ML20128L748
| ML20128L748 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/19/1985 |
| From: | Jens W DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NE-85-0396, NE-85-396, NUDOCS 8507110450 | |
| Download: ML20128L748 (5) | |
Text
idd r :yn a.a:n3 Vs3 President Nuclear Operatrms l,h FermF2 6400 Nath Dme Hghwav June 19, 1985
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NE-85-0396 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 NRC License No. NPF-33
Subject:
Detroit Edison Response Inspection Report 50-341/85021 This letter responds to the item of noncompliance described in your Inspection Report No. 50-341/85021.
This inspection was conducted by Messrs.
P.
M.
- Byron, M.
E.
Parker, and D. C. Jones of NRC Region III on April 7 through 30, 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) 586-5083.
Sincerely, l
cc:
P.
M.
Byron
'(ikk) p N.
J. Chrissotimos USNRC, Document Control Desk Washington, D.C.
20555 8507110450 850619 DUN 211985 PDR ADOCK 05000341 G
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THE DETROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATIONS ORGANIZATION RESPONSE TO NRC INSPECTION REPORT NO. 50-341/85021 DOCKET NO. 50-341 LICENSE'NO. NPF-33 INSPECTION AT:
FERMI 2, NEWPORT, MICHIGAN
. INSPECTION CONDUCTEDs APRIL 7 THROUGH 30, 1985 s
a..-.
a
RESPONSE TO NRC INSPECTION REPORT 50-341/85021 313tement of Noncompliance 85021-01 10 CFR 50, Appendix B, Criterion V, as implemented by DECO Quality Assurance Manual, Section 9.0.1 requires that activi-ties affecting quality shall be accomplished in accordance with procedures.
Contrary to the above, Engineering Design Package (EDP) 1996 was not implemented in accordance with Plant Operations Manual (POM) Procedure 12.000.64 "EDP Implementation Procedure."
This resulted in the following:
a.
The EDP verification sheet did not adequately reflect the EDP and its accompanying Engineering Change Requests (ECR).
b.
Not all test, vent, and drain (TVD) caps were installed.
c.
POM procedure 47.000.77, " Test, vent, and Drain (TVD) Cap and Plug Verification," omitted a pene-tration (X-220) which consists of eight TVD caps.
Corrective Action Taken and Results Achieved a.
The original work order (PN-21 No. 609080 issued on 1-14-85) required the installation of test, vent, and drain connection caps per the direction of Engineering Design Package (EDP) No. 1996.
To facilitate implemen-tation, a checklist was developed to determine the current field status (i.e which test connections currently had caps and which did not) via a walkdown.
This walkdown was performed January 15 through 18, 1985.
On January 28, 1985, Engineering Change Request (ECR)
No. 1996-2 was issued to both delete the installation of some caps required by EDP-1996 and add tha installa-tion of other-caps not previously identified.
These changes were not subsequently incorporated into the original verification walkdown sheet as required by procedure 12.000.64 "EDP Implementation Procedure".
The responsible person failed to adhere to plant procedures.
The EDP verification walkdown checklist was changed to incorporate all subsequent revisions to EDP-1996 (ECR's 1996-2, 1996-3, 1996-4 & 1996-5) and the walkdown was reperformed on April 24 and 25, 1985.
Also, the EDP 1
x RESPONSE TO NRC INSPECTION REPORT 50-341/85021 Corrective Action Taken and Results Achieved (cont'd)
Implementation Plan was revised as required by Procedure 12.000.64.
In addition, PN-21 No. 992725 was generated on April 15, 1985 to verify installation and add test, vent, and drain caps as required by ECR No. 1996-2.
This PN-21 was signed completed on April 19, 1985.
Completion of PN-21 No. 992725 and the revised verification walkdown checklist of April 25, 1985 fully document that the current field condition is consistent with the design requirements.
b.
A review of the documentation associated with PN-21 No.
609080 indicated that all caps were installed in accor-dance with EDP 1996 and ECR's 1996-1 and 1996-2.
How-ever, at the time the work was completed there were no administrative controls in place to assure the con-tinued integrity of these caps on their associated test, vent, and drain connections.
Since this occur-rence, Surveillance Procedure No. 47.000.77 has been issued to administratively control the subject caps.
In addition after completion of the EDP, all associated plant drawings will be updated in accordance with procedure to reflect those test and vent connections which require caps.
c.
Penetration X-220 was omitted from Surveillance Procedure 47.000.77 when the procedure preparer was compiling penetration data from the four source docu-ments, including EDP-1996.
The preparer overlooked this omission because he used his final product to check against the original source documents instead of using the source documents to reverify the completeness of the final list.
In addition to the above, the technical reviewer of the procedure used the original preparer's source documents to check the information for each penetration identi-fled in the procedure for accuracy but failed to verify that the procedure ccntained all of the required pene-trations.
Immediately after the discrepancy was discovered, the preparer and the technical reviewer reanalyzed all information used to generate the procedure and cor-rected the procedural deficiency.
The revised proce-dure was submitted and approved by OSRO and the plant superintendent on May 20, 1985.
The preparer and 2
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i RESPONSE TO NRC INSPECTION REPORTr50-341/85021 Corrective Action-Taken and.Results Achieved (cont'd) theLtechnical reviewer were then instructed by their
).
immediate. supervisors of the importance of checking and auditing large amounts of technical data systematically and logically to preclude. recurrence of this type of error on any future documents which might be-generated by these individuals.
Corrective Action to Prevent Further Noncompliance Detroit Edison has procedures in place to prepare EDP imple-mentation packages and to prepare and technically review procedures to ensure correct technical and work content.
, These procedures were not adequately implemented.
The individual who incorrectly implemented plant procedure 12.000.64 which resulted in the failure to incorporate ECR 1996-2 into the walkdown checklist was instructed to read the procedure again and fully acquaint himself with all of its requirements.
As discussed in c. above, the personnel
. involved in the preparation and review-of Surveillance E
Procedure 47.000.77 have been apprised of the importance of
. thorough review of their work against the governing documents.
c As stated in b. above, Procedure No. 47.000.77 has been issued to provide administrative controls over the subject capc.
Additional assurance will be provided once the associated plant drawings-have been updated to reflect these i
caps..
This will. provide assurance that the required caps remain in-place.
Date When Full Compliance will be achieved The drawings will be updated to reflect the required caps by November 30, 1985.
At that time, Detroit Edison will be in full compliance.
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