolved the incident.
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Concern No.'3'
The alleger' voiced an opinion as to his/her. lack of confidence in.
the DER resolution process..
'NRC Review-The inspector contacted the alleger:to obtain specific examples of DERs on which the alleger was basing his/her concern-that the-DER process was not' adequate. The inspector reviewed the examples identified by the alleger as being inappropriately. evaluated and found them to adequately resolve the identified concerns. Specific.
examples are not discussed in this report to preclude possible identification of the alleger.
Conclusion The inspector was unable to substantiate the concern.
4.
Exit Interviews (30703)
'
The inspector met with the licensee representatives denoted in Paragraph I throughout the inspection period and on March 23, 1989.
The inspector sumarized the scope and results of the inspection and discussed the likely content of the inspection report. The licensee
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did not indicate that any of the.information disclosed during the inspection could be considered proprietary'in nature.
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