ML20126B247
| ML20126B247 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/05/1985 |
| From: | Jens J DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| EF2-70454, NUDOCS 8506140049 | |
| Download: ML20126B247 (4) | |
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j ayne H. Jen)
Vicy President '
Nuclear Operations -
North Dixie Highway ISOn pia >sesass Newport, wenigan 4stes June 5, 1985 EF2-70454 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 Docket No. 50-341 NRC License No. NPF-33
Subject:
Detroit Edison Response Inspection Report 50-341/85013 This letter responds to the item of noncompliance described in your Inspection Report No. 50-341/85013.
This inspection was conducted by Messrs.
P.
M. Byron, M.
E.
Parker, C. D.
- Anderson, S. G. DuPont, and S. Stasek of NRC Region III from February 17 through April 6, 1985.
The item of noncompliance is 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.
We trust this letter satisfactorily responds to the non-compliance cited in the inspection report.
If you have questions regarding this matter, please contact Mr. Lewis Bregni, (313) 584-5083.
Sincerely,
/
'h
/
cc P.
M. Byron N.
J. Chrissotimos USNRC, Document Control Desk Washington, D.C.
20555 l
8506140049 B50605 JUN 111985 i
PDR ADOCK 05000341 G
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1 THE DETROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATIONS ORGANIZATION RESPONSE TO NRC INSPECTION REPORT NO. 50-341/85013 DOCKET NO. 50-341 LICENSE NO. NPF-33 INSPECTION AT: FERMI 2, NEWPORT, MICHIGAN INSPECTION CONDUCTED:
FEBRUARY 17 THROUGH APRIL 6, 1985 9
RESPONSE TO NRC INSPECTION REPORT NO. 50-341/85013 o
Statement of Noncompliance 85013-03 Technical Specification 6.8.2 requires that the applicable (maintenance) procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be reviewed by the Onsite Review Organization and approved by the Superintendent--Nuclear Production.
Contrary to the above, the licensee's maintenance contractor, Bechtel, performed maintenance activities using Bechtel procedures which were not reviewed by OSRO nor approved by the Superintendent--Nuclear Production.
Corrective Action Taken and Results Achieved Conversion of contractor-unique procedures to Edison
-maintenance procedures has been ongoing since September, 1984.
The transition from PMO (project) procedures to Nuclear Operations procedures has been underway since June, 1984.
However, this conversion task had not been completed as of March 20, 1985, and some procedures which had not been reviewed by OSRO and approved by the Superintendent, Nuclear Production (SNP) were still included in safety-related work packages.
It should be noted, however, that all such procedures had been previously reviewed and approved by Detroit Edison Engineering and Quality Assurance organizations.
This noncompliance could have been prevented if the procedures which had not yet been converted had been deactivated by Nuclear Administration on March 20.
Nuclear Quality Assurance identified this situation on April 2,
1985, and initiated DER NP-85-0144 to address this problem on April 3, 1985.
For safety-related work packages initiated after April 3, Bechtel was directed to include only procedures which had received OSRO review /SNP approval, or procedures which did not require OSRO review /SNP approval.
Bechtel has confirmed that safety-related field work completed after May 10, 1985 has been performed using appropriately reviewed and approved procedures.
All field work completed using Bechtel safety-related work packages between March 20 and May 10, 1985, inclusive will be evaluated to determine the impact of using procedures not reviewed by OSRO or approved by the SNP.
A preliminary evaluation has been completed for work packages closed between March 20 and May 7, 1985, and there have been no impacts. I
-a RESPONSE TO NRC INSPECTION REPORT NO.- 50-341/85013 Corrective Action Taken and Results Achieved (Cont'd)
Other safety-related contractor or PMO procedures identified during the review / evaluation process have been inactivated if OSRO review /SNP approval is required but not yet accomplished, or if the need for OSRO review /SNP approval has'not yet been determined.
An evaluation of the impact of the use of these unapproved procedures since March 20 is also being conducted and will be completed before June 28, 1985.
Corrective Action to be Taken to Avoid Further Noncompliance Nuclear Operations Interfacing Procedure 11.000.131 will be revised to state that Nuclear Administration has the authority to deactivate or recall procedures which have not received OSRO review /SNP approval when such review and approval are required.
Nuclear Operations Interfacing Procedure 11.000.131 will also be revised to more clearly describe the methods used to obtain OSRO review /SNP approval.
The requirements of the new revision will be communicated to Fermi 2 personnel using a Nuclear Operations Notice.
Date When Full Compliance Will be Achieved Contractor and PMO procedures used in safety-related work packages initiated after April 3, 1985, were required to be reviewed by OSRO and approved by the SNP, or are procedures which do not require OSRO review.
Continued compliance is being assured by Nuclear Quality Assurance review of safety-related work packages to preclude the use of unapproved procedures.
The evaluation of the impact of using procedures which did not receive the required OSRO review /SNP approval will be completed by June 28, 1985.
Nuclear Operations Interfacing Procedure 11.000.131 will be revised by June 28, 1985. -