ML20203D181
| ML20203D181 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/03/1986 |
| From: | Agosti F DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| VP-86-0038, VP-86-38, NUDOCS 8604220052 | |
| Download: ML20203D181 (4) | |
Text
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3/>8 ce P s ent Nuclear Operations
.- 1 Detroit
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6400 Nortn Dme H<ghway Nuclear fd9""
Operations
(
)
April 3, 1986 VP-86-0038 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Reference:
(1)
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 (2)
Letter, W.ll. Jens to J.G.
Koppler January 29, 1986, VP-86-0013
Subject:
Detroit Edison Revised Response Inspection Report 50-341/85042 This letter provides a revised response to the notice of violation included with your Inspection Report No.
50-341/85042.
This inspection was conducted by Messrs.
P. M.
Byron and M.
E. Parker of NRC Region III on October 1 through November 30, 1985.
We trust this letter satisfactorily responds to the notice of violation cited in the inspection report.
If you have questions regarding this matter, please contact Mr. Joseph E.
Conen, (313) 586-5083.
Sincerely, 8604220052 860403 A[(
ADOCK05000gi i
PDR G
cc:
Mr. M. D. Lynch Mr. W.
G. Rogers Mr.
G'.
C. Wright USNRC Document Control Desk Washington, D. C. 20555 APR 7 1986 I M o jy;t
4 THE DETROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATIONS ORGANIZATION RESPONSE TO NRC INSPECTION REPORT NO. 50-341/85042 DOCKET NO. 50-341 LICENSE NO. NPF-43 INSPECTION AT:
FERMI 2, NEWPORT, MICHIGAN INSPECTION CONDUCTED:
OCTOBER 1 THROUGH NOVEMBER 30, 1985 1
l
s b.
i RESPONSE TO NRC INSPECTION REPORT NO. 50-341/85042 Statement Of Violation 85042-02 10 CFR 50.73 (a) (1) states in part:
"The holder of an operating license for. nuclear power plant (licensee) shall submit a Licensee Event Report (LER) for any event of the type described in this paragraph within 30 days after discovery of the event."
Contrary to the above, the licensee has failed to submit 16 LERs within 30 days after discovery from March 20 through October 31, 1985.
Corrective Action Taken and Results Achieved An investigation of tha LER process was initiated in September 1985 af ter an excessive number of LERs due in August were submitted late.
This investigation determined that a problem existed with the process of LER preparation and submittal.
The root cause of this violation was determined-to be an inefficient process for generating initial draft LERs and inadequate resources dedicated to the development of LERs in final form for submittal.
The situation was exacerbated by the relatively high number of LERs overall and compounded when clusters of LERs became due in a short time interval.
Most of the late LERs fell due during these cluster periods.
In addition, promptness of LER submittal was occasionally sacrificed in order to submit complete information in each report.
Prior to receiving notification of this violation, the following corrective actions were taken.
o Based on'the identified need for additional resources, the process of acquiring additional dedicated resources was initiated.
o Temporary contract support for the preparation of final LERs was brought in to assist during peak periods.
o The process for initial LER preparation was changed to give the responsibility for preparing initial draft rsoorts to 'the staf f : engineer responsible for the in:tial investigation.
This action helped ensure that all information needed.for the final report would be assembled before preparation of the_ final report began, thereby improving the efficiency of those tasked with preparing the final report.
It is also anticipated that requiring the responsible engineer to prepare the initial draft of the LER will result in more thorough and timely evaluation of these events thereby improving the prescribed corrective actions.
1
RESPONSE TO NRC INSPECTION REPORT NO. 50-341/85042 Corrective Action Taken and Results Achieved (Cont'd) o In order.to eliminate delays in investigating an event, the on-call plant supervisors have been instructed to ensure.that the appropriate group acknowledges their responsibilities for event investigation immediately after event occurrence.
Corrective Action To Avoid Further Violation An additional Detroit Edison engineer has been assigned to the LER preparation function to cope with any future peaks in the production of LERs and to reduce the dependence on contract personnel.
Furthermore, preliminary LERs are now being submitted within the 30 day time period for events which cannot be fully investigated in the alotted time.
This practice had been previously avoided in favor of submitting complete information, even though this resulted in late submittal of several LERs.
Since the initial investigation, Section 5.1 (Timing of LERs) of the LER procedure (12.000.56) has been revised to explicitly provide for preliminary LERs in the event that complete information cannot be collected prior to the LER due date.
This section has also been revised to clearly require LERs to be submitted within 30 days of the discovery of the reportable event consistent with regulatory requirements.
These actions, combined with the anticipated reduction in the nudber of reportable events as operating experience increases, are expected to eliminate late submittal of LERs.
Date When Full Compliance Will be Achieved Full compliance has been achieved.
2