ML20058E199
| ML20058E199 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/23/1993 |
| From: | Burgess B, Salehi K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058E175 | List: |
| References | |
| 50-341-93-20, NUDOCS 9312060205 | |
| Download: ML20058E199 (8) | |
See also: IR 05000341/1993020
Text
{{#Wiki_filter:, .. . - - - - _ - . - - . .- =. - . _.. .- . . . ,
,. , . ' O. S. NUCLEAR REGULATORY-COMMISSION REGION III { Report No. 50-341/93020(DRS) j Docket No. 50-341 License No. NPF-43 i ! ! Licensee: Detroit Edison Company 6400 North Dixie Highway Newport, MI 48166
facility Name: Fermi 2 Power Plant inspection At: fermi 2 Site, Monroe, M1 l Region 111 Office, Glen Ellyn, IL -l ! Inspection Conducted: September 16 through September 24, 1993 ! October 18 through November 4, 1993 l . Inspector:ct wud /g J [f 3 f 'K. Salehi / / Date j /Whf j Approved By: [gv- - Date - . tr ur'gits, GI F
Operational Programs Section .; i I
Inspection Summarv !
! Inspectio:e_on September 16 - 24. 1993. apd October 18 throuah November 4.-1993 l (Report No. 50-341/93020fDRS)) i . Areas Insp_eJ;ted: Routine, announced, safety inspection by Region Ill ! , . personnel of the Quality Assurance Program. l ' ! 4 Results: Two violations were identified involving the lack of adherence to j procedural requirements and inadequate corrective actions in response to a ! Deviation Report (DER).
! J ! , '} !
- -
) .'
f ! 9312060205 931123 E 5 [[ PDit ADOCK 05000341 , Q PDR l . . .- - - - - . - - . - , . . . -. - . . - . . . . . .
--
\\ - . - .
i . - DETAILS
1. Exit Meetina Attendees I Detroit Edison Company (DECO) l D. Gipson, Senior Vice President, Nuclear Generation !
- R. McKeon, Plant Manager
l +D. Bergmooser, Supervisor, NSSS Technical Engineering l T. Bradish, Audits Supervisor J. Bragg, Group Lead, NQA Audits
- J. Conen, Sr. Engineer, Licensing
! R. Delong, Radiation Protection Manager ! P. Fessler, Technical Manager J. Flynn, Senior At'.orney, Legal l L. Goodman, Director, Nuclear Quality Assurance
+K. Howard, Supervisor, Plant Engineering l +E. Juarez, Nuclear Training ! 4A. Kowalczuk, Director, Plant Support t +P. Marquardt, legal !
- W. Miller, Director, Nuclear Licensing
' R. Newkirk, Supervisor, Licensing , J. Nolloth, Maintenance Superintendent l
- J. Nyquist, Supervisor, Safety Engineering
l J. Plona, Superintendent of Operation
K. Sessions, Supervisor, Quality Assurance ! G. Smith, Director, Nuclear Fuels i T. Stack, Supervisor, Nuclear Security
- R. Szkotnicki, Supervisor, Quality Assurance
! +J. Tibai, Principle Compliance Engineer i U. S. Nuclear Reaulatory Commission (NRC)
- W. Kropp, Senior Resident Inspector, fermi, DRP
4K. Riemer, Resident Inspector, Fermi, DRP
Other J. Crews, Consultant
- Denotes those in attendance at the telephone exit on November 4 and
' the interim exit on September 24, 1993. + Denotes those in attendance only during the telephone exit on
November 4, 1993. 7 > t 't 2 , - - - . _ , - _ __ _
--- - . .- _ - - - . . . - . , .
- ..
2. Inspection Overview ' The objective of this inspection was to examine portions of the licensee's Quality Assurance (QA) program. The inspector interviewed , staff, reviewed documents and made observations to accomplish this , ' objective. This inspection focused on QA activities performed during ! 1989 through 1991. Two violations of the NRC requirements were ! identified in this inspection for events that occurred in that period. . One violation was for not meeting the procedural requirements and the ] other was for inadequate corrective actions. l The NRC inspector concluded that:
The QA inspectors and auditors were independent in their performance of their duties. If safety issues were appropriately identified, the QA staff had documented the findings accordingly.
No safety-significant issues were identified by the inspet or ! which were missed by the QA staff.
A communication difficulty between a supervisor and other QA staff contributed to inadequate root cause analysis and determination of corrective actions.
There existed a need to improve the DER process, the determination of root cause analysis / corrective actions, and . the procedures for yellow lining drawings. ! 3.0 Inspector Evaluation . The inspector inspected the QA organization and evaluated qualification and certification of testing personnel, independence of inspections, DER resolution and corrective action, inspector knowledge concerning . selection criteria of snubbers, organization and implementation of the l fire protection program, control and retrieval of M&TE Equipment records ! and the adequacy of yellow line changes to documents. Although the
, majority of areas examined did not show safety concerns, two violations ' 4 were identified. Discussions of the inspector identified issues and the . violations are addressed in the following subsections: s i 3.1 Evaluation of ANSI /ASME N510 Oualification and Certification for Testina Personnel The NRC inspector examined the certification and qualification j requirements / records for QA inspectors and auditors. This examination generally covered the overall certification process. Selective , examinations of certification records for inspectors and auditors did , not identify regulatory deficiencies. In addition, the qualifications ' and training on ANSI /ASME N510 " Testing of Nuclear Air-Cleaning Systems," for personnel testing HEPA filters were reviewed. Based on
! l I 3 t I ,
_ .. .l - . . 3 - observations of documentation, NRC determined that liEPA filter. . . I surveillance tests, conducted in-1989 and 1991, were performed under the i sulervision of certified inspectors. Three different test procedures, 43.404.001, " Division 1 Standby Gas Treatment filter Performance Test", 43.404.002, " Division 2 Standby Gas l ! Treatment filter Test", and 43.413.001, " Control Room Emergency Filter Test", required ANSI N45.2.6 certification for the lead test persons i conducting tests. To verify that each HEPA filter test was performed j under the guidance of a lead test person, each test procedure had a
signature line for sign off by a certified lead test person. ! . The signature line for the lead test person certified to ANSI N45.2.6, ! " Qualification of Inspection, Examination and Testing Personnel for_ l Nuclear Power Plants," during the above three listed tests conducted in ' 1989 was incorrectly signed by two individuals who were not AflSI i N45.2.6 certified. The licensee stated that the tests were performed j under the observation of a certified contractor and another certified l inspector from the corporate office. However, the signature line for ! the above three tests was not initialized or signed by either of the . certified indivia als. Since the above three test procedures
specifically required ANSI N45.2.6 certification, and since the lead i persons were not certified, the licensee did not meet its own procedural requirement. Failure to comply with HEPA filter testing procedural i requirements, for signature of each test by a person certified to ANSI
N45.2.6 requirements, is a violation of 10 CFR 50 Appendix B, Criterion V (50-341/93020-01 (DRS)). .j .: The NRC inspector evaluated test documentation and determined that'the l tests were technically adequate based on the presence of a certified l contractor and another corporate office certified inspector. Review of j the security log by the licensee confirmed the presence of the certified j inspectors in areas where the tests were conducted. Quality Assurance j ' management used the security log as evidence that the certified inspectors were present and monitored the three conducte1 tests. ' Subsequent HEPA filter tests in 1991 and 1992 were conducted by the above uncertified individuals and completed satisfactorily. Completion- ! of these tests indicated an adequate knowledge level for the performance j of HEPA filter testing. The licensee has implemented training for ANSI /ASME N510 and removed ANSI N45.2.6 as a requirement for HEPA filter
testing. This removal of ANSI N45.2.6 was subsequent to a statement j from the ASME committee which confirmed the licensee's interpretation
that qualification to ANSI N45.2.6 is only one method of many that could be used to meet the certification requirement of N510. Therefore the corrective action to the violation was considered adequate and no response is required. In addition to ANSI N45.2.6 certification requirements, the above HEPA filter test procedures required ANSI /ASME N510 training for the lead test persons conducting tests. Section 4.3 of the ANSI /ASME N510-1980, Page C-4, required in part, "lests shall be made only by persons who have demonstrated their competence to satisf actorily make the specific 4 - . . , . . - . . - . . , - - .,
.. . . . - - - - .- - .. - . ' ,. e tests in question, as evidenced by experience and training." The procedures required only the lead test person be trained on ANSI /ASME N510 and certified to ANSI N45.2.6 requirements. In spite of the code and procedural requirements, the two lead test personnel who conducted the tests and signed off as lead test personnel, had not received training on ANSI /ASME N510. An audit of the test documentation by the 0A audit organization was completed on June 24, 1991. DER 91-0589 was
generated and identified the inconsistency between lack of certification
of lead test ' personnel and the procedural requirement to be certified and trained.
! As part of the corrective action in response to DER 91-0589, the licensee deleted the ANSI N45.2.6 certification requirement from the , ' procedure, but retained the ANSI /ASME N510 training requirement for lead test person. Further, the licensee developed a training course for ' ' ANSI /ASME H510. However, the licensee exempted the training requirement for three lead test personnel (including the two who had signed off on ! the test documentation), principally because they participated in HEPA ! filter testing. Documentation of a waiver request made no reference to training conducted for these individuals. Participation of these individuals in testing was not an adequate replacement for training as
specified in the licensee's Management Directive and Fermi Interfacing l Procedure FIP-TQI-16-SQ Revision 2. This procedure stated that requests ! for waivers "shall be supported by certified or authenticated documents
such as official transcripts, verifiable certificates of completion, i etc." No such documentation was identified or presented to the. l inspector to justify waiving the training requirement. Therefore, the
licensee's previous action to waive the training requirement in response
to the DER constituted inadequate corrective action. Inadequate l corrective action is a violation of 10 CFR 50 Appendix B, Criterion XVI. , (50-341/93020-2(DRS)). ' . ' Although the three lead test personnel did not receive formal training on ANSI /ASME N510, plant records indicated that they had conducted the , tests under the supervision of certified inspectors with ample familiarity with the ANSI /ASME N510 code. That participation and i subsequent on the job training for the three lead test personnel, who independently conducted similar tests appeared to be adequate. All
other personnel associated with HEPA filter testing have also rcceived ' N510 testing. The licensee has also yeviewed the procedure addressing
waivers and considered it adequate to preclude an inadvertent waiver , without sufficient basis. Because the subsequent actions appeared j adequate, the violation is considered as no-response violation.
. 3.2 Independence of Inspections and Audits Performed Durina 1989 to Present i The NRC inspector interviewed approximately 40% of the total population of onsite QA inspectors and auditors, including those who were no longer s in QA positions at this facility. The inspector did not identify issues or receive any statement that implied management was directing ' inspectors and auditors to suppress safety issues. For each QA i inspector interviewed, the clear message communicated was one that l , 5 i .. . -- -. . - - . - . - - - -
, _ - - - - . . - _ _. . ' . . . . . reflected the inspectors' ability to identify any unsafe condition, - without reprisal from management. Further, the NRC inspector did not . 1 identify any instances of safety significant issues or findings. l 3.3 Review of DERs . l Although no safety significant issues were identified during this
inspection, the results of the interviews and the review of selective i documents generated a concern. The concern was that several DERs
received less than adequate root cause analysis and determination of s corrective actions. 4 Based on review of the below DERs, the inspector determined that the l selection of a DER initiator and a DER reviewer received unnecessary. ~ attention, where more emphasis should have been placed on the root- cause analysis and corresponding corrective actions. a. DER 90-310 was related to missed documentation of inspection on l the Weld Process Contr01 sheet. The originator of this form had ! mistakenly entered "H" for " Hold" on line 2, for Pre-Fitup ! cleanliness rather than on line 3, Fitup. At the time the work j was done, the QA inspector realized the error, and performed the
necessary inspection at the Fitup. , However, he failed to document the error and that the inspection l was conducted at the intended hold point, the Fitup. Based.on i interviews and discussions with the auditors and supervisors, the i i inspector was told that the audit team and the supervisor spent
! much effort debating if it was a missed insp*: tion or inadequate documentation. In the process, the root cause and ccrrective action failed to address why the inspector had not documented that - he had noted the error and the fact that he had conducted the i j inspection. ' [ b. DER 90 324 was related to an RHR LPCI loop line check valve. A QA inspector missed yellow lining a drawing which indicated the ' ' removal of the valve counterweight. Since the yellow lining had i not taken place, the removal of the valve counterweight could not have been verified. To ascertain the removal of the counterweight, the staff had to halt the operation and visually j verify the removal of the counterweight. To address this issue, a , DER was generated. However, similar to the above case, there were difficulties concerning who should generate the DER to address ) i this issue. Had sufficient attention been provided to the true . root cause of this D:R, which was inadequate yellow lining, other later problems which were attributed to inadequate yellow lining could have been prevented. The NRC inspector evaluated management involvement in the close out of I selective DERs generated by the staff. This evaluation did 6 . 4 , .,. . .,-_..,.,,m_ - _ . .- . . , . . . . _ _ , - 2
.. -- - - . - -- . - . . - . - -_ .- - = . . - - - . .- ! .. ' not identify any major concerns alluding to management suppressing or j
attempting to suppress generation or processing of DERs. Further, the ' reviewed DERs were completed and closed within a reasonable time span. , Finally, the role of management in the review of findings was evident. 3.4 Adecuacy of Inspectors Knowledae Concernino Selection Criteria About- Installation of Snubbers
During the inspection and after review of documentation and interviews
with plant personnel, the NRC inspector investigated the role of the QA
inspectors in tne removal of snubbers and installation of struts. The !' QA inspectors were tasked with verification of which snubbers were removed and which were being replaced with struts. Removal of the snubbers and installation of struts were in accordance with a schedule e ! i and guideline established by the design engineers responsible for the snubbers. The NRC inspector determined that the QA inspectors did not need to have detailed knowledge of the selection criteria for removal of -i the snubbers. This responsibility was within the domain of the design i engineering and system engineering staff. The responsible design
engineer for this modification stated that the removal and exchange of snubbers was accomplished without any difficulties or error, j 3.5 Oroanization and Implementation of Fire Protection Procram , The inspector reviewed various past inspection reports and examined available documents pertaining to the fire protection program. Based on , the review and observations made by cognizant Region III inspectors, there were some minor problems associated with the licensee's fire protection program. Both the licensee and the NRC Region III staff.were j ' aware of these issues and were following them consistent sith their regulatory significance. The fire protection program is subject to i routine NRC inspection. 3.6 Control and Retrieval of Material and Test Eauipment (M&TE) Records from the Vault. The NRC inspector evaluated only the retrieval and storage of M&TE I records from the vault. This evaluation also included review of l selected records and interview with responsible individuals. There appeared to be no significant concerns or findings in this area. The overall control of M&TE records had been previously inspected by the NRC and concerns regarding retrieval and storage of M&TE records had been addressed by the licensee. l 3.7 Adecuacy of Yellow tine Verification Reauirement The NRC inspector examined the effectiveness of the yellow line , procedure. This procedure was an important portion of the validation of l quality assurance. Subsequent to a work order on a system the inspectors yellow lined portions of a drawing of the system which were . affected by the work order. This implied that the~ inspections of that 1 l 7 .- . __ -. _ __ . __ ._
l . , , - ' .) ' .. portions of the system were completed. If yellow lining were missed, completion of the work and the corresponding inspection would be in doubt. Inadequate and lack of yellow lining were contributing causes of _ ; several different problems in the QA organization. Descriptions of two ) examples appear in the following subsections. I
The NRC inspector evaluated the circumstances surrounding the swapping ' and installation of chart recorders in the control room and the i simulator. The chart recorder in the control room should have been ! installed in the simulator and the chart recorder installed in the j simulator should have been installed in the control room. - i This problem was previously addressed by the NRC in inspection report - Number 50-341/930012 (DRP). This and other similar issues were combined i into a violation of NRC requirements resulting in escalated enforcement. Since this issue was previously addressed by the NRC, the inspector did , not pursue this issue. However, since the root cause of this issue pertained to. yellow lined procedures, the NRC inspector conducted 1 interviews with the licensee staff regarding yellow line practices in the field. No violations of NRC requirements were identified. DERs 90-310, 90-324, and 93-363 were related to the adequacy of the _ yellow lining. This inspection identified that the licensee was aware '
, of this problem. The review of several memoranda related to QSR-92-0149 ! " indicated the licensee needs to improve the yellow lining portion of the - QA program. Discussions held between the NRC inspector and the QA ! management organization concerning the yellow lining procedure clarified
that the licensee was fully aware of this issue. t
4. Exit Meetina -
The inspector met with the licensee representatives (denoted in -) Paragraph 1) at the conclusion of the inspection on September 24, 1993,
ta discuss the scope and findings of the inspection. An interim ! telephone exit was held on October 20, 1993; and a formal exit which ? provided the results of the inspection was held via telephone on ! November 4, 1993. The licensee representatives did not identify any l document used during the inspection as proprietary. l ! l . I i
8 }}