ML20206L565
| ML20206L565 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/23/1988 |
| From: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206L553 | List: |
| References | |
| 50-341-88-08, 50-341-88-8, NUDOCS 8811300062 | |
| Download: ML20206L565 (20) | |
See also: IR 05000341/1988008
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-341/88008(DRP)
Docket No. 50-341 License No. NPF-43
Licensee: Detroit Edison Company
2000 Second Avenue
Detroit, HI 48226
Facility Name: Fermi 2
Inspection At: Fermi 2 Site, Newport, Michigan
Inspecti0n Conducted: March 8 through September 20, 1988
Inspector: L. ? Wharton
Reviewed By: F. C. Hawkins, Chief
Quality Operations Section, NRR
khkb
Approved By tL W. Cooper, Otiief / 23/
[
Projects Section 3B aT
Inspection Summary
Inspection from March 8 to September 20, 1988 (Report No. 50-341/88008(ORp)) l
Area Inspected: An inspector of the Nuclear Regulatory Commission's (NRC's)
Office of Nuclear Reactor Regulation (NRR) conducted a special announced
inspection of the circumstances with regard to and licensee actions in r
response to material control allegations that were reported to the NRC
in January and February 1988.
Results: Two violations were identified (See Sections 3.7 and 3.13), and
three open items were identified (See Sections 3.1, 3.3, and 3.7). Open
items are matters that have been discussed with the licensae, will be revined
further by the inspector, and will involve some action on tne part of the NRC,
the licensee, or both. l
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DETAILS
1. Persons Contscted
a. Detroit Edison Company
D. Gipson, Plant Manager
- W. Orser, Vice President, Nuclear Operations
- S. Catola, Vice President, Engineering and Service.:
B. Sylvia, Group Vice President
- L. Goodman, Director, Licensing
- T. Riley, Supervisor, Compliance
- P. Anthony, Licensing, Compliance Engineer
- R. Stafford, Director, Quality Assurance
L. Grant, Senior Engineer, Quality Engineering Section
- W. Ackerman, Senior Engineer, Quality Engineering Section
J. Fischer, Senior Inspector, Plant Safety
L. Bugoci, Associate Engineer, QA Program Assurance
- R. Nuc
May, Director *R.Bryer, Supervisor,learMaterialManafementMaterial Engineer
C. Emanuelle, Principal Engineer, Material Management Division
Y. Sabir, Senior Engineer, Material Management
H. Valenta, Engineer, Materials Management
D. Prakash, Engineer, Plant Engineering Section
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B. Stone, Miintenance Support Engineer, Maintenance Department
J. Bragg, Supervisor, Plant Quality Assurance - Quality Control
B. Hravatic, Principal Buyer, Nuclear Procurement
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5. Kramer, Supervisor, Procurement Section
S. Hassoun, Senior Engineur, Plant Engineering Section
G. Sharma, Principal Engineer, Plant Engineering Section
T. Bird, Senior Quality Specialist, QA Program Assurance
J. Shafer, Supervisor, General Materials
R. Root, Supervisor, Nuclear Tools Section, Maintenance
L. Washington, Assistant Nuclear Materials General Supervisor
S. Vandevelde, Materials Clerk, General Materials
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b. U.S. Nuclear Regulatory Commission
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l *R. Wharton, Quality Operations Engineer, NRR
- W. Rogers, Senior Resident Inspector, Fermi 2
- S. Stasek, Resident Inspectur. Fermi 2
P. Pelke, Project Inspector, Region III
- F. Hawkins, Chief, Quality Operations Section, NRK
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- Denotes those personnel who attended the exit on September 20, 1988.
I The inspector also interviewed others of the licensee's staff during
this inspection.
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2. Background on Material Control Allegations
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In January and February of 1988, a series of allegations was reported
to the NRC Region III Office with regard to material control practices
at Fermi 2. There was a total of 16 allegations, 13 by one alleger and
3 by another. On January 6, 1988, two NRC inspectors conducted a saaple
inspection of the allegations. Upon confirmation of some of the aliNer's
concerns, the allerations were submitted to the Detroit Edison Cottpan',
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(DECO) for invest'gation and disposition. The licensee stablished n
task force to investigate the allagations, evaluate the impact of M..se
allegations on nuclear safety, and determine the appropriate actite for
resolution to any resulting problems. The licensee had an ind m ndent
contractor perform part of the int stigation. The licensee identified
and documented additional problems that surfaced during this effort. ,
The results of the licensee's review are documented in a letter dated ;
April 19, 1988 (attached).
On April 6 and 7,1988, the NRC inspector met with both allegers to ct.tain ,
i as much specific information as possible regarding the al:egations. These ;
i interviews were transcribed. Each allegation consisted nf technical ,
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concerns related to material control practices ano program implementation.
. The intent of this inspection was to review the circumstances surrounding ;
the technical concerns, determine whether or not the allegations were ,
subst&ntiated, and address any resulting technical issues. '
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3. Allegation Review (AN No. RIII-88-A-0001),
3.1 Allegation No. 1 i
Components that were not safety-related and had ;;ot been evaluated by h
the material engineering group (MEG) were installed in the plant in '
safety-related applications.
NRC Inspection Scope and Results ,
Ouring a transcribed interview conducted by the NRC, the alleger expressed
concern that items that were not safety-related had been installed in i
safety-related applications without a technical review by the MEG to
determine their acceptability. The 311eger further stated that these
items had been installed in safety-related applications for up to two
years before they wers discovered end documented un deficiency event
reports (DERs). The alleger was unable to identify additional examples
other than those that had been documented by the licensee on DERs. 1he
following DERs were identified: '
a. DER NP 85-324, "Non-Q Equipment Installed in QA-1 System" ,
b. DER 87-049, "Non-Q Component Used in Q Application" l
c. DER 87-055, "Non-Q Components in Q Application"
d. DER 87-109, "Non-Q Lube Oil Circulation Pump Motor in
Safety-Related Application"
e. DER 87-361, "Non Safety-Related Actuator Diaphragm installed '
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in Safety-Related Apolication"
f. DER 87-381, "Inadequate Review of Parts for Safety-Related
Applications"
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The NRC inspector reviewed these DERs with regard to components that
are not safety-related being installed in safety-related applications
and determined that all the DERs, except DER 87-381, addressed specific
misapplieations of nonsafety-related components. DER 87-381 identified
a programmatic deficiency regarding Procedure 12.000.29, Revision 1),
, Step 6.2.4.2, which allowed parts that are not safety-related to be used
in safety-related applications without an MEG evaluation to determine
the acceptability of the proposed part. The licensee had issued
Procedure 12.000.29, evision 18, on November 10, 1987, to specify
that a technical evc' stion by MEG is required for a part to be used
in a safety-relateo .lication. Additional act. ion taken in response
L DER 87-391 is spr Mcally addressed in Section 3.4 of this report
(Allegation No. 5).
As part of its investigation of the material control allegations reported
to the NRC, the licensee reviewed several requisitions of stores and found
that they were incomplete. The licensee discovered an instance where it
had not complied with procedure 12.000.29, Revision 18, and documented
this in OER 88-0017. DER 88-0017 further related a question as to the
adequacy of the reviews of the issue document (requisition on stores)
portion of the safety-related work packrges performed by the Production
Quality Assurance (PQA) Section. The ' censee determined that the proposed
j action to ensure correct installation of parts, as noted in DER 87-381, also
was appropriate for the proccdural noncompliance portion of DER 88-0017.
Although the licensee determined that PQA personnel had adequately reviewed
the it ue document portion of tne work package to verify use of the correct
matarial, Procedure hQAP 0503, "Review of Work Packages," was revised to
clearly define PQA's review responsibilities and to more closely ensure
that administrative deficiencies were identified.
On the basis of the NRC inspectnr's triview, it appears that the licensee's
actions taken to correct the programmatic deficiencies are adequate, and
- if completely imph.a. anted, these actions will prevent components that are
not safety-related from being misapplied in the future. However, the
inspector is concerned thit part of the licensee'r. proposed resolution
i to OER 87-381 was not sufficient as planned. The technical review of
Requisition of Stores No. N0027143 that resulted from DER 87-381 was
not appropriate remedial corrective action because it only addresses
the identified discrepancy and does not consider any previous similar
occurrences (components previously installed in the plant) and their
potential effect on safety. Additionally, although MEG reviewed 20
l requisitions of stores to determine any generic concern, they reported
I no results of the review but only indicated that the review was complete.
It appears to the inspector as if the MEG relied on the Maintenance
Departn.ent to respond to the OER without performing any independent
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investigation. Thus, the NRC inspector did substantiate this allegation.
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Components that are not safety-related were installed in safety-related
! applications without the MEG performing a technical evaluation. Pending
! the MEG's completion of appropriate corrective action in response to
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DER 87-381, this matter is considered open (0 pen Item 50-341/88-08-01).
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3.2 Allegation No. 2
Components that are identified as nonconforming are always found
acceptable by the MEG during their review.
NRC Inspection Scope and Results
During a transcribed interview conducted by the NRC, the alleger
expressed concern because the MEG reviewI of nonconforming components
always resulted in the component being found acceptable by some method.
The alleger stated that the licensee routinely upgraded components t'st
were not safety-related as a way to disposition nonconforming components.
The alleger provided as an exanple an occurrence that had been previously
identified and documented by the licensee.
DER NP S6-0287 documented where a valve stem that was not aualified by
the American Society of Mechanical Engineers (ASME) was installed in an
ASME Code Class 1 valve. According to the licensee, the stem had been
originally ordered safety-releted (Procurement Code Q), but the purchase
order was erre,neously changed to commercial quality (Procurement Code CQ),
The stem was procur9d CQ, then accepted and stocked incorrectly as not
safety-related (Procurement Code NQ). .
During its review of tne work package (PN 21 No. 985307), the Maintena. ice
Department identified that the valve stem did not meet the ASME Code
requirements for the valve. The manufacturer was contacted and asked to
provide nondestructive examination results and the certified material test
report associated with the subject valve stem. Concurrently, the licensee
had a spare valve stem with the same heat number tested; it failed to meet
, Charpy V Notch test requirements. The Systems Engineering Section perfe med
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a safety evaluation of the specific aDolication of a nonconformina valve
stem. The results of the safety evaluation and the manufactbrer's
concurrence made it possible for the licensee to allow the valve stem
to remain installed temporarily (24 months) because the valve stem was
! installed in a locked open valve that was used only for maintenance
purposes. The licensee replaced the valve stem as part of Terporary
Modification 86-147 auring the spring 1988 outage. This valve stem was
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later reclassified by the manufacturer as nonpressure retaining. The
Authorized Nuclear Insurance Inspector (ANII) concurred with this
modification and signed off on the DER to close o't this deficiency.
The NRC inspector reviewed numerous engineering evaluations used to
disposition nonconforming items and noted none that appeared questionable.
Most items were designated as nonconforming while awaiting either required
documentation or pending results of material verification testing.
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inspector also noted that the MEG had dispositioned nonconforming it ,s
as scrap or salvage (unacceptable) in their e,aluations.
i On the basis of the details provided by the alleger and information
reviewed, the inspector did not substantiate this allegation. Thi-
matter is considered resolved.
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3.3 Allegation No. 3
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4 The MEG revises sheif-life requirements for a specific component,
but the shelf-life requirements for identical components stored in
the warehouse are not similarly revised.
NRC Inspection Scope and Results
During a transcribed interview condacted by the NRC, the alleger expressed
concern that different shelf-life requirements (durations) existed for
identical components. The alleger stated that when the MEG revises
shelf-life requirements, the revision is only applied to that specific
component and to future purchases and that identical items are stocked
in the warehouse with different shelf-life durations. The alleger did !
not provide any specific examples of this concern. ,
The StC inspector reviewed engineering evaluation disposition forms
(EEDFs), the spare parts reference system (SPRS) parts expiration report,
warehouse file stock cards, and material stored in warehouses A and B to
verify that shelf-life requirements were properly established, revised,
and extended. The inspector reviewed DERs, MG shelf-life policy memoranda,
- and QA audits and interviewed the coordinator of shelf-life items, the
General Materials Supervisor, the MEG Supervisor, and other personnel to
verify that shelf-life requirements were understood and reflected
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establisted requirements.
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Before being notified of this allegation, the licensee had documented
this concern as an observation in Audit A-QS-P-87-35, "Quality Assurance
Audit of NE/ Materials Engineering Group." MEG Shelf-Life Policy Memorandum
NE-NS-87-0082 (March 19, 1987) states that the policy regarding shelf-life
- is not to revise a previously establishcd shcif life for material already
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stocked in the warehotse. The audit report stated that this practice
results in different shtlf-life durations for the same types of material.
The licensee proposed no corrective action to this condition because it
j was noted as an audit observation and not an audit finding. In addition,
the conflicting shelf life durations noted in the observation were more
, conservative than the manufacturers recommended shelf life. The audit .
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observation resulted in two recommendations: (1) revise the MEG
documentation file to reflect the MEG Shelf Life Policy Memorandum and
(2) revise NE 6.13, "Shelf Life Control," to incorporate the MEG Shelf
Life Policy Memorandum requirements. At the time of this inspection, the
MEG documentaticn file did not reflect the MEG shelf-life policy and the
revision to NE 6.13 had not been completed. Additionally, the licensee
i reported that when shelf-life requirements are revised, the new requirements
- are not currently being backfitted to stored material.
On the basis of this review, the NRC inspector substantiated this ',
allegation. The inspector is concerned that when the established
shelf lives of items are conservatively revised (shortened) that the
i identical items with less conservative (longer) shelf lives remain in
storage and are available for use until the end of their unrevised shelf
life. If the reasoning useu to shorten the shelf life of an item is i
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technically valid, then that reasoning must hold true for all other
identical items. Prudent engineering practice appears to dictate that
shelf lives for all identical items should be the same. This concern
was discussed with licensee personel who stated that this practice will
be discontinued. Pending NRC verification of the licensee's action, this
matter is considered open (0 pen Item 50-341/88-08-02).
3.4 Allegation No. 5
Requisitions on stores, used to withdraw material from the warehouse,
do not identify how the material is to be used.
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NRC Inspection Scope and Results
During a transcribed interview conducted by the NRC, the alleger expressed
concern that when material is withdrawn from the warehouse for maintenance
activities that are not safety-related, the specific applications are not
identified on the requisitions. The alleger believes the plant
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identification system (PIS) number and work request number, tying
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the material used to a specific activity, should be referenced on
all requisitions. The alleger did not provide any specific examples
of this concern.
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Before being notified of this allegation, the licensee had documented
i problems with regard to the proper preparation of requisitions on stores.
DERs86-009, 87-381, and 88-0017 identified procedural noncompliance,
personnel errors, and lack of attention to detail by material suitability
reviewers as the root causes of problems with preparation of requisitions
on stores. DER 87-381 addressed the programmatic weaknesses that
! contributed to the problem. However, because the licensee has taken a
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comprehensive approach to improve the program this issue is still open.
l The licensee's planned actions include (1) complete revision of
l Procedure P0M 12.000.029, "Haterial Issue and Return," (2) revision to the
! requisition of stores (ROS) form to make it user friendly, (3) one-on-one
- training, for all ROS initiators, material suitability reviewers, and
l authorizers, and (4) periodic review of selected requisitions until the
preparation error rate is acceptable (below 5 percent). The NRC inspector
1 believes that when the proposed actions are completed, they should
i adtquately address the programrnatic weaknesses identified in the DER.
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l The NRC inspector selected approximately 50 recent requisitions of stores
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from the warehouse B file room. The requisitions included items with
procurement code classifications of nonsafety-related (NQ), commercial
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quality (CQ), and safety-related (Q) components. Each R05 referenced a
l PIS number or work request number to provide direct correlation between
{ the material or item and the specific maintenance activity in which it
! was used. The inspector did not identify any material accountability
problems with material withdrawn from t e warehouse.
On the basis of the review the inspector did not substantiate the
l allegation. This matter is considered resolved.
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3.5 Allegation No. 6
Approximately 50 percent of the information in the spare parts reference
system (SPRS) is inaccurate.
NRC Inspection Scope and Results
During a transcribed interview conducted by the NRC, the alleger expressed
- oncern that information listed in the SPRS was not accurate and, as a
result, unacceptable parts were requisitioned from the warehouse and
installed in the plant. The alleger gave several examples where
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incorrect parts had been requisitioned and later installed; these
examples were all previously documented on DERs by the licensee.
The SPRS is a computerized list of cross-referenced information regarding
stock items (spare and replacement parts) that are available from the
warehouse for installation in the plant. The list includes data, such {
ds part descriptions, procurement Codes, part numbers, appenved
applications, and other user information. The purpose of the SPRS is to
assist material users in identifying the proper item to be requisitioned
from the warehouse for any specific use.
Before being notified of this allegation, the licensee had documented
numerous instances where the SPRS data base was inaccurate. In these
instances, most of the inaccuracies were identified as data entry errors
and were not believed at the time to have resulted in the requisition of
any incorrect stock items. Later, during the resolution of DER 88-0015,
the licensee noted that there was no mechanism for routinely incorporating
the resulting part changes into the SPRS data base when engineering design
packages and as-built notices (both types of design changes) were
implemented. This weakness, in c.Thination ;ith the d:t: b::e entry
inaccuracies discussed earlier, contributed to the issuance of
unacceptable parts from the warehouse for installation in the plant.
The licensee's immediate corrective actior, to resolve this weakness in
the SPRS was to discontinue the use of the SPRS as an independent reference
or source of information for determining the acceptability of a part for a
proposed application. Licensee personnel stated that the restricted use of
SPAS would continue until the accuracy of the SPRS is validated. As an
interim measure, quality control group must review all work packages that
require safety related or commercial quality parts to verify that use and
application of the part is consistent with the plant's design-basis
requirements. Additionally, the licensee established a task force
consisting of quality engineering, maintenance, and materials engineering
personnel. The task force was assigned to address the SPRS programmatic
deficienc;es and develop a plan to update and verify the SPRS data base
(SPRS validation plans .
The licensee performed Surveillance 88-0026 "Spare Parts Reference
System," to determine the accuracy of the SPRS. A random sample of
100 quality assurance level 1 stock components was selected and reviewed
to verify that the HEG had approved the applications of these components
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and to verify the accuracy of SPRS data. The errors that were found with
the MEG files and SPRS data were subsequently addressed b DER 88-0511,
"No Documented Approval of Component Application in SPRS.y' The DER is
still open.
The NRC inspector reviewed the SPRS data base to verify the accuracy of
selected data field entries. The inspector also reviewed the task force's
efforts, related surveillances, DERs relating to SPRS inaccuracies, and the
proposed validation plan developed to resolve DER 88-0015. The validation
plan addressed the major goal of the SPRS, which is to ensure that spare
i and replacement parts are properly designated so they can be accurately
, requisitioned and installed. The inspector reviewed the detailed
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instruction to the plan and found it technically adequate to accomplish
the objective of verifying the applicable SPRS data field. However, the
instruction needs to be formally approved and properly implemented.
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On the basis of the review, the inspector substantiated this allegation.
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SPRS information was inaccurate and was used to requisition parts for
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installation in the plant. The licensee's proposed SPRS validation plan,
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if properly implemented, should address the issue. The licensee had
! committed to completing the SPRS validation in response to a previous
l NRC violation (Violation No. 50-341/88-06-03). This violation involved
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the installation of incorrect parts in that a diesel fire pump alternator
i was replaced with an alternator of different make and number without
! being evaluated for suitability. NRC review of the licensee's corrective
actions is currently ongoing.
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3.6 Allegation No. 7
! When nonconforming components are identified, identical components
j stored in the warehouse are not segregated.
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j NRC Inspection Scope and Results
j During a transcribed interview conducted by the NRC, the alleger provided
two exar>ples that supported his concern about identical components to those
j identified as nonconforming not being segregated in the warehouse. Both
- had been previously documented by the licensee in DERs NP-86-287 and
87-109. The alleger stated that the licensee often separately stocks
identical items and assigns them different procurement code classifications,
such as not safety-related and safety-related.
- The NRC inspector reviewed the referenced DERs. DER NP-66-287 identified
1 an instance where a valve stem that did not meet ASME Code requirements
was incorrectly installed in a ASHE Code Class 1 valve application. The
j DER was later dispositioned use-as-is based on safety review and vendor
concurrence with the application. For more specific information regarding
, this DER, see Section 3.2 of this report (Allegation No. 2).
l Similarly, DER 87-109 identified an instance where a motor that was not
l safety-related was used in a safety-related application. The 1\ horsepower
- lube oil circulating pump motor was classified on the Q-list as
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safety-related because it is electrically fed frcm a QA Level 1 power
supply. Although the motor was stocked as though it was not safety-related,
the original technical and quality requirements had been imposed by the
supplier, Colt Industries. An engineering evaluation to determine if the
motor could be used in the safety-related application was performed by the
Maintenance Department. Maintenance personnel compared the installed motor
with the original motor and found that both motors were identical except
for the code letters and bearing type designation. The differences between
the two motors were determined to be inconsequential, and the motor was
dispositioned use-a:-is based on the engineering analysis and vendor
information.
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The NRC inspector could not make a connection between the allegation and
the examples that were provided. In both cases, the installed items
were nonconforming because they failed to meet the requirements of a
specific incorrect application, not because the items were inherently
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deficient. There was no need or requirement to segregate the identical
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items (stems and motors) stored in the warehouse because they were not
intended for the same applications as the items provided in the examples.
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On the basis of the review, the inspector determined that the practice
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of stocking identical items with different procurement codes is allowable
as long as proper controls exist to ensure that items are properly
l requisitioned and installed. However, the inspector notes that a
- violation for failure to identify and segregate nonconforming items
1 in the warehouse is identified in Section 3.13. This matter is
considered resolved.
- 3.7 Allegation No. 8
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l MEG supervision occasionally disregarded procuremant program
requirements.
i NRC Inspection Scope and Results
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During a transcribed interview conducted by the NRC, the alleger gave two
l examples of verbal directives purportedly given him by MEG supervisors to
. bypass the required procurement review. The alleger also provided MEG
l policy memoranda to support his concerns,
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The MEG is responsible for reviewing procurement actions to ensure that
l technical and quality requirements are appropriately addrewed for items
j ar.d services that are both safety-related and not safety telated. In both
- examples given, the alleger stated that the required act.ivities were
accomplished, contrary to the verbal directives. The alleger did not
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provide enough specific information about the two instances to permit
' the NRC inspector to independently verify that the work had been properly
accomplished.
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In an attempt to identify other instances where directives were given
j to bypass required activities, the inspector interviewed selected MEG
i personnel. They stated that they were not aware of any verbal directives
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given by NFG supervision to bypass required MEG procurement activities.
Thus, no additional similar instances were identi.'ied.
During its investigation of this allegation, the licensee conducted
a surveillance of MEG activities. As a result, the licensee issued
DER 88-0087, "HEG Procedures Do Not Require Retention of Technical Review
Documents," and DER 88-0088, "Failure to Comply With FMD PRI, Revision 0,
Procedure, Manuals and Orders." DER 88-0087 referred to instances where
MEG file information and checklists related to engineering evaluations had
not b.en treated as quality assurance (QA) records. The proposed corrective
action to resolve the Leficiencies identified on DER 88-0087 (still open)
required escalation to licensee management for HEG to agree with the action
recommended by the Plant Safety section. These actions include (1) revising
Procedures NE 6.11. "Technical Review of Procurement Documents," NE 6.12
"Engineering Evaluation of Onsite Material," and NE 6.14 "Spare Parts
Reference System," and (2) submitting the existing backlog of MEG documents
to the Information Systems group as QA records by April 1, 1989. It
appears to the NRC inspector that the action proposed for the resolution
, to DER 88-0087 will be sufficient if properly implemented.
DER 88-0088 referred to instances where the MEG had issued policy memoranda
that conflicted with approved rocurement procedures. One example, MEG
Policy Memorandum NE-88-0002, p' Shelf-Life Policy," specified a shelf-life
start date that conflicted with that specified in Procedure NE 6.13,
Revision 0, "Shelf-Life Control." The immediate action was to revise the
HEG policy memorandum to ensure its consistency with the approved procedure.
However, the licensee stated in the DER that the underlying cause of the
! problem was that policy memoranda had been used by MEG in lieu of controlled
procedures. To correct the problem of DER 88-0088 (still open), the
licensee proposed to incorporate the appropriate MEG policy memoranda
into procedures by September 30, 1988. This proposed action also required
i management attention before the HEG and the Plant Safety section came to
l agreement. The NRC inspector believes that the action proposed to resolve
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DER 88-0088 will be satisfactory if properly implemented.
The NRC inspector reviewed DERs and MEG policy memoranda to evaluate the
MEG's interface with the procurement process. The inspector interviewed
MEG personnel regarding MEG file information and reviewed engineering
evaluation disposition forms (EEDFs) and checklists to verify that technical
and quality requirements were properly established for safety-related items
and services. The inspector found that EEDFs used to upgrade
commercial quality (CQ) material did not establish specific engineering
criteria and verification requirements with regard to the performance
characteristics of the items. The EEDFs rationalized that verification
of the part number would ensure that the item was capable of performing
its intended safety-related function. The following are typical examples
of CQ material that was upgraded on the sole oasis of part number
verification:
a. EEDF 4986, limitorque worm gear
b. EEDF 4988, limitorque worm shaft gear
c. EEDF 4978, thyrector diode
d. EEDF 5063, cage valve
11
_ _ _ _ _ _ _ _ _ - _ _ _ _
.
C
.
These failures to establish that materials, parts, and equipment that
are essential to safety-related functions are reviewed for suitability
of application and that appropriate quaiity standards are specified is
considered to be in violation of 10 CFR 50 Appendix B, Criterion III
(Violation 50-341/88-08-03).
On the basis of the review, the inspector determined that the MEG did
not comply with the administrative controls established for the procurement
program and that these deficiencies were properly documented by the
licensee on DERs. Thus, that part of the allegation was substantiated;
although, no instances were identified where MEG supervision instructed
personnel to circumvent the procurement system in such a way as to affect
installed equipment or components. Pending review of the specific actions
implemented by DERs 88-0087 and 88-0088, this matter is considered open
(0 pen Item 50-341/88-08-04).
3.8 Allegation No. 9
When the MEG reviews requisitions of stores to verify that commercial
quality (CQ) electrical switches and relays are being properly applied,
it does not consider the seismic properties of the parts.
NRC Inspection Scone _and Results
During the transcribed interview conducted by the NRC, the alleger
expressed concern that the MEG's review of requisitions of stores for
CQ switches and relays did not include a seismic evaluation. The alleger
stated that the licensee dedicated CQ components for safety-related use
without considering whether the intended application of the item required
seismic properties. The alleger did not provide any specific examples cf
this concern.
The NRC inspecto reviewed engineering evaluation checklists (EECs) to
determine whether the licensee considered seismic requirements in its
evaluations. ECCs are used for dedicating components for safety-related
use. The inspector verified that seismic requirements were considered on
each of the EECs that were reviewed. The inspector also reviewed DERs to
determine if the licensee had documented any deviations related to seismic
applicability or seismic qualifications of CQ components. No DERs related
to seismic issues were identified.
On the basis of the review, the inspector did not substantiate this
allegation. The MEG does consider seismic requirements in its reviews.
This matter is considered resolved.
3.9 Allegation No. 10
The material management system (MMS) is not updated and item stock
numbers are not changed when engineering design packages (EDPs) or
as-built notices (ABNs) are implemented.
12
- _ _ - _ _ - _ - _ _ _ _ _ - _ _ _ _ .
'
.
.
NRC Inspection Scope and Results
During a transcribed interview conducted by the NRC, the alleger expressed
i concern that obsolete spate parts could be incorrectly installed in the
plant because the HMS is not updated to reflect changes in item stock
codes. The alleger stated that spare parts are rendered obsolete as a
result of part changes or replacements implemented by EDPs and ABNs.
The alleger gave an example of an obsolete Rosemount transmitter,
Model 1151, that had been incorrectly installed in the plant, but
did not provide the specifics of where the transmitter had been installed
or whether the incorrect installation had been documented on a DER.
The NRC inspector interviewed Nuclear Procurement section personnel and
discussed the use of the MMS with them. The HMS is a Detroit Edison
Company (DECO) computerized inventory control system used primarily for
contracts management, budgeting purposes, and tracking accounts pcyable.
The HMS is not a source of design-basis information and the licensee
does not use the system to select parts for installation.
The NRC inspector reviewed DERs to determin.e if the example provided
by the alleger had been previously documented by the licensee. DER 87-139
documented a problem that fit the description related by the alleger. The
DER stated that the use of an obsolete stock code had resulted in the
4
requisitioning of scrapped material, an 0-ring, for installation in a
Rosemount transmitter. Two different stock codes, one obsolete and the
other reclassified (new), had both referenced the vendor's part number
'or the 0-ring. The obsolete stock code had not been deleted in the
l .AS; therefore, the scrapped 0-ring was still approved for installation.
A review was performed by MEG to verify the suitability of the installed
l item for its application.
!
j On the basis of the review, the NRC inspector found no clear connection
! between the allegation and example provided by the alleger. The allegation
, described HMS updating problems that could potentially affect correct part
l installation, The example depicted an SPRS updating problem that resulted
I
in an incorrect installation. The inspector determined that this concern
! is of no safety significance because the MMS does not affect part
- application, installation, or design-basis configuration control. This
issue is considered resolvea, However, with regard to the concern that
obsolete parts can be incorrectly installed in the plant, the inspector
determined that this concern is valid. Installation of incorrect parts
in the plant because of an inaccurate SPRS data base is addressed in
Section 3.1 of this report (Allegation No. 1).
i
l
3.10 Allegation No. 11
I
The DER process is inadequate and uriable to resolve problems. Corrective
I actions taken by MEG in response to DERs do not address the root cause of
l the deficiencies.
13
- - - - - - - - - - - - - . - - - - - - - - - _
_ _ _ ,
.
'.
NRC Inspection Scope and Results
During a transcribed interview conducted by the NRC, the alleger expressed
concern that the DER process was inadequate because protslems identified by
DERs were not resolved. As an example, the alleger refeired to DER 85-324,
which the MEG completed in 1986. The alleger maintained that the DER was
not properly resolved and did not correct the parts classification problem.
- Before being notified of this allegation, the licensee had made numerous
changes in the DER process. These changes have continued throughout the
first half of 1988. The process was initially revised through the
'
issuance of FIP-cal-01-SQ, "Deviation and Corrective Action Reporting,"
Revision 0, December 30, 1987. The revised procedure (1) required
evaluation and tracking of regulatory and industry findings and
notifications; (2) required evaluation for adequacy of root cause
determination, disposition, and corrective actions by the Nuclear
Production Department after completion but prior to closure; (3) increased
the Plant Manager's role to an in process review of DERs; (4) incorporated
the LER process; and (5) incorporated the operating experience report
, program. This procedure (FIP-cal-01-SQ) was revised again on May 23,
1988. This latest revision (1) allows Nuclear Organization personnel
'
to initiate DERs anonymously, (2) adds provisions for escalating DERs
I when the initiating individuals and their supervisor cannot agree whether
!
the DER should be processed, (3) adds guidelines for repotting events
through the Nucin t Netwcrk, (4) allows for conditional release of items
l
on hold, (5) ade a mechanism to identify DERs that are significant
I
conditions adverse to quality, (6) expands the scope to include personnel
i safety items. (7) reassigns responsibility for DER number designation and
i tracking to the Plant Safety Director, and (8) requires an SR0 to screen
l DERs.
1
i The NRC inspector reviewed various DERs related to material control to
i
'
see if the responses routinely addressed root causes. The inspector also
interviewed MEG, Plant Safety, and Quality Engineering personnel with
'
regard to the DER process. For the DERs reviewed, the inspector noted
I that the MEG did not always completely respond to DERs. The NRC Open
l Item 50-341/88-08-01, referenced in Section 3.1, Allegation No. 1, is
I an example of an incomplete MEG response to a DER. However, improvement
! was noted on recent DERs. Other instances were noted of DER issues
1
assigned to the MEG that required escalation by the Punt Safety group
to management for agreement to proposed corrective action. The DERs
referenced in Section 3.8, Allegation No. 8, are examples that required
l escalation to management. The evaluations of DER responses performed
i by the Plant Safety section sufficiently ensure that the underlying
l causes of deficiencies are addressed.
.
l On the basis of the reviews, the NRC inspector found no connection between
i
the allegation and the example provided by the alleger. The allegation
dealt with the entire DER process. DER 85-324 identified a specific
problem with the classification of General Electric parts and was not
indicative of a programmatic breakdown of the DER process. To address
DER 85-324, the MEG performed a complete evaluation of all stocked
14
. _ _ _ _ _ _ _ _ _ _
.
.
.
.
General Electric parts and corresponding safety classifications; thus,
4
the licensee's actien to address the DER was proper and complete.
'
, However, the inspector did substantiate this allegation to the extent
that the MEG's respo1se to DERs did not always address the root cause
.
of the problein. It ippears the licensee's substantial changes in scope
definition and reassignment of responsibilities will improve the
responsiveness and effectiveness of the DER process. This matter
is considered resobed,
j
3.11 Allegation No. 12
,
The master instrument list (MIL) is not correct.
,
- NRC Inspection Scope and Results
!
During a transcribed interview conducted by the NRC, the alleger expressed
l
concern that the MIL does not reflect the design changes as they are
implemented by engineering design packages (EDPs) and as-built notices
- (ABNs). The alleger stated that when an instrument is replaced with a
new or different model, the change does not apply to all identical
instruments used in the same application. The alleger did not provide
any specific examples of the concern.
,
The NRC inspector reviewed DERs to identify any incorrect MIL information
i that had been documented by the licensee. The inspector identified
, DERs 88-0016 and 88-0415 as being related to incorrect MIL information.
DER 88-0016 was written as a result of the licensee's investigative
'
! effort to address these allegations and identified a wrong component
- number in the MIL for a .90semount transmitter. The same transmitter
l was listed in the SPRS and the MIL, but with different part numbers.
{ A field verification revealed the MIL to be in error. The underlying
i cause of the deficiency was attributed to the old Nixdorf input terminal /
1 program (data input), which did not allow verification of the input
j before the hard copy was printed. However, the hardcopy information
a was verified and maintained as a controlled document. The licensee
! corrected this problem by issuing ABN 7371 to update the MIL.
1
- DER 88-0415 identified instrument set points documented in the MIL that
were not consistent with the set points documented on the instrument
l
.
specification sheets. The original set points for the B emergency diesel
generator low level lube oil temperature alarm had never been changed
i
because the Operations Department had determined that they were acceptable.
The corrective action was to issue an ABN reflecting the field set points.
! Although it was thought to have been cancelled, an ABN (written in 1985),
i had been issued and incorporated the new set points into the MIL. These
DERs do not appear to indicate a programmatic breakdown that would have
- rendered the MIL inherently incorre.t.
,
l The MIL no longer exists because in March 1988 the licensee began
i consolidating the separate base configuration design documents, which
! consisted of the master instrument list (MIL), master valve list, Q list,
'
and seismic qualification review team list. The accuracy of the individual
,
15
l .
I
l
- - _ _ - _ - _ _
1 .
,
,
<
!
design documents, such as the Mll, were not verified before they were
combined to form the CECO data bise because they were maintained as
source documents for controlling plait design configuration.
i The NRC inspector interviewed the Nuclear Engineering Division and Nuclear
i
Production Division personnel responsible for implementing the guidelines i
for the data transfer and update. The inspector verified that each !
organization had defined a controlled process for updatirg their <
respective CECO data fields. The inspector also reviewed selected CECO I
l
'
data fields to verify that plant equipment and identification had been .
incorporated into CECO from the MIL. The administrative controls
established for transferring, updating, and maintaining the CEC 0
data base appear sufficient.
On the basis ar the review, the inspector did not substantiate the
allegation. The lack of specific information provided by the alleger,
in conjunction with the MIL's incorporation into CEC 0, precluded
identification of any incorrect instrument listings. This matter
is considered resolved. [
1 3.12 Allegation No. 13
I
The DECO Engineering Research engineer, referred to by the alleger as
the Warren Service Center engineer, maintains the approved / controlled
materials list (A/CML) and is frustrated with trying to approve consumable
material after it has been installed.
1
j NRC Inspection Scope and Results
l The A/CHL specifies limitations and restrictions for the applicability
and use of consumable materials approved by the Nuclear Engineerina/
Engineering Technology Section. ThepurposeofthelististominImize
.
l
the likelihood of equipment and system failures resulting from an
- environmentally assisted breakdown of consumables. Requests for changes
'
to the A/CHL are processed using an A/CHL change notice. The list is
!
maintained by a DECO Engineering Research engineer who works part time
j
for the Nuclear Engineering / Engineering Techaology Section at Fermi 2.
i
'
During a transcribed interview conducted by the NRC, the alleger stated
I that a Deco Engineering Research engineer responsible for reviewing and
l approving consumable material to be added to the A/CHL was frustrated by
the Fermi 2 practice of requesting approval to add material to the A/CML
after the material had oeen installed in the plant. The examples
provided by the alleger were the use of formanite for valve leak repairs
and the use of castor oil as a cutting aid. The alleger did not provide
l specifics as to where the consumables were used, only that the furmanite
l
example had occurred approximately 18 mcmchs ago.
The NRC inspector interviewed the DECO Engineering Research engineer to
determine if consumable material was installed before it was approved for
use. The engineer stated that h. iiad been approving consumables for use
at Fermi 2 for approximately tour years and could not recall any
16
____________ _
.
.
post-installation approval requests. He further stated that he did not
feel he had been pressured to approve consumable materials for use at the
plant.
The NRC inspector interviewed Nuclear Engineering / Engineering Technology
Section personnel and discussed the use of the A/CML with them. The
inspector also reviewed the A/CML and A/CML change notices to verify that
appropriate restrictions and limitations had been imposed on the use of
consumable materials. The inspector reviewed DERs to determine if the
examples provided by the alleger had been previously documented by the
licensee. The inspector identified DER 87-275 that was related to the
use of furmanite. No DERs were identified that related to the use of
castor oil. DER 87-275 documented a misapplication of the A/CML in the
use of furmanite for a valve leak repair. The problem had been initially
identified by the NRC as a violation (Violation No. 50-341/87-31-M)
because a safety evaluation had approved the use of furmanite for a
specific application based solely on its inclusion in the A/CML and
not on the ability of the material to meet the requirements of the actual
application. The inspector determined that this example did not support
the allegation that consumable materials are approved after installation
in the plant.
On the basis of the review, the inspector did not substantiate this
allegation. This matter is considered resolved.
3.13 Allegation No. 14*
The shelf-life program is not adequately wplemented.
NRC Inspection Scope and Results
During a transcribed interview conducted by the NRC, the alleger expressed
concern that 2500 items, some of which were purchased safety-related (Q),
have not had shelf-life requirements established by the MEG and that
shelf-life reevaluations (extensions) were only performed on an emergency
basis. The alleger further stated that the SPRS parts expiration report
(shelf life expiration report) was inaccurate and that shelf-life durations
were inconsistent for identical items. The concern regarding the
inconsistency of shelf-life durations is addressed in Section 3.3
of this report (Allegation No. 3); the other concerns are addressed
below.
Before being notified of this allegation, the licensee had performed an
audit of the MEG's activities. The purpose of the audit was to verify
the adequacy and effectiveness of the engineering activities performed
by the MEG, which included the evaluation and control of shelf-life items.
" Denotes allegations made by the second alleger.
17
~
_ _ - _ _ _ _ _
.____ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ - _ _ _ __ __ _ _ _ _ _ _ _ _ _ . _ _ - _ _ _ _ _ _ _ _
. .
.
The audit identified two findings: (1) items tagged with shelf-life
expiration dates were not listed on the shelf-life expiration report
and (2) quality control acceptance tags had not identified shelf-life
expiration dates for stock items. Additionally, the audit identified
one observation: identical shelf-life items have different shelf-life
durations. Audit Finding Reports A-QS-P-87-35-01 and 02 were issued to
evaluate the findings and to track the corrective action. At the time
of the inspection, the observation had not been addressed.
The NRC inspector reviewed engineering evaluation disposition forms (EEDFs),
the shelf-life expiration report, warehouse file stock cards, the MEG
activities, and material stored in warehouses A and B to verify th h
shelf-life requirements had been properly implemented. The inspector
found that EEOFs for shelf-life extension were completed on an as needed
(emergency) basis. For the EEDFs reviewed, the inspector found an
acceptable justification was provided to establish and extend shelf-life
durations. The justifications referenced shelf-life requirements for
different categories of material as presented in MEG policy memoranda.
The licensee provided the Military Standardization Handbook MIL-HDBK-695
C, "Rubber Products: Recommended Shelf Life," as the technical basis for
thS shelf-life requireinents delineated in the MEG shelf-life policy
memoranda. Although the MEG shelf-lifo policy memoranda are not an
appropriate reference for shelf-life determinations, the inspector
determined that MIL-HOBK provided the necessary technical basis for
shelf-life requirements. Additionally, the inspector verified that
the shelf-life expiration report was inaccurate with respect to storage
locations, shelf-life durations, and shelf-life e41 ration dates.
These inaccuracies were discussed with licensee pernnnel who stated
that the report would be corrected.
Section 17.2.15 of the Fermi 2 UFSAR requires that nonconforming items
in storage be clearly identified to indicate their unacceptable status
and be segregated until they can be properly dispositioned. During a
walkdown of warehouse B, the inspector noted the following safety-related
material with expired shelf life that had not been identified as such by
the licensee: (1) stock code 790-0533, Okonite tape; (2) stock
code 920-0587, RTV foam; and (3) stock code 101-0054, grout. These
failures to identify and segregate expired (nonconforming) shelf-life
items are considered to be in violation of 10 CFR Part 50, Appendix B,
Criterion XV (Violation 50-341/88-08-05).
On the basis of the review, the inspector has determined that the
controls established for the shelf-life program are not adequately
implemented. Thus the allegation is substantiated.
3.14 Allegation No. 15*
A quarterly inventory revealed that 200 feet of safety-related pipe
could not be accounted for.
18
.______ _______ _
o
.
1
[ NRC Inspection Scope and Results
During a trcnscribed interview taken by the NRC, the alleger stated that
there was no installation record for 200 feet of steel pipe that had been
i
purchased for safety-related use at Fermi 2. The alleger was concerned
that if the licensee received a 10 CFR 21 notification the material could
, not be located. The alleger said there had been two DERs issued that would
d
support his concern although he did not provide the specific DERs or
j any specifics on them.
The inspector interviewed Plant Safety section personnel with regard
l to the traceability requirements for safety-related material. Licensee
- personnel stated that traceability requirements for safety related material
- only apply to that material used in safety-related applications, It was
j further stated that the steel pipe in ouestion was assumed to have been
,
used in ar. application that was not safety-related. This assumption was
- based on the fact that the licensee procures all steel pipe safety-related
j (Q) and uses it for both safety-related and nonsafety-related applications.
- If the pipe is used in an application that is not safety-related, its
i traceability is not maintained. The inspector reviewed several DERs to
- identify any that fit the description of the two mentioned by the alleger.
However, none of the DERs reviewed by the inspector documented the
'
j unaccountability of steel pipe.
l On the basis of the review, the inspector did not substantiate
l the allegation. This matter is considered resolved.
! 3,15 Allegation No. 16*
l All oils and greases that were previously in the shelf-life program
are not included in the preventive maintenance program.
l
l NRC Inspection Scope and Results
During a transcribed interview taken by the NRC, the alleger expressed
! concern that the new guidelines that had been established for lubricants
'
were not being followed. The alleger stated that the responsibility to
maintain lubricants, all of which were originally included in the
shelf-life program, had been transferred to the preventive maintenance
- program. He was concerned that because the transfer of responsibility
' had never been formally or procedurally implemented, lubricants with
! expired shelf lives were being issued for use in the plant. The alleger
.
did not provide any specific examples of this concern.
! The NRC inspector reviewed oil and grease preventive maintenance
- activities and several DERs to determine if the licensee had documented
l any deviations frum the established lubricant guidelines. Before being
<
notified of this allegation, the licensee had issued DER 86-123, which
i was related to shelf-life extension for a stored grease. To correct this
i problem, the licensee established two sampling programs to ar.nually test
! lubricants, one for oils and one for greases. The NRC inspector verified
l
that preventive maintenance personnel had performed the annual lubricant
I
i
19
_ _ _ _ _ _ _ _ _ ___
s
O
.
sampling, which began in January 1987. As a result of the most recently
performed lubricant samplings, two DERs were issued: DER 88-0077
documented unacceptable oil based on visible settling and separation
in the samples and DER 88-0427 documented contaminated oil based on the
results of the chemistry report that analyzed the samples. The licensee
determined that the underlying cause of these deficiencies was oil
which occurred from the poor practice of
contaminationbyintermixingIlthroughthesamepumpandpipingsystem.
drawing different types of o
The licensee proposed to change the pumping scheme, discard any
contaminated oil, and incorporate cautions against intermixing into
the lubrication manual to prevent recurrence of this problem.
The NRC inspector verified that bulk-stored lubricants at the turbine
building lube oil issue station and warehouse C (oil and grease warehouse)
had been accurately identified and labeled. However, the inspector noted
that lubricants had not been deleted from the SPRS shelf-life expiration
report and that shelf-life expiration tags remained on the lubricant
drums stored in warehouse C.
The NRC inspector interviewed warehouse and maintenance personnel and
discussed the inclusion of lubricants into the preventive maintenance
program. Questions were raised by the inspector regarding oil and grease
shelf lives and the DECO Engineeting Research Department (ERD) reports
that established the shelf-life. In response to the questions, licensee
personnel identified a problem with the implemented shelf-life for gruses,
which resulted in DER 88-1179 being issued to document the indeterminate
quality of sealed grease stored in the warehouse. The root cause of the
DER was a misinterpretation of ERD Report 86B73-7, which provided the basis
and established the selection critoria for the lubricant sampling plan.
The licensee's immediate action was to have all sealed grease containers
tagged and placed on hold pending sample analysis or disposal.
l On the basis of the review, the inspector did not substantiate this
- allegation because lubricants are included in the preventive maintenance
program. This matter is considered resolved.
l 4. Exit Meeting
l
j The inspector met with licensee representatives (denoted in Section 1)
l throughout the inspection and at the conclusion of the inspection on
September 20, 1988, The inspector summarized the scope and findings
of the inspection activities, and the licensee acknowledged the inspection
l
findings.
! The inspector also discussed the likely content of the inspection report
with regard to the documents or processes reviewed during the inspection.
The licensee identified proprietary information that had been disclosed
to the inspector during the course of the inspection. However, after
l discussions with the licensee, the inspector has determined that there
!
is no proprietary information contained in this inspection report.
! Attachment:
i
Detroit Edison Ltr NRC-88-0094
dated Aprl) 19, 1988
i
\ 20
,
t