ML20211C905

Rev 1 to Qapr 16, Corrective Action

ML20211C905
Person / Time
Site:	Fermi
Issue date:	09/10/1984
From:	DETROIT EDISON CO.
To:
Shared Package
ML20211C861	List: ML20211C855 ML20211C866 ML20211C873 ML20211C890 ML20211C895 ML20211C905
References
FOIA-86-370, FOIA-86-A-147 QAPR-16, NUDOCS 8610220052
Download: ML20211C905 (6)

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Ennco Ferm; Atomic Poi.e* Piant Unit 2 QAPR 16

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2 o. 7 Edison Program Requirements 1

%' 52 10196; C0KRECTIVi; ACTIOt1

. 1.0 Purpm.e

- To define a uniform = thed and responsiblities for identifying, decu-menting, evaluating. en raating, repnrting, and trending conditions considered adverse to quality or nuclear safety.

2.0 Applicability The provisions of thi s. Ql.PT. t ha l 1 ?pply to all nonconforming acti-vities or conditiuns adverse to quality to preclude recurrence. The mett.ods set forth in this CAPR are not iwant to be or take the place of norul supervioury control of activities.

3.0 Definitions 3.1 Conditions Ad*;- " '*ality - Ariy anomaly affecting quality including failu:.m. .-.lfunctions, deficiencies, deviations, deiettive rh terial and equipc.ent, abnormal occurrences, and nonconformances.

3.2 Signific_ ant, Conditions Adverse to Oualtiv - A condition adverse to quality is considered significant when, if uncorrected, it could have a serious effect on safety or operability. The cause of such conditions-shall be deterr.ined and corrective action taken to prevent recurrence.

3.3 Corrective Action - As used under the provisions of this proce-

' dure, corrective action involves those steps taken to preclude or reduce the probability of recurrence of conditions adverse to quality. Such actions may involve redesign, revision of a written requirer.c:t, reassignment of personnel, adding process centr.,1s or inspectior. steps, dc ve lopt,c nt of peraunnel, includir.g supervision, training, and qualification, etc.

4.0 References 4.1 10Ct A t -Lepor t ing of De f e c t s and Noacompliance 4  ; . J r. ' .!' s -L...  : cf .-- - -t!- te:::tr (I+fiele -.

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4.3 10CFR50.72-Im=ediate tiotification Kequitecrents for Operatirg Nuclear Power Pla:.t >

4.4. 10CFR50.7 3-1.icensee Event Report Systeo OA!!!I/I3.1 8610220052 861009 l% 7 3 TE A-147 PDR ,

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QAPR 16 Ennco Ferm. Atomic Power P. ant Und 2 a 7

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5 2 10 1984 CORRECTIVE ACTION 4.5 ANSI N18.7/AND 3.2 - 1976-Administrative Controls med Quality Assurance for the Operational Phase of Nuclear Power Plants (Endorsed by Regulatory Guide 1.28, 2/1979 Rev. 2}

for Control of 4.6 ANSI N45.2.13 - 1976-Quality Assurance Requirement Procurement of Items and Services for Nuclear Power P3 ants (Endor (Endorsed by R.G. 1.123 (7/1977 Rev. 1)]

4.7 Fermi 2 FSAR-17.2 - Corrective Action 4.8 Technical Specification. Sections 6.6 and 6'.2.

4.9 QAPR 15 - Nonconf erming Hat erials , Parts, or Component s 4.10 OQAF 16 - Corrective Action 5.0 RESPONS1h11.171ES_

5.1 Nuclear Quality Assurance (NQA) is responsible for reviewing the e requirements for prompt identification and correction of condi-tions adverse to quality and approving procedures that describe

' the c.ctheda used for 1:plecent at ion. NQA is responsible for

, concurring with the identified corrective action and verifying e the effectiveness of the implementation.

5.2 Personnel who discover a condition adverse to quality shall All plant promptly notify their immediate supervisor and/or NQA.

personnel are responsible for reporting ti. rough supervisory

• channels to the Superintendent-Nuclear Production the discovery

, s of any significant condition adverse to qiiality. NQA shall receive a copy of the noncortf ormance document.

5.3 In the case of a significant condition adverse to quality, NJA personnel shall review, approve, and particpate to the extent necessary in the determination of the cause of the condition and the corrective action required to prevent recurrence.

5.4 The Onsite Safety Review Organization (OSRO) is responsible for evaluating significant conditions adverse to quality and report-ing on its conclusions.

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5.5 The Nuclear Saf ety Ecview C: cup 0: conditics.s ing and concurring in the disposition of significant j adverse to quality brought to its attention by OSR0 and for i carrying out the provisions of its Charter as defined by the I Technical Specifications.

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o r r31984 ConKECTIVE ACTION 5.6 7he responsible Norlear Operations organtzution Supervisor shall identify the root cause and the appropriate action to prevent recurrence and effectively implewent the corrective action.

5.7 bQA sholl a=>ure through teview and approval, the adequacy or procedures for comuunicatinns with the NRC regarding reportable deficiences. These procedures shall address, but are not limited to, the reporting requitecents of 10CFR21, 10Crn50.55(e),

10CFn?2, and IUCFK73.

5.8 The Nuclear Engineering organiz6 tion is responsible for cont rol of design and design changes at the Fermi 2 Power Plant associ-ated with Plant engineering, nuclear technology, and nuclear f uel sar.a g eree n t .

In its continuing role with respect to configuration control and corrective action, it is responsible for ensurinF that nonconf ormances are resolved, variations f roc design are processed, modifications to systems and structures .are processed, that engineering analyses are provided in eupport of corrective action, and that engineering documents are revised, and issued as necessary, tc reflect the as-tuilt, codified condition.

5.9 Nuclear Production shall assure that efforts of plant operations resol-personnel are directed toward identifying, analyzing, and vang ferti 2 plant onelte corrective action such that related work does not continue until a course of action is established; that, when appropriate, Nuclear Engineering and NQA resolve the nonconformances; and that trend analyses and other appropriate actions are taken. Of particular importance during plant opera-tior, and maintenance activities is the procedural requirement fut follow-up on the discrepancies and failures to assure that sici-lar systets, cctponeath, or caterials in the plant are also corrected.

6.u kequirecents 6.1 Conditions adverse to quality, including failures, talfunctions, deviations, and detective cateriul and equiptent, abnura.a1 occut-rences and nonconf ormances shall be documented through esta-blished procedures f or disposit ion of nonconf ormaces. These procedures shall require that the conditions adverse to quality te evaluated ard that necessary action be taken to preclude

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v-n consideration of other struttures, Sybtets , and co;;.cn(,t 3 similar discrepancies might exist cr occur.

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6.2 The corrective action necessary to prevent a recurrence may be documented on a nonconformance document for resolving nonconfor-

. nonces or on a Corrective Action Report. All nonconformance documents shall be reviewed by the responsible and af fected organization and NQA. The af f ected organization makes routine follow-ups to assure that the agreed upon corrective action is accomplishe.d. Follow-up action is also taken by NQA to verify proper implementation of corrective action and to close out the corrective action in an expeditious manner. Reports specifying and documenting the corrective action taken are also reviewed by NOA prior to filing in the records Storage Facility to ensure that reports are adequate and complete.

6.3 NQA shall review all nonconformance documents, audit and inspec-tion reportn, trend analyses, and other conditions adverse to quality to determine the necessity to apply corrective action to prevent recurrence. Based on this review, NQA shall determine if significant conditions adverse to quality do exist. For those items identified as significant conditions adverse to quality, NQA shall assure that adequate investigative and recedial or preventive corrective action is initiated and effectively imple-sented. The Superintendent-Nuclear Production, shall be notified of significant conditions requiring further action on his part or that of the Plant staff.

6.4 Discrepancies in materials, equipment , or per f ormance, or failures in the QA Program, when discovered, shall be corrected as promptly as possible. In addition to correction of the imme-diate discrepancy, each situation shall be evaluated to determine the root cause(s), and appropriate actions shall be idcntified to correct them. These actions are reported to appropriate levels of management, usually through routine audit reports, trend anlyses, or other means.

b.5 Corrective action shall be initiated upon discovery of any signi-ficant condition adverse to quality as defined in Paragraph 3.2 of QAPR 15. These significant conditions adverse to quality include the following:

1. Nonconformance Requirements for documentation and

~ disposition of nonconf ormances are given in QAPR

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or Cc ;:ren:5 2 Audit _ Findings The system of conducting audits, reporting

~~ audit ' findings, and recommending corrective action are given in QAPR 18-Audits.

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3. Procedural o_r Docucentation Deficiencie_s Any deficiency alleged to exist in a procedure, work instruction, or

. completed form, which as a result of its implementation could create a significant condition adverse to quality, shall be documented on a nonconformance document and reported to the Superintendent-Nuclear Production for appropriate action.

4. Activities of Personnel Any activity which allegedly jeopardizes saf e operation of the Fermi 2 plant shall be documented on a nonconformance document and reported to the Superintendent-Suclear Production f or appropriate action.

5. Repetit_ive Adverse Conditions Conditicns adverse to quality which are found to be recurring shall be evaluated by the Onsite Saf ety Review Organization (OSRO). Such reviews shall include consideration of structures, systems, and cocponants in the Termt 2 plant where similar conditions might exist or occur _and shall be coc onicated to appropriat e levels of canagement for resolution.

6. Supplier _ Discrepancies When recurring discrepancier appear to involve a supplier, the appropriate NQA personnel shall bring the catter to the attention of the Director-NQA for renolution.

7. Reportable Events and Noncompliances Any defect or nonecepliance conditten reportable to the Nuclear Regulatory Com:ission (SRC) under the provisions of 10CFR21 or the Technical Specifications, shall be deemed to be

S 1 g n i f i c a n t , and shall be processed in accordance with the provisions of this QAPR.

8. Inaden mte rnrrective Actinr; Ineffective corrective acticn may be significant and should be escalated to the appropriate levels of managetent for resolution. Corrective actions may be associated with nonconformances, NQA audits, trending reparts, or as a result of other information brought to the attention of management.

( ' Ven bre. contractors, or suppliers to Edison are responsible for

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and quality assurance r e y.ir e r e r.t s m; = c i: a c i t. p t w u r e.c e r.,

docu:nent s and are also responsible f or det ermining and correc tir:g the cause of the nonconf ormance when the condition is determined to be significant. When suppliers repeatedly furnish products m 't 11/11.5 osunwid

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9-5: P 101984 CORRECTIVE ACTION that do not conform to the requirements of the applicable pur-chase cont ract , HQA shall be responsible to conduct a reappraisal of the suppiter's quality assurance program, when appropriate.

Results of the reappraisal, together with a request for specific corrective action, are transmitted to the supplier. If the supplier performance dees not improve NQA shall initiate action to have the supplier removed f rom the Approved Suppliers list .

6.7 Actions taken for significant conditions adverse to quality shall include the following:

1. Ident ification of the condition

2. Action taken to correct the condition (remedial)

3. Identification of root cause

4. Determination ci the need for corrective action to prevent recurrence

5. Dctereination of reportebility to NP.C

6. Documenting the actions taken and their basis.

7.0 Eecords 7.1 All Corrective Action documentation shall be classified o.

permanent quality records and collected, stored, and maintained in accordance with QAPR 17.

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January 26, 1985 NE-85-0233

?"IORITY Rourgga y sc Director of Nuclear Reactor Regulation 3 {d 'S Attention: Mr. B. J. Youngblood, Chief a Licensing Branch No. 1 Division of Licensing d{ og 2L.

p U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Reference:

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NRC Docket No. 50-341 ,, gg 4 f , g,[

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(2) Letter dated January 19, 1985, Requ g for Exemption to Appendix J

Subject:

Request for Exemption to Appendix J This letter is intended to provide more complete justi-fication for the request for exemption to,10CFR50,'g Appendix J originally submitted in Reference 2. Reference requestedexemptionfromParagraphIII.D.(2(b i , which states: ,

" Air locks opened during periods when containment integrity is not required by the plant's Technical Specifications shall be tested at the end of such periods at not less than Pg."

Whenever the plant is in Operatiohal Condition 4 or 5, containment integrity is not required. Therefore, if an air lock is opened during either of these conditions the subject paragraph requires that an overall air lock leakage test be conducted prior to entry into Operational Condition 3. Such a test involves the following activities:

o Installing 14 tie downs to the interior air lock door (4-6 hours) o Pressurizing the air lock to Pa (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) o Waiting for the ,ir lock volume to stabilize.and '

recording the leakage (3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />) o Depressurizing the air lock, removing and storing the tie downs below the air lock floor g k g k' I (3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />).

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,e January 26, 1985 NE-85-0233 Page 2 This test would require an average of 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. Often there are minor problems that require containment entry just prior to entering Operational Condition 3. This would require an additional 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> test or personnel would be required to remain inside containment to perform such activities until entry is made into Operational Condition 3.

Paragraph III.D.2(b)(iii) of Appendix J allows the interior and exterior air lock door seals to be pressurized to P a as a satisfactory method of assuring air lock integrity after being opened while in Operational Conditions requiring containment integrity. This test is much less time.

consuming (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />).

Therefore, Detroit Edison requests an exemption from paragraph III.D.2(b)(ii) and instead intends to demonstrate air lock leak tight integrity prior to entering Operational Condition 3 by verifying acceptable leakage after pressar-izing the interior and exterior air lock door seals to not less than Pa. If, however, maintenance has been performed on the air lock since the last successful test performed pursuant to III.D.2(b)(i), an air lock leakage test will be performed.

Detroit Edison also requests that the draft Fermi 2 Technical Specifications be changed as indicated in

. Attachment 1 to conform to the requested exemption.

I hereby certify that this proposed change to the Fermi 2 Technical Specifications as well as the changes requested in letters dated January 10 and January 22, 1985 respectively, accurately reflects the plant, the Final Safety Analysis Report and the staff's Safety Evaluation Reports in all material respects, except as necessitated by the above discussed change.

Should you have any further questions, please contact Mr. O. Keener Earle (313) 586-4211.

Sincerely, f

cc: Mr. P. M. Byron Mr. M. D. Lynch Mr. L. N . Olshan Document Control Desk, USNRC Washington, D. C. 20555

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CONTAINMENT~ SYSTEMS .

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4.6.1.3 Each primary co'ntainment air lock shall be;ilemonstrated OPEMB_Lj': 3

a. Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following each closing, except when the a' lock is being used for multiple entries, then at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, by verifying seal leakage rate less than or equal to 5 scf per hour when the gap between the door seals is pressurized to Pe, 56.5 psig.

_) b. Pa

,g By conducting an overall air lock leakage test at P,, M.5 psig, and by verifying that the overall air lock leakage rate is within its limit:

1. Prior to initial fuel loading and at 6-month

• intervals thereafter,

2. gt,m,bdp'e' Bed during periods when containment integrity was ,o gs Prior lockx e not re t.

At leasts'sl [ mothshyver once per [ tis" 'l'Dn"Yy((g .7 " l '#

Y.Y'c'.'.l"'d that only one door in each 3'"

d. air lock can be opened at a time.**

s, Pr . o r tc establishino PRIM ARY 60/4TAIKMENT TNTEGR\TY if thi air loc.K has bun openE d ~

d e r inc P E rio a s w h e n c. o n C ain vn E nT i n C 6.6n8 iT y w a s n eT RE'joice d, Th L d t .n c o s Tn nTi o n S h e ll U trdfy is Sell IER K n6E y-erE lE S5 Th n d o r E.9 u A l t o E.s e t PLR hc e R W htn tLL S60 ls

. 15 P r E 5 5 0 r 2-E. 6 t o Pa ,y a e b c.TW E EN t he d o c,e56.5 .ps ; q O nit lcc.K is t e sTe d PoR3e n nT- Te t.l.Ic.l. 3. C . J IA S Tt a d .

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"The provisions of Specification 4.0.2 are not applicable.

• • Except that the inner door need not be opened to verify interlock OPERABILITY when the primary containment is inerted, provided that the inner door inter-lock is tested within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the primary containment has been deinerted.

3/4 6-9 FERMI - UNIT 2

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FERMI 2 Psga 1 NUCLEAR OPERATIONS DIRECTIVE 12-11-85 NUCLEAR SAFETY PURPOSE This directive provides guidance regarding nuclear safety. including the safety impl# cations of plant changes procedure changes, plant incidents, and operating experiences, and establishe related individual and organizational responsibilities.

GENERAL POLICY Thes Detroit Edison has primary responsibility for the safe operation of its nuclear power plant responsibility shall be carried out diligently, and the scope of Edison's concern shall go beyond e' conformance to NRC regulations and requirements. Compliance with regulations does not release the Company from its responsibility for nuclear safety.

A comprehensive program of surveltlance, review. and investigation of plant performance and abnormat occurrences. as well as industry oparating experience, shall identify potential or actual safety probfome and suggest solutions. However, changes made to the plant or operating procedures can sometimes produce unexpected results because of complicated interfaces subtle interactions of systems. Therefore, the design configuration and the operating procedure in existence when the operating license is issued rSall only be substantively modified when the change will fulfill a mandatory requirement or reb.t in significant improvements in safety and or operability Any changes shall t,e carefully evaluated before they are implemented A thorough evaluation of any incidents resembling those analyzed in the Final Safety Analysis Report (FSAR) shall permit continuing venfication that operatior.at empenence is within the bounds defined by the FSAR.

RESPONSIBILITIES Any design changes, changes in operating procedures. plant incidents, or operating experi which have potential safety implications shall be investigated by an appropriate organlistional unit or review group. Three specific safety review groups within the Nuclear Operations organization have designated and overlapping responsibilities in performing and/or appro anfety reviews These three groups are (1) the Onsite Review Organization (OSRO). (2) the Independent Safety Engineering Group (ISEG), and (3) the Nuclear Safety Review Grou Tr t ufC, responstt'l.t.es o' e?:* 9 oer ere covered in program descriptions. procedures .4.- cw and v work instructions for e6ch of tr.(se orgf r.artsons' units ir additei e notic s re e of the Board of Directors,in accordance with its organizational directives. shall monitor the overall safety policy, praritmaranon..and partsunence of review activitios AR MS . it.F oRM AfloN SYSicMS atc 3 T _h...REV, PAGE_,,,, o m . . d , _ ,,_,,pigosn . m a s y s .._

DEC 13 885

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