ML20112E341
| ML20112E341 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 02/18/1985 |
| From: | Jens W DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| EF2-70389, NUDOCS 8503260511 | |
| Download: ML20112E341 (7) | |
Text
'
. U syne H. Jens venw nt Nuclear Oper:tes
,f Fermb2 6400 North Dixie Highway Edison =r=-'-'
Fedreerv 18, 1985 EF2-70389 Mr. James G.
Keppler Regional Administrator Region III U.
S.
Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Reference:
(1)
Fermi 2 NRC Docket No. 50-341
Subject:
Detroit Edison Response Inspection Report 50-341/84-40 This letter responds to the items of noncompliances described in your Inspection Report No. 50-341/84-40.
This inspection was conducted by Messrs.
P.
M.
Byron,
M.
E.
- Parker, C.
- Anderson, W.
F.
Christianson, S.
- Stasek, T.
M.
Tongue, and J.
S.
Wiebe of NRC Region III on November 19 through December 31, 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 the inspection report.
The appropriate criterion and the number identi-fying the item are referenced.
We trust this letter satisfactorily responds to the non-compliances cited in the inspection report.
If you have questions regarding this matter, please contact Mr. Lewis Bregni, (313) 586-5083.
l Sincerely,
/ h I
cc:
P.
M.
Byron
/M R.
C.
Knop USNRC, Document Control Desk
, k' d
i Washington, D. C.
20555 g3260511850215 EB25 885,
g ADOCK 05000341 y
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f THE DETROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATIONS ORGANIZATION RESPONSE TO NRC REPORT NO. 50-341/84-40 DOCKET NO. 50-341 LICENSE NO. CPPR-87 INSPECTION AT:
FERMI 2,'-NEWPORT, MICHIGAN INSPECTION CONDUCTED: NOVEMBER 19 THROUGH DECEMBER 31, 1984' e
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IRESPONSE.TO.NRC INSPECTION REPORT NO.
50-341/84-40 Statement of Noncompliance 84-40-01 b
C4 iL10 CFR 50, Appendix-B,-Criterion-V,-'as' implemented by DECO
- Operational.< Quality: Assurance Program Requirement'5, re-
. Lquires that ^ activities affecting quality -shall be prescribed
'by appropriately documented instructions or procedures and
,shall ~ be accomplished ?in accordance' with these documents.
Contrary to-the~above,-the requirements'of Administrative Procedure' 12.000.07 were not ) fully implemented in that a.
Several' procedures sere signed / approved by the Operations ~ Engineer and in one case, a Nuclear Shift' Supervisor, neither of whom are eligible delegates.
b.
On December 19, 1984,.the inspector found in the Control Room,Etwo procedures which were stamped "Information Only" and not '" Controlled" -as required.
~
. Corrective Action -Taken and Results Achieved a.
inue procedures : identified in Section 6.0 of the
'inspectiori report. signed by an. unauthorized cklegate will be' approved by an authorized individual.
In addition, a letter was senti from the Superintendent, Nuclear Production to On - Site Review Organization (OSRO). members and alternates discussing this item of noncompliance with emphasis on proper procedure
. approval.
This letter identifies authorized delegates for the Superintendent.-
Eb.
'As' stated in'the-inspection. report, the "Information only" copies of procedures :-found in the Control Room were promptly removed and replaced with controlled copies.
Corrective Action Taken to Avoid Further Noncompliance a.
The corrective action taken will provide sufficient
-control until the related administrative procedures are revised to ' clarify and resolve' this issue.
An ' audit has been initiated to determine if other
. procedures were approved by. unauthorized delegates.
Corrective action will be taken, if required.
J,
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RESPONSE TO.NRC INSPECTION REPORT NO.
50-341/84-40 J
Corrective Action Taken to Avoid Further Noncompliance
-(Cont ' d) b.
'A review of_ Control Room procedures was conducted between December 21, 1984 and January 11, 1985.
The results ' of this review were.provided to the NRC Resident Inspector on February 7, 1985.
The-errors detected-during this review have been corrected.
' Nuclear Administration will continue to conduct-periodic reviews of the controlled sets of Control Room procedures to ensure accuracy.
In addition, the accuracy of these procedure sets is subject to audit and. surveillance by NOA.
Date When Full Compliance - Will Be Achieved a.
Edison is currently in compliance with regard to who is authorized to approve procedures for the Superintendent, Nuclear Production.
Administrative procedures specifying procedure approval methods will be revised by March 15, 1985.
b.
~ Full compliance has been achieved.
h
- 7. -
~ RESPONSE TO NRC INSPECTION REPORT NO.
50-341/84-40 LStatement of Noncompliance 84-40-02
^
10 CFR 50, Appendix B, Criterion V, as implemented by DECO Operational Quality Assurance Program Requirement 5, re-fquires that:actitivies:affecting quality shall be prescribed
- by_ appropriately. documented instructions or procedures and shall be. complete, current, and contain sufficient quantita-tive andl qualitative acceptance criteria as appropriate to
. verify satisfactory-work performance.
~ Contrary L to the above, numerous procedures were found to be inadequate or incomplete in that:
_e s
a.
Procedures 24.138.06 and 20.000.21 were found with typographicaltmistakes in calculations and/or set-4
' points.
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b.r Primary containment isolation ~ valve G33-F001 was not-
' adequately included in-the surveillance program.
Acceptande criteria in. numerous procedures were not c.
compatible with technical specification requirements.
d.
Surveillance Procedure.24.106.07 referenced an
' attachment 2, but attachment 2 was not included within the -procedure as _ issued.
e.
Administrative Procedure 12.000.04 did not fully implement the applicable technical specification requirement.
Corrective Action Taken 'and Results Achieved a..
The typographical errors in the calculations in procedure 24.138.06, Jet Pump Operability Test, as described in the_ inspection report were corrected in
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Revision 4, dated ^ January 14, 1985.
The setpoint errors in-procedure 20.000.21, Reactor Scram, as
~ described in the inspection report were corrected in Revision 4, dated February 5, 1985.
~b.
Testing of Reactor Water Cleanup System Isolation Valve G33-F001 was incorporated into procedure 24.000.04, Miscellaneous ' Systems Cold Shutdown Valve Operability Test, Revision 0, approved February 1, 1985.
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RESPONSE TO NRC INSPECTION REPORT NO.
50-341/84-40 Corrective Action Taken and Results Achieved (Cont' d) c.
A procedure improvement program has been initiated.
Phase 1 of this program consists of a review of all previously. approved procedures to assure certain problem areas are found and corrected.
A requirement of the Phase 1 program is to assure that procedures are compatible with Technical Specifications.
d.
Procedure 24.106.07, Revision 0, Scram Discharge Volume
' Vent and Drain Valve Monthly Verification, referenced an attachment 2 that was not needed and did not exist.
Reference to the attachment was deleted in Revision 1 which was approved on December 26, 1984.
-e..
Administrative Procedure 12.000.04, On Site Review Organization has been revised to implement technical specification requirement 6. 5.1. 3 that OSRO alternates be appointed in writing by the OSRO chairman.
In addition, a review was made of the method used by OSRO to document compliance with this procedure.
This review revealed that stricter controls, which also provide flexibility, need to be established; therefore, additional changes to Administrative Procedure 12.000.04 are being evaluated.
Corrective Action Taken to - Avoid Further Noncompliances a.
The errors in the calculations in procedure 24.138.06 were caused by inattention to detail while the procedure was being prepared and reviewed.
The errors in the setpoints-in procedure 20.000.21 were caused by a time difference between When the procedure was revised and when the technical specification instrument setpoint was changed.
Both of these error types will
.be corrected by the more thorough and timely procedure review and approval program now being used.
This l
program includes a complete re-review of previously approved Nuclear Production procedures as well as an improved program for recently approved procedures.
Testing of valve G33-F001 was deleted from a surveil-b.
lance procedure with the intent to incorporate this testing into a different procedure.
More effort will be made to assure that procedure changes of this type are processed promptly. b
b.
s
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' RESPONSE TO'NRC INSPECTION REPORT NO.
50-341/84 '
Corrective Action Taken to A' void Further NoncOmpliances (Cont' d) c.-
. Procedure 12.000.07 has been revised to require an.
~ independent technical review using a' check list.
The check list includes a step to assure compatibility with.
Technical Specifications.
Also, when Technical Specifications are1 changed,.a timely review of all-affected procedures will be made and necessary changes made.
ld.
Th'e -independent. technical review as discussed in c.
above will aid in avoiding recurrence of problems of this nature.
e.
Administrative Procedure 12.000.04 is being revised to fully implement the applicable technical' specification requirements.
Date When Full Compliance Will Be Achieved
- 3 a.
_ Edison is in full compliance with regards to procedures s
24.138.06 and 20.000.21.
Phase 1 of the procedure improvement program -is scheduled for completion by March 15,-1985-and Phase 2 is scheduled to be performed during the-18 month procedure review cycle.-
' b". 2 Fullfcompliance has been achieved.
Phase 1 of the procedure ~ im' rovement program for p
c.
procedures required for fuel load will be completed
. prior to fuel load.
Phase 1 of the remaining procedures is. scheduled to be completed by March 15, 1985.
Thus, full compliance will be achieved by March 15, 1985.
.d.
Full compliance has been achieved.
e.
Detroit Edison is in full compliance with regards to meeting technical specification 6. 5.1. 3 requirements.
Administrative ' Procedure 12.000.04 will be revised by March'1, 1985.
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