ML20149K859

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Forwards Insp Rept 50-341/97-03 on 970320-0509 & Notice of Violation
ML20149K859
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 07/01/1997
From: Grant G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Gipson D
DETROIT EDISON CO.
Shared Package
ML20149K861 List:
References
50-341-97-03, 50-341-97-3, EA-97-201, NUDOCS 9707300196
Download: ML20149K859 (7)


See also: IR 05000341/1997003

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Mr. D. R. Gipson

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Senior Vice President

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Newport, MI 48166

SUBJECT:

NRC INSPECTION REPORT 50-341/97003 AND NOTICE OF VIOLATION

Dear Mr. Gipson:

On May 9,1997, the NRC completed an inspection at your Fermi 2 reactor facility. The

enclosed report presents the results of that inspection.

During the 7 week period covered by this inspection period, your staff completed

inspections, modifications and repairs to a significant number of plant components. The

plant was then successfully started up with no significant operator errors or equipment

problems, and with good support from Maintenance, Engineering, and management in

addition, engineering continued to identify and correct deficiencies associated with the

emergency equipment cooling water (EECW) system and Dedicated Shutdown procedures.

However, we were concerned with the number and significance of the deficiencies that

resulted during the performance of maintenance activities. In some instances, these

deficiencies resulted in unnecessary challenges to safety systems and potentially degraded

the reliability of multiple safety and important to safety systems. In addition, NRC

inspectors continued to identify inadequacies in the control of work activities, conduct of

maintenance work activities, foreign material exclusion practices, and the preventive

maintenance program.

Based on the results of this inspection, the NRC has determined that two violations, of NRC

requirements occurred. The violations are cited in the enclosed Notice of Violation f. Notice)

and the circumstances surrounding them are described in detailin the subject inspection

report. The first violation includes three examples of inadequate procedures. The sacond

violation is of concern in that radiological workers failed to follow radiological protection

procedures.

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Several examples of minor radiological procedure adherence prob!sms identified during

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previous inspections and this example indicate that management should address this

concern to prevent a possible decline in performance in this area.

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You are required to respond to this letter and should follow the instructions specified in the

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enclosed Notice when preparing your responsa. The NRC will use your response,in part,

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to determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

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Based on the results of this inspection, the NRC has determined that three apparent

violations were identified and are being considered for escalated enforcement action in

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accordance with the " General Statement of Policy and Procedure for NRC Enforcement

Actions" (Enforcement Policy), NUREG-1600. The two apparent violations are of concern

I

because your staff failed to recognize the substantial impact and safety significance of

problems affecting motor operated valves and motor operated fused disconnect switches

and the need to implement corrective actions in a timely manner. The first apparent

violation pertained to the failure to recognize and implement timely corrective action for a

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known deficiency associated with the potential displacement of motor pinion gears. This

could have resulted in a common mode failure mechanism jeopardizing the operability of

multiple motor operated valves. The second violation pertained to the failure to recognize

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and irnplement timely corrective action to resolve the improper latching of motor operated

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fused disconnect switches. This could have significantly reduced the reliability of multiple

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safety and important to safety systems and could have resulted in a common mode failure

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mechanism.

A predecisional enforcement conference to discuss these apparent violations and those

discussed in inspection Report 50-341/97002 has been scheduled for August 6,1997.

The decision to hold a predecisional enforcement conference does not mean that the NRC

has determined that a violation has occurred or that enforcement action will be taken. The

.

purposes of this conference are to discuss the apparent violations, their causes and safety

significance; to provide you the opportunity to point out any errors in our inspection

reports; and to provide an opportunity for you to present your proposed corrective actions.

In addition, this is an opportunity for you to provide any information concerning your

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perspectives on: 1) the severity of the violation (s), 2) the application of the factors that

the NRC considers when it determines the amount of a civil penalty that may be assessed

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in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other application

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of the Enforcement Policy to this case, including the exercise of discretion in accordance

with Section Vll. You will be advised by separate correspondence of the results of our

deliberations on this matter. No response regarding these apparent violation (s) is required

i

at this time. In addition, please be advised that the number and characterization of

apparent violations described in the enclosed inspection report may change as a result of

further NRC review.

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D. R. Gipson

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter

and its enclosures, and your response will be placed in the NRC Public Document Room.

Sincerely,

Geoffrey Grant, Chief

Division of Reactor Projects

Docket Nos: 50-341

License Nos: NPF-43

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Enclosures:

1. Inspection Report No. 50-341/97003

2. Notice of Violation

cc w/encls:

N. Peterson,

Supervisor of Compliance

P. A. Marquardt, Corporate

Legal Department

James R. Padgett, Michigan Public

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Service Commission

Michigan Department of

Environmental Quality

Monroe County, Emergency

Management Division

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Distribution:

Docket File w/ encl

Project Manager, NRR w/ encl

PUBLIC IE-01 w/ encl

DRP w/ encl

OC/LFDCB w/enci

Rlli PRR w/enct

SRI Fermi w/ encl

A. B. Beach w/ encl

Rlli Enf Coordinator w/ encl

Deputy RA w/ encl

CAA1 w/enci (E-Mail)

TSS w/ encl

DRS w/enct (2)

J. Lieberman, OE w/ encl

J. Goldberg, OGC w/enct

R. Zimmerman, NRR w/ encl

SEE PREVIOUS CONCURRENCES

DOCUMENT NAME: R :\\l n s p r pt s\\ Pow e rs\\Fe rm\\Fe r 97003.d r p

To receive e copy of tNo document, indicate in the box *C" = Copy w6thout attachment / enclosure "E" = Copy with attachment / enclosure

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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter

and its enclosure (s), and your response will be placed in the NRC Public Document Room

(PDR).

Sincerely,

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Geoffrey Grant, Chief

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Division of Reactor Projects

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Docket Nos: 50-341

License Nos: NPF-43

Enclosures:

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1. Inspection Report No. 50 341/97003

2. Notice of Violation

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cc w/ encl:

N. Peterson,

Supervisor of Compliance

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Legal Department

James R. Padgett, Michigan Public

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SRI Fermi w/enct

A. B. Beach w/ encl

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Rlli Enf Coordinator w/enci

Deputy RA w/enci

CAA1 w/enci (E-Mail)

TSS w/ encl

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J. Lieberman, OE w/ encl

J. Goldberg, OGC w/ encl

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DOCUMENT NAME: R:\\insprpts\\ Powers \\Ferm\\Fer97003.drp

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Mr. D. R. Gipson

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Senior Vice President

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The Detroit Edison Company

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6400 North Dixie Highway

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SUBJECT:

NRC INSPECTION REPORT 50-341/97003 AND NOTICE OF VIOLATION

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Dear Mr. Gipson:

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On May 9,1997, the NRC completed an inspection at your Fermi 2 reactor facility. The

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enclosed report presents the results of that inspection.

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During the 7-week period covered by this inspection period, your staff completed

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inspections, modifications and repairs to a significant number of plant components. The

l

plant was then successfully started up with no significant operator errors or equipment

]

problems, and with good support from Maintenance, Engineering, and management. In

i

addition, engineering continued to identify and correct deficiencies associated with the

emergency equipment cooling water (EECW) system and Dedicated Shutdown procedures.

l

However, we were concerned with the number and significance of the deficiencies that

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resulted during the performance of maintenance activities. In some instances, these

deficiencies resulted in unnecessary challenges to safety systems and potentially degraded

i

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the reliability of multiple safety and important to safety systems. In addition, NRC

inspectors continued to identify inadequacies in the control of work activities, conduct of

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maintenance work activities, foreign material exclusion practices, and the preventive

,

j

maintenance program,

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i

Based on the results of this inspection, the NRC has determined that two violations of NRC

requirements occurred. The violations are cited in the enclosed Notice of Violation (Notice)

.

and the circumstances surrounding them are described in detail in the subject inspection

{

report. The first violation includes three examples of inadequate procedures. The second

j

violation is of concern in that radiological workers failed to follow radiological protection

procedures.

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D. R. Gipson

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Several examples of minor radiological procedure adherence problems identified during

previous inspections and this example indicate that management should address this

concern to prevent a possible decline in performance in this area.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part,

to determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

_

Based on the results of this inspection, the NRC has determined that three apparent

violations were identified and are being considered for escalated enforcement action in

accordance with the " General Statement of Policy and Procedure for NRC Enforcement

Actions" (Enforcement Policy), NUREG-1600. The two apparent violations are of concem

because your staff failed to recognize the substantial impact and safety significance of

problems affecting motor operated valves and motor operated fused disconnect switches

and the need to implement corrective actions in a timely manner. The first apparent

violation pertained to the failure to recognize and implernent timely corrective action for a

known deficiency associated with the potential displacement of motor pinion gears. This

j

could have resulted in a common mode failure mechanism jeopardizing the operability of

'

multiple motor operated valves. The second violation pertained to the failure to recognize

and implement timely corrective action to resolve the improper latching of motor operated

fused disconnect switches. This could have significantly reduced the reliability of multiple

safety and important to safety systems and could have resulted in a common mode failure

mechanism.

A predecisional enforcement conference to discuss these apparent violations and those

discussed in Inspection Report 50-341/97002 has been scheduled for August 6,1997.

The decision to hold a predecisional enforcement conference does not mean that the NRC

!

has determined that a violation has occurred or that enforcement action will be taken. The

purposes of this conference are to discuss the apparent violations, their causes and safety

significance; to provide you the opportunity to point out any errors in our inspection

reports; and to provide an opportunity for you to present your proposed corrective actions.

In addition, this is an opportunity for you to provide any information concerning your

perspectives on: 1) the severity of the violation (s), 2) the application of the factors that

the NRC considers when it determines the amount of a civil penalty that may be assessed

in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other application

of the Enforcement Policy to this case, including the exercise of discretion in accordance

with Section Vll. You will be advised by separate correspondence of the results of our

deliberations on this matter. No response regarding these apparent violation (s) is required

at this time. In addition, please be advised that the number and characterization of

apparent violations described in the enclosed inspection report may change as a result of

further NRC review.

._

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_ - - _ . . .

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D. R. Gipson

-3-

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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter

and its enclosures, and your response will be placed in the NRC Public Document Room.

3

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Sincerely,

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Geoffrey Grant, Chief

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Division of Reactor Projects

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Docket Nos: 50-341

License Nos: NPF-43

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Enclosures:

1. Inspection Report No. 50 341/97003

'

2. Notice of Violation

,

cc w/encls:

N. Peterson,

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Supervisor of Compliance

j

P. A. Marquardt, Corporate

Legal Department

,

j

James R. Padgett, Michigan Public

Service Commission

Michigan Department of

,

Environmental Quality

Monroe County, Emergency

Management Division

,

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