ML20148B893

Correction to NOV from Insp on 930916-24 & 1018-1104. Violation Noted:Personnel Signing Off as Lead Test Person for Tests Conducted 1991 on Div 1 & 2 Standby Gas Treatment Filters Were Not Certified to ANSI N45.2.6

ML20148B893
Person / Time
Site:	Fermi
Issue date:	05/07/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20148B885	List: IR 05000341/1993020 ML20148B893
References
50-341-93-20, NUDOCS 9705130402
Download: ML20148B893 (1)

Text

.

NOTICE OF VIOLATION Detroit Edison Company Docket No. 50-341 Fermi 2 Power Plant License No. NPF-43 During an NRC inspection conducted between September 16 through 24, and October 18 through November 4,1993, two violations of NRC requirements were identified. In accordance with the "GeneralStatement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:

A. 10 CFR Part 50, Appendix B, Criterion XVI, states, in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected."

Contrary to the above, as of the inspection conducted September 24,1993, training required by FIP-TQl-16-SO, Revision 2, to certify lead test personnel to 2 ANSI /ASME N510 requirements for HEPA filter testing had not been provided to l three (3) lead test personnel. The failure to provide training constituted a condition adverse to quality identified in 1991 which was not promptly corrected.

This is a Severity Level IV violation. ,

B. 10 CFR Part 50, Appendix B, Criterion V, states,in part, " Activities affecting  ;

quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." >

Contrary to the above, personnel signing off as the lead test person for the tests conducted in 1991 on Division 1 and Division 2 Standby Gas Treatment Filters, and Control Room Emergency Filter were not certified to ANSI N45.2.6 as required by test procedures 43.505.001, 43.404.002, and 43.413.001.

This is a Severity Level IV violation.

The inspection showed that steps had been taken to correct the identified violations and to prevent recurrence. Consequently, no reply to the vio'stions is required and we have no further questions regarding this matter.

1 I

1 l

i i

9705130402 970507 PDR ADOCK 05000341 )

O PDR i

..= - -- - - . - - . - _- - .. - - . -. -- - - -

4 EXECUTIVE

SUMMARY

Enrico Fermi, Unit 2 NRC Inspection Report 50-341/93020 l This inspection included a review of the quality assurance (QA) program, it was an i

announced inspection conducted by a regional reactor inspector.

The objective of this inspection was to examine portions of the licensee's CA program.

l The inspector interviewed staff, reviewed documents and made observations to accomplish this objective. This inspection focused on QA activities performed during 1989 through 1991. Two violations of NRC requirements were identified in this inspection for events that occurred in that period. One violation was for not meeting the procedural requirements and the other was for inadequate corrective actions.

The following changes were made to the report:

The following statements from the original report were determined to be inaccurate and were removed:

In the Notice of Violation, the reference to the Enforcement Policy was corrected.

in (original) Section 3.1 " Evaluation of ANSI /ASME N510 Qualification and Certification for Testing Personnel":

1. The last sentence of the first paragraph reading " Based on observations of documentation, NRC determined that HEPA filter surveillance tests, conducted in conducted in 1989 and 1991, were performed under the supervision of certified inspectors." Further evaluation identified that ~ths 1

@y[y Bgy@j@@R{j@lR$@@JiMfgri@@j while certified  !

inspectors were onsite, and had conducted on-the-job training on filter testing, the surveillance tests were not entirely performed under the j supervision of certified inspectors, j

2. The first sentence in the fourth paragraph reading "The NRC inspector evaluated test documentation and determined that the tests were technically adequate based on the presence of a certified contractor and another corporate office certified inspector" and the third sentence in the same paragraph reading " Quality Assurance management used the security log as evidence that the certified inspectors were present and monitored the three conducted tests." Following identification that the certified individuals were not in the test vicinity throughout the test, the NRC inspectors reevaluated the test results and determined that they were technically adequate based upon comparable results achieved during more recent testing. Review of written statements determined that the Quality Assurance management had not stated that the security logs confirmed certified individuals were present and monitored the tests, but rather stated that certified individuals were onsite throughout the testing period and provided oversight of the tests.

3. The beginning of the sixth sentence in the fourth paragraph reading "The I licensee has implemented training for ANSl/ASME N510" and the third 2

'O f S

~+.-_w *~ ..w- n - 2-w..-~x + . a .- --.u-~ .

Based on these changes, the inspectors concluded that:

4 The corrections being made herein to inspection Report (IR) 93020 did not affect

the previous technical conclusions or any previous decisions regarding equipment operability or adherence to regulatory requirements.

Problems with the DER process continued to occur, following issuance of IR 93020.

i These problems included identification of issues, thoroughness of root cause  !

determinations, and adequacy of corrective actions to prevent recurrence. During i the Systematic Assessment of Licensee Performance (SALP) public meeting in l March 1996, the issue of problem identification and resolution was discussed by both the NRC and the licensee.

1. Maintenance M2 Maintenance Support of Facilities and Equipment

M 2.1 Maintenance and Test Ecuioment (M&TE) Control (Formerly Section 3.6) 4 in M93, the NRC inspector evaluated only the retrieval and storage of M&TE 1

records from the vault. This evaluation also included review of selected records

and interview with responsible individuals. The inspector concluded that there were l no significant concerns or findings in this area and noted the overall control of M&TE records had been previously inspected by the NRC. NRC concerns regarding

retrieval and storage of M&TE records had been addressed by the licensee. In

, 1995, because of continuing concerns with the M&TE program, the NRC performed 4

a more through review of the entire M&TE program, as documented in IR 95008.

Retrieval and storage of M&TE records were verified as part of this wider inspection and no problems were found during that portion of the inspection. The 1995 inspection identified several problems with the M&TE program, as well as a violation associated with a Quality Assurance (QA) audit of the program in 1993. 1

,i The inspection report also noted that some problems identified by QA in 1991 had I been corrected, such as control of leak rate test and motor-operated valve testing equipment.

]

M4 Maintenance Staff Knowledge and Performance M4.1 Certification and Qualification of QA Insoectors and Auditors (Formerly part of l Section 3.1) l

{ a. Scope j The NRC inspector examined the certification and qualification requirements /

! records for QA inspectors and auditors. This examination generally covered the i overall certification process.

L

b. _Qbservations and Findinas in 1993, the inspector determined that selective examinations of certification 4

records for inspectors and auditors did not identify regulatory deficiencies. The 4 l 4

l l

l issue of QA ins 9ector certification was again reviewed in IR 95012. As described in that report, aeveral deficiencies with the QA inspector certification process were identified in QA audits in 1989 and 1991. Further review of the audit reports and discussion with audit personnel revealed that minimal corrective actions were taken following the 1989 audit findings. However, when the same problems were discovered during the 1991 audit, the QA auditors correctly escalated the issue and the certification process was corrected, including bringing in an outside consultant  !

to recertify the inspectors in question. The inspectors also identified a concern i with the certification and technical ability of one inspector. This was addressed in IR 96002. The qualifications and training of lead auditors were reviewed by NRC in irs 93002,94015, and 95002. In all cases, the auditors were found to have the appropriate training and background prior to being assigned as lead auditors for the audits reviewed.

c. Conclusions Based upon the inspections listed above, the inspectors concluded that the QA inspectors and auditors were properly trained and certified. While problems with QA inspector certifications existed in 1989 and 1991, the licensee's OA auditors correctly escalated the finding and the licensee took appropriate corrective action solve it.

M4.2 Evaluation of ANSI /ASME N510 Qualification and Certification of Testina Personnel (Formerly Section 3.1)

a. Scooe '

The inspectors rev! awed the qualifications and training on ANSI /ASME N510

" Testing of Nuclear Air-Cleaning Systerns," for personnel testing high energy particulate (HEPA) filters,

b. Observations and Findings Three test procedures, 43.404.001, " Division 1 Standby Gas Treatment Filter Performance Test," 43.404.002, " Division 2 Standby Gas Treatment Filter Test,"

and 43.413.001, " Control Room Emergency Filter Test," required certification to ANSI N45.2.6, " Qualification of Inspection, Examination and Testing Personnel for Nuclear Power Plants," for the lead person conducting the tests. Each test procedure had a signature line for verification that the lead test person was certified to the above standard.

V' hen the three filter tests above were conducted in j 991, the lead test person signature line was signed by two individuals who were not ANSI N45.2.6 certified.

This was identified during a QA Audit, 91-0143. The licensee stated that the tests were performed under the auspices of a certified contractor, as well as a certified inspector from the corporate office. However, the QA audit noted that the signature lines for the above three tests were neither initialed nor signed by either of the certified individuals. Because the test procedures specifically required ANSI N45.2.6 certification and the lead persons were not certified, the licensee's procedural requirements were not met. 10 CFR Part 50, Appendix B, Criterion V 5

" Instructions, Procedures, and Drawings" requires that activities affecting quality be accomplished in accordance with the documented instructions, procedures, or I drawings. Failure to comply with the HEPA filter testing procedural requirements, I ensuring that the lead test person was certified to ANSI N45.2.6, is a violation of  !

Criterion V (50-341/93020-01(DRS)). i Quality Assurance management reviewed the security logs and determined that the certified inspectors were on site, @gG@!dMg'eMij in the test area, during

{K@]l{p{yX@Bj@j when testing was being performed. The licensee also l obtained a letter from the contractor describing the ANSI /ASME N510 on-the-job l training conducted for the individuals. Subsequent HEPA filter [ tests were satisfactorily conducted by the same two individuals, indicating an adequate i knowledq9 level for performing HEPA filter testing. The licensee removed qualification to ANSI N45.2.6 as a requirement for HEPA filter testing, following confirmation from the ASME code committee that qualification to ANSI N45.2.6 was not required. Therefore the corrective action to the violation was considered adequate and no response is required.

Although certification to ANSI N45.2.6 was not required, qualification to ANSI /ASME N510-1980 was necessary. Section 4.3 of ANSI /ASME N510-1980, Page C-4, stated, " Tests shall be made only by persons who have demonstrated their competence to satisfactorily make the specific tests in question, as evidenced by experience and training." The two individuals who signed off as lead test personnel for the 1989 HEPA filter tests had not received training on ANSI /ASME N510. This was also identified by the licensee's QA auditors in audit 91-0143.

DER 91-0589 was generated which identified the lack of training and certification of the lead test personnel.

As part of the corrective action to DER 91-0589, the licensee developed a training course for ANSI /ASME N510. However, the licensee exempted three lead test personnel, including the two who had signed off on the [9M tests, principally because they participated in subsequent HEPA filter testing. The inspectors also noted that, as of December 1996, the licensee had not taught the course.

Furthermore, the waivers made no reference to training conducted for these individuals. According to FermiInterfacing Procedure FIP-TOI-16-SO Revision 2, requests for waivers "shall be supported by certified or authenticated documents such as official transcripts, verifiable certificates of completion, etc." No such documentation was identified to justify waiving the training requirement.10 CFR Part 50 Appendix B, Criterion XVI " Corrective Action" requires that significant conditions adverse to quality are promptly and adequately corrected. Therefore, waiving the training requirement in response to the DER appeared to constitute an inadequate corrective action. This is considered a violation (50-341/93020-02(DRS)).

The licensee presented the inspectors with plant records, including a statement from the certified contractor indicating the on-the-job training performed prior to and during the {99{ testing. Based on these records, the inspectors determined that, although the three lead test personnel did not receive formal training on ANSI /ASME N510, the on-the-job training appeared to be adequate. T he licen.see reviewed the procedure addressing waivers and determined it to be adequate co 6

- - . . - - - - ~ ~ - - - - - . - - - . . . - - . . - - - - - . -

i. *

preclude future waivers without sufficient basis. E

ecause the subsequent actions

appeared adequate, no response to the violation was required. Subsequently, it j was brought to the licensee's attention that no training was ever performed on ANSI /ASME N510, and that, despite the review and approval by the lead QA

} auditor, the closure package for 91-0589 was inadequate. A new DER, 94-0281, j was opened to correct the deficiencies of the original packags.

i ' The NRC inspectors reviewed the issue of the test signatures to determine if there l was any intent to falsify the records. To this end, the inspectors interviewed the  ;

i personnel involved & the responsible QA auditors, reviewed the security logs, and

evaluated the test documentation, including HEPA filter test results from ,

i subsequent years. Based on this review, the inspectors determined that the l l individuals and their management were aware that the individuals did not have l 4 ANSI N45.2.6 certification at the time they signed the HEPA filter test documents. l l However, to the best of the inspector's ability to determine, there was no intent to l

{- deceive anyone regarding performance of the test. The individuals' readily i j acknowledged they were not certified, the licensee's OA organization identified the )

discrepancy; and the line management reviewed the issue and took actions to i prevent it from recurring. Therefore, the inspectors determined that the issue j centered upon the licensee not reviewing the appropriate procedures prior to use to

ensure that all requirements were adequately met.  ;

4

c. Conclusions i NRC determined that the HEPA filter surveillance tests, conducted in]1991, were <

performed adequately, ethough the licensee's proceduraliequirements were not i j followed. The violations issued in 1993 appropriately characterized the issues and J j no further corrective actions are necessary on the licensee's part.

l M4.3 Adeausev of Insoectors Knowledae Concernina Selection Criteria About Installation l of Snubbers (Formerly Section 3.4)

! During the inspection and after review of documentation and interviews with plant l j personnel, the NRC inspector investigated the role of the QA inspectors in the j removal of snubbers and installation of struts. The QA inspectors were tasked with

verifying the proper snubbers were removed and that struts were correctly installed.

l During QA surveillance 92-0149, an auditor observed that the QA inspectors did

not appear to understand all the acceptance criteria and yellow line requirements.

The auditor requested that the engineering department provide written clarification l

3 of the yellow line requirements to ensure an adequate QA verification of the l modification was performed. This clarification was provided by memo dated March 16,1993. The inspectors verified that QA had no further problems with this i modification.

l l

i t

i 7 L

i

__ ._. _ _. , . - - ._. - - . _ _ i