ML20006B029
| ML20006B029 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/24/1990 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Sylvia B DETROIT EDISON CO. |
| Shared Package | |
| ML20006B030 | List: |
| References | |
| NUDOCS 9001310245 | |
| Download: ML20006B029 (5) | |
See also: IR 05000341/1989024
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Docket No. 50-341
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The Detroit Edison Company
ATTN:
B. Ralph Sylvia
Senior Vice President
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Nuclear Operations
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6400 North Dixie Highway
Newport, MI 48166
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Gentlemen:
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This refers to the special maintenance team inspection conducted by Mr. F
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Jablonski and others of this office on October 30 through November 3, and
November 13 through 17, 1989. This inspection covered activities at the Enrico
Fermi 2 Nuclear Power. Plant authorized by NRC Operating License No. DPR-43. -The
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inspection findings were discussed with Mr..W. J. McCarthy, you, and others of
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your staff on November 30, 1989.
The inspection was conducted during the first refueling outage to assess'an'd'~
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evaluate your support and implementation of. maintenance and engineering to
assure that plant structures, systems, and components. reliably perform on
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demand. Various activities were evaluated to determine.if maintenance and
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engineering were accomplished, effective, and adequately assessed by your own,
quality verification process.-
The enclosed copy of our inspection report identifies specific areas examined'
during the inspection. Within these areas, the inspection consisted of.a.
selective examination of procedures and representative records, observations,
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and interviews with personnel.
In an attempt to-focus on those activities that
are most risk significant, insights from a Probabilistic Risk Assessment study,
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performed by the NRC, were used to select systems and components.important'to
safety.
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0verall, the inspection team concluded that maintenance an'd engineering programs
were satisfactorily implemented at the Enrico Fermi 2_ Nuclear Power Plant. An.
executive summary highlights our inspection findings.and Section 4.0 of the
inspection report provides a synopsis.of:the effectiveness of your maintenance.
and engineering-programs.
The team identified. strengths.as well as weaknesses:in. implementation of the-
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maintenance'and engineering programs. Some:of.the more significant strengths'
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were upper management qualifications,. experience, and training; radiation.-
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protection job coverage and ALARA support for major maintenance activities;
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performance based quality assurance audits; significantly improved quality of
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procedures, and dedication process for conenercial grade equipment. We are
concerned about the level of management attention being given.to a-number of-
weaknesses, which include the following.
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9001310245 900124
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ADOCK 05000341
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The Detroit Edison Company
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JAN 2 41990
1.
Corrective action - Action to correct an important self-identified
weakness identified in a 1988_ audit _ involving poor maintenance supervision
was not effective. The team considered ineffective first line supervision-
to be a major contributor to many of the weaknesses that were identified
during this inspection and during startup activities. There continues to
be failures to follow maintenance procedures in some instances; this is a
problem previously identified by NRC. During this inspection, we
identified ten instances of procedure violations.
2.
Supervisor and management involvement - Supervisors, especially in the
mechanical area, even though on the job, were not very effective in
supervising.
In several instances, there appeared to be somewhat'of-a
casual work attitude by both supervisors and journeymen. Some supervisors
did not appear attentive to detail, nor did supervisors require it of
their subordinates.
Inadequate planning and shift turnover by foremen and
journeymen was noted during the inspection as well as during NRC coverage
of startup activities. At times, this resulted in duplicated-
troubleshooting activities by successive shifts.
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3.
Planning by su)ervisors and journeymen.- Poor-planning of small
maintenance jo)s by supervisors and journeymen led to inefficient work
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resulting in unnecessary radiation dose.
Post job; feedback sheets were
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rarely used to improve work planning.
4.
Engineering involvement - While improved, there continues to be problems
with engineering support for maintenance and_ modification activities.
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There does not appear to consistently be a sense of ownership on the.part
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of design engineers for all aspects of modification work,. including
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installation and testing.
In several instances, for example, test
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acceptance criteria were not specified in design packages. ;The systems
engineering group, while staffed with well qualified' engineers, is
relatively new. As a consequence, many engineers were not heavily
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involved with maintenance activities on their systems and, in general,
the interface between systems engineers and maintenance personnel was
found to be weak.
Many of the problems identified by our inspection team had been previously
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found by others or yourself during assessments of your performance. Your
performance in response to the self identified problems is considered a
significant weakness.. In addition to responding to the violations that are
described below, we request that you provide us a written response describing
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your corrective actions to address the weaknesses discussed above, including
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how you will improve your response to self identified issues.-
During this inspection, certain of your activities appeared to be in violation
of NRC requirements, as specified in the enclosed Notice. A written response
is required. In accordance with 10 CFR 2.790 of the Commission's regulations, a-
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copy of this letter, the enclosures, and your response to this letter will be
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The Detroit Edison Company
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JAN 2 41990
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placed in the NRC Public Document Room. The responses directed by this letter
and the accompanying Notice are not subject to the clearance procedures of the
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Office of Management and Budget as required by the Paperwork Reduction Act of
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1980, PL 96-511.
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We will gladly discuss any questions you have concerning this inspection.
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Sincerely,.
CRIG!NAL S!CNED BY llVDERT J. LilLLER
H. J. Miller, Director
Division-of Reactor Safety-
Enclosures:
1.
2.
Inspection Report
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No. 50-341/89024(DRS)
cc w/ enclosures:
Patricia Anthony, Licensing
P. A. Marquardt, Corporate
Legal Department
DCD/DCB (RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
James R. Padgett, Michigan
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Public Service Commission
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Harry H. Voight, Esq.
ilichigan Department of
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Public Health
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Monroe County Office of
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Civi1~ Preparedness
Commissioner Curtiss, OCM/JC
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K. Hart, NRR/LPEB
Director / Division of Reactor
Safety RI, RII, RIV, RV
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The Detroit Edison Company
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JAN 2 41990
placed in the NRC Public Document Room. The responses directed by this letter
and the accompanying Notice are not subject to the clearance procedures of the
Office of Management and Budget as required by the Paperwork Reduction Act of
1980, PL 96-511.
We will gladly discuss any questions you have concerning this inspection.
Sincerely.
01:iGINAL S!Gt!ED DY llVDERT J. MILLI 2 '
H. J. Miller. Director
Division of Reactor Safety
Enclosures:
1.
2.
Inspection Report
No. 50-341/89024(DRS)
cc w/ enclosures:
Patricia Anthony, Licensing
P. A. Marquardt, Corporate
Legal Department
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DCD/DCB (RIDS)
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Licensing Fee Management Branch
Resident Inspector, RIII
James R. Padgett, Michigan
Public Service Commission
Harry H. Voight, Esq.
liichigan Department of
Public Health'
Monroe County Office of
Civil Preparedness
Commissioner Curtiss, OCM/JC
K. Hart, NRR/LPEB
Director / Division of Reactor
Safety RI, RII, RIV, RV
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EXECUTIVE SUMMARY
An announced NRC combined team inspection of maintenance and engineering was
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conducted at the Enrico Fermi Nuclear Power Plant during the period of October 30
through November 3, and November 13 through 17, 1989. The inspection was"
conducted to determine if established maintenance and engineering-programs had
been implemented to assure the preservation or restoration of the availability
and reliability of plant structures, systems, and components to. operate on
demand.
In the areas of maintenance and engineering, the team looked at plant -
performance, management support, and implementation.
To accomplish this task,
several maintenance and engineering related activities we.re evaluated to =
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determine if they were satisfactorily accomplished, effective, and self-assessed.
During the inspection several strengths and weaknesses were identified as follows.
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Strengths
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Management qualification, experience, training, and involvement: upper-
management personnel were very experienced; outage and start up planning meetings
were well run and organized; the Onsite Review Organization (OSRO) assured post-
outage operational readiness by use of a comprehensive final check off system;
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supervisors and managers were trained in the " Steps to Effective Plant Supervisor"~
(STEPS) program that supports the Accountability / Victim Model; operations used
a pocket sized training aid for promoting. excellence in performance by personel;
system engineers had extensive experience and technical backgrounds; personnel
were trained in corrective action; quality assurance audits and self' assessments
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were performance based.
Radiation protection: job coverage and ALARA support
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for major maintenance activities significantly contributed to-the overall hw
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personal doses during the first refueling outage.
Planning: Maintenance
planners extensively used procedures in most cases and " runners" were provided
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to expedite planning approvals. :In-service Testing (IST): data were comput-
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erized, trended, and evaluated,
Procedures: for motor-operated valve assembly /-
reassembly and setting of switches have significantly improved,'were very.
comprehensive, detailed, and user friendly;~ for I&C activities included
statements about how the activity would impact plant operations; for post
maintenance testing provided excellent guidance and criteria. Dedication
process for commercial grade equipment: adequately demonstrated the concept.of
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" critical characteristics" for safety-related applications.
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Weaknesses
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Housekeeping and material ' condition were inconsistent: pipe, electrical. cable
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and lubricating oil were improperly stored; precautions were not taken to
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protect installed equipment from ongoing work. Action was not effective to
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correct continuing problems with following maintenance procedures and self
identified weaknesses with ineffective or absence of pre-job briefings by
maintenance foremen: supervisors, especially in the mechanical area, were not-
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effective; poor planning by some supervisors of less than major maintenance
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jobs caused unnecessary radiation dose and inefficient work; work attitude was
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casual, work instructions sometimes lacked detail or were incorrect and were
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indiscriminate 1y changed; some personnel were not attentive to detail; post
job feed back sheets were infrequently completed; turnover in maintenance
management was high and extreme competitiveness between maintenance departments
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detracted from real team effort.
System engineer concept of " ownership":
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system engineers had not received specified training, were not fully aware of
system status, did not review work requests, and were not actively involved
with trending and root cause analysis; communications between systems engineers
and maintenance was poor.
Specific responsibility was not assigned for
establishing post maintenance testing requirements: post modification testing
acceptance criteria were not always included in engineering design packages,
and interf ace between engineering and maintenance was poor; in one case, af ter
a design was complete, it seemed to belong to maintenance.
Root Cause
Analysis:
Review and analysis was not done of data that indicated repetitive
root causes or recurring work described on completed deviation event reports
(DER) and work requests (WR); understanding and guidance was unclear for'
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writing DERs.
Conclusion
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Results of this inspection showed satisfactory performance and some improvement
in the establishment and implementation of an effective plant maintenance and
engineering process by the licensee of_the Enrico Fermi 2 Nuclear Power Plant.
Based on the review of past work activities, observations of ongoing work
activities, work controls, and attempts at self-assessment the inspectors
determined that overall, electrical, mechanical, and I&C maintenance and
engineering support activities were adequate and commensurate with the
components' function. Many of the problems detected by the_ inspection team had
been previously identified by others or the licensee during self assessments of
maintenance. 'However, the licensee was not effective in correcting the
problems.
Effective management and_ aggressive response to these problems is
imperative to improve performance at Fermi. As described in the' Appendix-to
the transmittal-letter, some activities were in violation of regulatory
requirements. During another NRC inspection, a continuing adverse
trend was identified with maintenance support of security equipment. (RE:
50-341/89031)
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