ML20006B031
| ML20006B031 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/24/1990 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20006B030 | List: |
| References | |
| 50-341-89-24, NUDOCS 9001310248 | |
| Download: ML20006B031 (3) | |
Text
NOTICE'0F VIOLATION Detroit Edison Docket No. 50-341 Fermi 2 License No. NPF-43 i
As a result of. the inspection conducted on October 30 through November 3, and November 13 through November 17,1989, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1988), the following violations were identified:
1.
_10 CFR 50, @ edix B, Criterion V, as implemented by Section 17.2.5 of the Detroit Ecuon Quality Assurance Manual, requires that' activities affecting quality be prescribed by documented instructions, procedures, and drawings, and that those activities be accomplished in accordance with those instructions, procedures,-and drawings.
Contrary to the above:
a.
An approved Transient Combustible Review Worksheet was not obtained for 19 barrels of lubricating oil as required by procedure NPP-FPI-01, " Fire Protection," Revision 2.
As a result, the oil was inappropriately transported and stored on the fourth floor of the reactor building.
(341/89024-01A) b.
Adequate work instructions were not provided in WR 025C890721 to--
disassemble and reassemble check valve E1100F050B. This resulted in reassembly of the valve using incorrect match marks that prevented the valve from stroking.
(341/89024-018),
An operator did not follow Radiation Work Permit 89-001, which c.
included wearing gloves during temporary. installation of a pressure gauge on a core spray pump, as_ required by procedure FIP-RCl-01,
" Accessing and Working in Radiologically Controlled Areas."':As a l
result, during installation of the gauge, the operator came_in i
contact with potentially contaminated water'from the condensate l
storage tank.
(341/89024-01C) l d.
Many instances of nonconforming conditions were not documented and i
i evaluated as required by Specification 3071-128 Std. ET-3-1,
" Electrical Cable Damage Evaluation and Repair Procedure - QA1 and Non-QA1,'.' Revi sion AH. As a result, the use of butt splice repairs and Raychem splices, including engineering evaluations following repair are in_ question because the type of repair was not documented, nor were drawings revised to indicate the type of repair made.
(341/89024-010)
Mechanical craft workers omitted-steps 8.4.and 8.5 from installation e.
procedure 0298-60684 without obtaining concurrence from nuclear engineering and did not follow drawing C5140-300 nor the instructions associated with the installation of EDP-5546, "MSIV Manifold Assemblies," Revision 2.
As a result, the air supply system was not purged during installation of the MSIV manifold assemblies in accordance with EDP-5546, "MSIV Manifold Assemblies," Revision 2, 48 900124 CM 05000342 i
O FDC
and steel plugs from discarded manifolds were utilized to plug one <
of two 4 way pneumatic valve exhaust ports on each newly installed MSIV manifold, which was not consistent with drawing C5140-300.
(341/89024-01E).
f.
An Issue Facility Clerk failed to verify that the due date had not expired for the calibration interval specified on the calibration sticker of a pressure test gauge as. required by procedure NPP-MTI-01,
" Measuring and Test Equipment Program," Revision 0, Section 6.9.2.4 As a result, the gauge, which was past the calibration due date, was issued for the performance of NPP 43.000.002, "ASM6 Section XI Relief Valve Setpoint Test," (341/89024-01F) g.
Users of M&TE did not ensure that the equipment's calibration had not expired nor would expire during use as required by procedure NPP MTI-01, " Measuring and Test Equipment Program,'t Revision 0, Section 6.10.1.3.
As a result, pressure gauge PG-127-M for testing of Relief Valve B21F031A, was issued on September 28, 1989,- the calibration interval expired October 10, 1989, but the gauge was'not returned until October 21,.1989, which was 11 days past the calibration due date.
(341/89024-01G) 4 h.
A documented and approved change was not made to Potential Design Change 8534 before implementing the change as required by procedure FIP"CMI-01, " Potential Design Changes," Revision 2.
(341/89024-01H) 1.
Operations personnel did not stroke check valve E1100F050B on October 24, 1989, prior to accepting the work performed according to work request 025C890721 as required by procedure NPP-35.000.231,
" Exercisable and Spring Assist Closing Check Valves," Revision 21.
As a result, operations accepted a component that had been incorrectly reassembled and would not' stroke.
(341/89024-01I) j.
Inadequacies in procedures 24.203.04, " Core Spray Valve Operability and Position Verifictaion ' Test," Rev. 20, and 24.204.04 "RHR Shutdown Cooling and Head Spray Valve Operability Test," Rev. 20,-
resulted in the failure to full stroke test four testable check valves in the RHR and Core Spray Systems.
(341/89024-01J)
This is a Severity Level IV violation (Supplement 1).
2.
10 CFR 50, Appendix B, Critorion.XVI, as implemented by the Detroit Edison Quality Assurance Manual, requires that measures be established to assure conditions adverse to quality are promptly. identified ~and corrected.
In the case of significant conditions adverse to quality, the measures shall-assure that the cause of the condition adverse to quality is determined and corrective actions taken to preclude repetition, and that the signifi-cant conditions adverse to quality, the causes of the condition, and the corrective actions taken are documented and reported to the appropriate levels of management.
Contrary to the above:
i 2
Corrective action was not talen by the licensee to preclude repetition a.
of several self identified significant conditions adverse to quality.
During licensee audit 88-0113 and again in audit 89-0142, ineffective or absence of pre-job briefings by first line supervisors was ident--
ified as a significant problem. This condition still existed and-contributed to several of the problems identified during this-inspection with inadequate planning, review, and coordination 'at'the supervisor and craft level, which resulted in maintenance personnel spending excessive time in contam5n d ed and radiation areas. (It was noted in. licensee audit 89-01Hi, an evaluation of the' corrective action program, that "the completeness of corrective actions taken in all cases is less than effective.")
(341/89024-03A) b.
Measures have not been established =to assure that conditions adverse to quality are promptly identified and corrected.
Procedure.NPP-mal-04,
" Conduct of Maintenance," Revision 1, includes a definition of
" conditions adverse to quality" that precludes the need to write Deviation Event Reports in almost all cases, which eliminates review, evaluation, and corrective action. As a result, several instances were noted during the inspection where Deviation Event Reports should have been written but were not. (341/89024-038)
Corrective action was not effective in precluding repetition of c.
procedural violations in the area of maintenance.
Procedural violations were previously identified in Violation-341/88007-03.with three examples, and in Violation 341/88031 with two examples'.
During this inspection, as described in Violation'1, ten examples'of procedural violations were identified.
(341/89024-03C)
~ t Pursuant to the provisions of 10 CFR 2.201, you are required to-submit to -
this office within thirty days of the date of this Notice a written-statement or explanation in reply, including for.each violation:
(1) the-corrective actions that have been taken and the results achieved; (2) the corrective actions that will be taken to avoid further violations; and-(3) the date when full compliance will be achieved. ~ Consideration may'be given to extending your response time for good cause shown.
&wetwf N MO hhc Da)4f H. J. Mi 1
, Director
(/
Division Reactor Safety i
a i
.1 3
i
'