ML20212B940
| ML20212B940 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/03/1986 |
| From: | Agosti F DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| VP-86-0173, VP-86-173, NUDOCS 8612290347 | |
| Download: ML20212B940 (6) | |
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DmG O2Tn't Nuclear Operations Detroit' Y#*
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Edison EAF5FN gr.L.
December 3, 1986 VP-86-0173 Mr. James'G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 l
Dear Mr. Keppler:
Reference:
Fermi 2 l
NRC Docket No. 50-341 NRC License No. NPF-43
Subject:
Detroit Edison Response Insoection Reoort 50-341/86026 This letter responds to the notices of violation included with your Inspection Report No. 50-341/86026.
This inspection was conducted by Messr.
R. W. DeFayette, W. G. Rogers, M. E. Parker, C. D. Anderson, M. J. Farber, l
R. A. Kopriva, P. L. Hartman, T. S. Rotella, M. D. Lynch, I
D. S. Brinkmann, R. A. Becker, and L. E. Whitney of NRC Region III for the Period July 29, 1986 through September 29, 1986.
l Detroit Edison trusts this letter satisfactorily responds to'the notices of violation cited in Inspection Report 50-341/86026. If you have any questions regarding this matter, please contact Mr. Frank H. Sondgeroth, at (313) 586-5083.
l Sincerely,
[
1 cc W. G. Rogers J. J. Stefano G. C. Wright USNRC Document Control Desk Washington, D. C. 20555 8612290347 B61203
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THE DETROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATIONE ORGANIZATION RESPONSE.TO NRC INSPECTION REPORT NO. 50-341/86026 DOCKET NO.-50-341 ILICENSE NO..NPF-43.
. INSPECTION.AT:
FERMI 2,-NEWPORT, MICHIGAN INSPECTION CONDUCTED:
JULY 29,1986 THROUGH SEPTEMBER 29, 1986 I
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RESPONSE TO NRC INSPECTION REPORT -NO. 50-341/86026 Statement of Violation 86-026-03 Technical Specification 3.7.7.2 states, "With one or more of the above spray and/or sprinkler systems inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a continuous fire watch with backup fire suppression equipment for those areas in which redundant systems or components could be damaged; for other areas, establish an hourly fire watch patrol."
One of the required spray and sprinkler systems included is the diesel fire pump room wet pipe sprinkler located in the general service water pumphouse.
Contrary to the above, on September 8, 1986, at 8:00 p.m. EDT, the licensee failed to establish an hourly fire watch patrol within one' hour af ter the diesel fire pump room wet pipe sprinkler system was shown to be inoperable by its failure of the 18 month surveillance.
The fire watch was not established until September 9, 1986, at 11:55 a.m. EDT.
Correc tive_69.t100._TAhen._qnql Results Achieved At approximately 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> on September 8, 1986, during testing of the water flow alarm, Control Room annunciator 16D28 did not alarm as required on a simulated sprinkler system flow condition.
The operator conducting the test immediately notified the
. Nuclear Assistant Shift Supervisor (NASS) that the water flow alarm portion of the surveillance test had f ailed.
The operator was instructed by the NASS to continue the test.
At approximatelf 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> the operator returned to the Control Room because of procedural discrepancies in the surveillance test.
At approximately 1155 hours0.0134 days <br />0.321 hours <br />0.00191 weeks <br />4.394775e-4 months <br />, on September 9, 1986, the NSS on a subsequent shift reviewed the sprinkler surveillance results and determined that Technical Specification requirements had not been satisfied.
The NSS took immediate corrective action and established an hourly fire watch.
This violation was identified in Licensee Event Report 86-032.
I Corrective Action to Avoid Further Violation The NASS was counseled in the importance of adequately identifying Technical Specification Limiting Conditions for Operation and taking the appropriate steps to prevent such violations.
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RESPONSE TO NRC INSPECTION REPORT NO. 50-341/86026 Corrective Action to Avoid Further Violation (Cont')
A description of this event was placed in the Night Order Log for the Control Room shift me-,ement to reinforce the need to thoroughly review documentation to ensure Technical Specification compliance.
LER 86-032 will be discussed during the fourth quarter fire brigade meeting.
The LER has, also, been made required reading for Licensed and non-licensed operators for the month of December, 1986.
Date When Full Comnliance will be Achieved The NASS counseling has been completed.
Discussion of this event during the fourth quarter fire brigade meeting and the required reading will be complete by December 31, 1986.
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, RESPONSE TO NRC. INSPECTION REPORT NO. 50-341/86026
-Statement of Violation 86-02G-05 Technical Specification 6.8.1.a requires that wri*'en procedures be established, implemented, and maintt..ned covering, among other things, the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
. Regulatory Guide 1.33, Revision 2, Appendix A.
Section 9, requires, among other things, that maintenance that can af fect the performance of safety-related equipment should be properly planned.and performed with written procedures and documented instructions appropriate to the circumstances.
The Licensee's Procedure POM 12.000.15, Revision 20, "PN-21 (Work Order) Processing" requires, among other things, in Section 7.1.2.4.c, that "if after the-problem has been isolated, the scope of the repair or rework is not within that stated.on the PN-21, the responsible section head or designee shall revise the Attachment A as needed to complete the repair or rework.
Changes to Attachment A shall be reviewed by QA and Health Physics as applicable and the Nuclear Shift Supervisor.
. All those who are ' required to review the change shall sign the Attachment A to signify'their review."
Contrary to the above, on September 3, 1986, the licensee failed to implement this procedure as noted by the absence of a Health Physics signature on Attachment D to PN-21-654160 (Maintenance work on isolation valve for reactor building to torus vacuum breaker).
QCURCtlyA_Sgflon Taken and Results Achleved PN-21-654160 was initiated in the presence of Health Physics.
At the time of initiation Heath Physics attached a note to Attachment A of the PN-21 stating that their presence would be required for a system breach.
The work order was revised three times, none of which involved a system breach.
The fourth revision, D, to the work order involved a system breach.
A formal work package was not presented to Health Physics for review, as required by POM procedure 12.000.15 and Maintenance Instruction MI-M251, and no Health Physics sign-off was obtained.
The work order was routed to the work group as they were walking to the job location.
The work group, General Maintenance Journeymen, stopped at the Health Physics control point and notified them of their intention to return to the job location.
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RESPONSE TO NRC INSPECTION REPORT NO. 50-341/86026
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Corrective Action Taken and Results Achieved (Cont')
The. technicians at the Health Physics control point were unaware of.the pending. system breach and, therefore, had no further. input.- The work group proceeded to the job location and began work without-implementing the specific RWP required for the work.
Health Physics stopped ~ work on the valve, T23-F410, at 1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br />,tand initiated a Deviation Event Report.
All craft personnel working on the valve were required to read and initial the specific. RWP, 86-1222, prior to resuming work.
Corrective Action to Avoid Further Violation The importance of routing work packages to the applicable groups, when revisions are made thereto, will be discussed with all Operation Support Engineers (OSE's).
Additionally, all OSE's will be required to read POM procedure POM 12.000.13 (Radiation Work Permit)
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The importance-of reviewing the RWP board prior to entering the radiologically controlled area will be discussed with the above mentioned General Maintenance Journeymen.
The work group will also be made aware of the importance of conveying precise information to the Health Physics control point about the task
.to be completed.
Date When Full Connliance will be Achieved Full compliance will be achieved by December 31, 1986.
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