IR 05000341/1985026

Insp Rept 50-341/85-26 on 850513-22.No Violation or Deviation Noted.Major Areas Inspected:Maint,Design Change, Surveillance,Tests & Experiments & QA Program for Startup Activities

ML20128Q484
Person / Time
Site:	Fermi
Issue date:	05/29/1985
From:	Hasse R, Hawkins F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20128Q446	List: IR 05000341/1985026 ML20128Q442
References
50-341-85-26, NUDOCS 8506040211
Download: ML20128Q484 (5)

Text

'

y U.S. NUCLEAR REGULATORY COMMISSION

.

- REGION III _

ReportNo..-50-341/85026(DRS)

'

Docket No. 50-341 . License No. NPF-33 Licensee:. Detroit Edison Compan Second Avenue

' Detroit, MI 4822 Facility 1Name: Fermi Nuclear Power Plant, Unit 2 Inspection At: Fermi 2 Site, Monroe, Michigan Inspection Conducted: May 13-22, 1985 Inspector: -

E '2_T W Date Accompanying Personnel: D. Jones

' Approved By: F.'Hawkins, Chief .

5/Z 9 /M~

Quality Assurance Programs Section

'

Da te --

Inspection Summary

'

Inspection on May 13-22, 1985 (Report No. 50-341/85026(DRS)) .

Areas Inspected: Routine, unannounced inspection by a Region III based

' inspector of maintenance, design change, surveillance, and tests and experi-

.ments programs and the quality assurance program for startup activities. The inspection involved a total of 60 onsite inspector-hours by one NRC. inspecto .Results: .No violations or deviations were identified in the'five areas inspecte '

8506040211 850529 PDR ADOCK 05000341 t

a PDR ,

.

. : ...

,

DETAILS ~ Persons Contacted

.

Detroit Edison Company

. *E. Griffing, Assistant Manager, Nuclear Operations

"

_* G. Trahey,-Director, Nuclear QA

.*J. Conen, Licensing Engineer

• B. Wickman, Supervisor, Maintenance and Modifications QA

• J. Nyquist,' Assistant to Superintendent, Nuclear Production

~ W. Miller, Supervisor, Operational Assurance R. Szkotnicki, Supervisor,-Technical Staff F. Schwartz, Supervisor, QA Staff E. Preston, Operations Engineer

.T. Byrd,' Supervisor, Procurement QA

'USNRC P. Byron, Senior Resident Inspector

• D. Jones, Resident. Inspection Staff-

0ther personnel were contacted as a matter of routine during the inspectio * Denotes those attending the exit interview on May 22, 198 . Action on Previous Inspection Findings (Closed) Noncompliance (341/84-48-02): Failure to ensure inspection procedures used by the General Procurement Inspection l Division (GPID)

were reviewed and approved by Nuclear Quality Assurance (NQA). The GPID now performs-its inspections in accordance with procedures and plans

-

~ approved by:NQA. Inspection Reports are also approved by NQA. In addition, GPID inspectors have been certified as Level II inspectors in accordance with ANSI N45.2.6-197 '3- ~ Program Areas Inspected

.

During this inspection, the adequacy o.f implementation of the licensee's maintenance, modifications, surveillance, and test.and experiments

~

. programs was ~ reviewed. -This was a followup to the program reviews of these areas documented in Inspection Report 50-341/84-25(DRS). In addition, the licensee's program for QA coverage of'startup activities and its implementation were reviewed for adequac Quality Assurance for Startup Activities The startup QA program consists of three elements: (1)100%

surveillance of startup testing for procedure compliance by Operational Assurance;-(2) periodic audits by the Nuclear Quality Assurance' audit function and; (3) inspections performed by the quality ' control function for specific test step L

V-w .

(1) Startup testing surveillance is accomplished using a standardized checklist contained in " Procedure Compliance Module for Startup/ Demonstration Testing", Revision 1. The surveillance covers the initial test review against the Technical Specification through test completion and review and approval of results. A review of the module and all completed surveillances to date indicated that the program was adequate and properly implemente (2) The inspector reviewed the audit schedule for startup activities and several recently completed audits of this are The audit schedule was adequate and the completed audits were properly conducted. Responses to audit findings were also adequate. However, the inspector noted during this review that many actions related to audit findings, not restricted to startup activities, were overdue (23 of 85 actions). The overdue actions were initial responses by the audited organization, responses to inadequacies in the initial response, and completion of corrective action Licensee personnel stated that they were aware of this timeliness problem and had taken action to correct it. A Nuclet r Operations Directive (N00) had recently been issued addressing this issu Also, a letter had recently been issued by the Vice Pn.sident, Nuclear Operations indicating that timeliness in respons$ to such issues was to be part of an employee's performance appraisa T11s is considered an unresolved item pending NRC review of the e,fectiveness of the licensee's corrective action (341/85026-01).

No violations or deviations were identifie Maintenance Program Implementation The administrative controls-for the maintenance program were described in Administrative Procedure-(AD) 12.000.15,"PN-21(Work Order) Processing." Implementation detail was contained in various maintenance instructions. The preventive maintenance (PM) program was described in AD 12.000.17, "PM Program." The PM program also includes instrument calibrations not specified in the Technical Specification (1) 'A review of selected completed work packages indicated that

completed maintenance activities were conducted in accordance with the progra (2) A review of the implementation of the PM program resulted in the following concerns:

(a) During 1984, 57% cf the priority 1 and 2 PM tasks and 52%

of the priority 3, 4, cnd 5 tasks were completed. Through April, the completion rate for 1985 was 61% and 44%,

respectively. The licensee has conducted no objective

,

,

evaluation of the impact of these low completion rate !

!

. i

"

T[.

,

^

~

This is considered an unresolved item pending NRC review of the licensee's evaluation of-the PM program completion rate'(341/85026-02).

(b) The PM program as described in AD 12.000.17, requires that-all PM tasks not completed during the month in which they are issued are cancelled and returned to the PM coordinator (PMC).- The PMC then decides whether to reissue the task

<

the following month or wait for the next due date (unless

'the responsible Section Head requests a reschedule). This system permits-lower priority' tasks to be completed with resources that could be applied to either overdue, higher priority tasks or overdue. tasks'of the same priority. This is considered an unresolved item pending: licensee revision of the.PM program to ensure resources are applied to the highest priority tasks (341/85026-03).

(c) The licensee has established an 18 month frequency fo instrument calibrations which are not specified by the Technical Specifications. Based on a cursory review, the inspector is concerned that-the specifi.ed frequency is not

. sufficiently conservative. The adequacy of the 18 month calibration period for non-Technical Specification cali--

brations is considered an open item.pending further NRC review'(341/85026-04).

No violations- or deviations were identifie Surveillance Program Implementation

>

The surveillance-program is controlled by Procedure AD 12.000.18,

" Surveillance Program." A master list is maintained which cross

-

references the specific Technical Specification requirement, the-implementing procedure, and the surveillance frequency. The inspector compared a sample of Technical Specification surveillance requirements to'the master surveillance list. With one exception, implementing procedures had been prepared and the specified frequencies were. consistent. Specifically, Technical Specificatio .8.4.a. requires that a program be established to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or: accident to as low as practical levels. Specification 6.8.4.a.1 specifies ~that as part of this program, preventive maintenance and periodic inspection requirements be' established. The implementing procedures for Specification 6.8.4.a.1 have not been prepared. This is considered an'open item to.be completed by the licensee and reviewed by the NRC 1 prior to comercial operation (341/85026-05).

No violations or deviations were identifie d. -Tests and Experiments Tests and experiments not described in the FSAR are controlled in the same manner as a modification. To date, no such tests or

.

.

'

3..q s

experiments have been performed by the licensee under the operations program. . Implementation of this program will' be assessed during the

= routine inspection program, Design Changes'and Modifications The design ch nge program is controlled by Procedure;AD 12.000.64,.

"EDP Implementation Procedure", and a series of Nuclear Engineering (NE) procedures.. Nuclear Engineering is responsible for preparing the design package and the operating-organization is responsible for implementation.' Nuclear Engineering conducts:a final. review after -

implementatien. The inspector reviewed a sample of completed Engineering Design Packages (EDPs). The packages had been' properly prepared'and implemente !The inspector did note that some safety evaluations tended to be-

-weak. Criteria used for the evaluation were design intent and they-excluded consideration of design details, such as system interface The design changes available for review were not sufficiently complex to make a good' assessment of this issue. The inspector discussed this

-

matter _ with the licensee and noted that updateng safety evaluations as the designs are detail _ed represents good practice. The inspector had no-further questions in this are No violations or deviations were identifie . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or-deviations.. Three unresolved items disclosed during this inspection are

-_ discussed in Paragraphs 3.a and . -Open Items-

Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector .and which involve some action on the part of the NRC 'or licensee or both. Two open items disclosed during this' inspection are discussed in Paragraphs 3.b. and . Exit Interview Theinspectormetwithlicenseerepresentatives(denotedinParagraph1)

at the conclusion of.the inspection on May 22, 1985, and summarized the purpose, scope, and findings of the inspection. Discussions with licensee personnel. indicated-that the inspector had-no access to proprietary information during the inspection.

,

5