ML20093C255
| ML20093C255 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/21/1984 |
| From: | Jens W DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20093C235 | List: |
| References | |
| EF2-69714, NUDOCS 8410100447 | |
| Download: ML20093C255 (5) | |
Text
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Wayne H. Jens N e Ope tx>ns Deholt.
b (3 September 21, 1984 sas-4 EF2-69714 Mr. James'G. Keppler Regional' Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Reference:
Fermi 2 NRC Docket No. 50-341
Subject:
Noncompliance at Fermi 2 Inspection Report 50-341/84-32 This letter responds to the items of noncompliance described in your Inspection Report No. 50-341/84-32.
This inspection of activities regarding the Operational Quality Assurance Program was performed by Messrs.
W. Kropp and M. Moser on August 1-3, and 6-10, 1984.
The items of noncompliance are discussed in this reply as required by Section 2.201 of the NRC's " Rules of Practice",
Part. 2, Title 10, Code of Federal Regulations.
The enclosed response is arranged to correspond to the sequence of items cited in the body of your report.
The number for the items of noncompliance and the applicable-criterion are referenced.
We trust this letter will satisfactorily respond to the noncompliances cited in your report.
If you have questions regarding this matter, please contact Mr. Lewis P. Bregni, (313) 586-5083.
Sincerely,
((kg cc:
Mr. P. M. Byron Mr. R. C. Knop
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Mr. W. Kropp V
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THE DETROIT EDISON' COMPANY
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y FERMI 2 NUCLEAR OPERATIONS ORGANIZATION R'ESPONSE TO'NRC. REPORT NO. 50-341/S4-32
- DOCKET NO. 50-341 LICENSE NO. CPPR -
INSPECTION AT:. FERMI 2, NEWPORT, MICHIGAN INSPECTION' CONDUCTED:
AUGUST l-3 AND 6-10, 1984 O
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v RESPONSE:TO NRC INSPECTION REPORT NO.. 50-341/84-32 l Statementof Noncompliance, 84-32-04, Criterion XVI 1
10'CFRt50,-Appendix B, Criterion XVI, as implemented"by Detroit. Edison: Company's-Qualit'y Assurance Program Require-mentp16;' requires 1that conditions adverse-to quality.be promptly; corrected.
- Contrary;to'theLabove, the licensee' failed to provide prompt Ecorrectiveiaction on an(NRC-finding issued in September, 19831(Inspection LReport 8 3-20).
Specifically, the finding dealt with'the? licensee's failure to implement a shelf life
' program..,At the time of.this inspection, the licensee was continuing tolissue material without determining if the
-shelf life-had expired.
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. Corrective' Action Taken~and Results Achieved In December of.1983, Detroit Edison respo'nded to NRC con-g
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cerns regarding shelf life cited in Inspection Report 83-20.
Thea esponseJdescribed a computerized. program under develop-r
-ment atlthat~ time... Information gathering and any.necessary changes to implementing' procedures were expected to be com-c pleted iniJunel-of 1984.
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, _ 1984, approximately 8000 of the 14000 items By. June 30~
' stocked had be~en researched to identify items with a limited shelf 111fe and-establish shelf' life expiration dates.
On August 19,01984, immediate corrective action was taken by
' requiring that the General l Supervisor-Nuclear Materials stop l
, ' Lissuing: safety related: material with. shelf life: expiration Jdates unknown or expire'd' unless Technical Review approval was obtained.
Temporary revisions to Maintenance and
- Warehouse procedures were.made.attthat time.
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temporary revisions required warehouse personnel to retag items on the shelf.with;"Do Not-Issue" tags where shel.f life
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f expiration-dates were in' question or unidentified.
-Maintenances. Instruction MI-M329, " Identification and (Implementation of Shelf. Life Requirements" has been issued.
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(This; instruction addresses material-already in stock, new
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stockfitems:and material ordered'for immediate repair activ-
'ities. iMaintenance' Instruction MI-M245, " Criteria for 6-_
' Technical Review",..Rev' 2, has. incorporated the standards s:
for technica11 establishment of shelf life when vendor
- information has not been provided.
Warehouse procedure
_revisionsfreflecting.MI-M329 and MI-M245 have been-issued.
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a RESPONSE TO NRC. INSPECTION REPORT NO. 50-341/84-32 I
Corrective' Action and Results Achieved (Cont'd)
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- A' detailed Technical Review of-all safety related items in stock;has been performed.: :Those-items with limited shelf
-life'have been'~ identified, and data entry and verification
_in the. IMPACT SHELFLIFE computer. program is complete.
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retaggingfof.this. material by. warehouse, personnel has been
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icompleted.: The Technical Review Group is' reviewing-1 7
consumable / controlled materials for. shelf-life requirements.
' ' Anylof1these. items-with ' shelf life req _arements will be listed as, stock items and controlled through the Shelf ' Life
- Program.as identified in MI-M329.
Th.s review will be
' complete by September. 22, 1984.
In addition, material issuances over the past year are being reviewed to_ ensure that-no safety related material with a questionable shelf
--life was issued.
Corrective Action Taken to Avoid Further-Noncompliance Affected maintenance-personnel have been trained in the use and application of MI-M245 and MI-M324, as required by Maintenance Procedure 31.000.07.
Warehouse personnel associated with shelf life material have been trained on-the requirements of MI-M329 and MI-M245.
The. warehouse personnel have also been trained on the pro-cedure to 12.000.28 and1the revisions to procedure 12.000.29.
Date When Full Compliance Will be Achieved The'necessary procedure revisions will be completed by September. 2 2,'- 1 9 8 4.
The Shelf Life Program will be fully
.i implemented,-and the review for material potentially beyond-i its shelf life will be complete by September 28,.1984.
' Evaluation of expired material that had been issued, as L
discussed above, and any. corrective action necessary will be complete before initial criticality.
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RESPONSE 1TO NRC; INSPECTION REPORT NO. 50-341/84-32 4
S Statement of Noncompliance,- 84-32-05, Criterion v t
10.CFR 50,-Appendix B,, Criterion,V, as implemented-by.
Detroit-Edison Company!s Quality Assurance-Program Require-Ement 5,-requires activities--affecting quality to be accom-c>.
plished.in accordance with procedures.
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= Contrary;to the-above, the licensee has.not implemented a trending program in accordance with procedure NQA 1602,
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" Trending of Corrective Action."
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Corrective Action Taken'and Results Achieved
.This noncompliance had been1noted and identified as an audit J
Efinding by Nuclear Quality Assurance-(NQA) during audit No.
A-QS-P-84-24, Audit Finding Report (AFR) No. 7.
The proce--
' dure in questio'n,-NQA-1602, had not been implemented due to the need to establish a common coding system for the data Lbase that~the principal NQA sections could utilize.
NQA and its predecessor organization, Project Quality Assurance (PQA), have been performing manual trending activities of
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-various types, and will_ continue to do so until.NQA 1602 is-
. revised,. implemented, and-validated.
Corrective Action Taken to Avoid Further Noncompliance The procedureLwill be revised by September 28, 1984, to include-a common, coding system.
A' specific person has been
' assigned-the responsibility to implement the procedure, n,
including issuance;of periodic reports.
Date When Full Compliance Will-be Achieved vn~
Implementation of'the procedure-will commence October 1, i
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.1984.. The first Monthly Summary Report will be, issued by-i 1
, November 9, 1984,. and'the firat quarterly Trend Analysis
-Report will be issued in January of;1985.
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