ML20235G251
Text
() np Ww Nok7: R A a se}
~'
o P e 7- )?h e g N Aeft4 June 16, 1987 J S k h.,o A*. Gne ns.,(jJ)
Phl./4 Mr. Richard E. Petticrew, Chaiman County of Monroe, Michigan Board of Commissioners 125 East Second Street Monroe, MI 48161 Dear Mr. Petticrev-Thank you for your letter of May 28, 1987, requesting information related to the NRC's inspection of Detroit Edison Company's SAFETEAM files.
As you may recall, prior to the NRC's full power Comission meeting in July of 1985
~
Region 111 directed that a review of SAFETEAM concerns and Detroit Edison's investigations of these concerns be completed.
At that time, SAFETEAM files contained approximately 750 safety-related concerns.
We asked the utility to sample approximately 50 percent of the safety-related cercerns in the SAFETEAM files. We reviewed til of ttc S/,FETEAM cases with the utilit) in order to appropritttiy classify pctentiti safety-related concerns.
All ci the safety-related concerns were then divided ec,ually between the utility and.the KRC for further followup. The utility elected to look at all sefety-related concerns assigned to it The KRC inspected a 20 percent sample of its assigned concerns.
The NFC sam le was selected using engineering judgment to first select the most potential y safety significant cases with the belance selected randomly.
This resulted in the NRC inspecting approximately 10 percent of all safety-related concerns. During the course of the review the utility expanded the number of concerns it reviewed. This resulted in some SAFETEAM concerns being reviewed by both NRC and the utility, and in the utility inspecting in excess of 50 percent of the safety-related concerns.
While we had identified problems with the prograr overall, the safety concerns were four.d to be properly addressed ano appropriate corrective actions were taken wher wcrranted.
Further, the Office of 3r.vestigaticns (01) evaluated those concerns involving potentic1 wrongdoing. The 01 report is critical of the i
SAFFTEAM process for identifyir.g allegations and for investigating them. Tbc l
NRC technical staff concluded, through its own review and through the results of the utility's reexamination of the SAFETEAM safety-related allegations, that there were no safety questions that were not adequately addressed from a i
I technical point of view. These matters wcre all addressed during the full power licensing meeting in July of 1985.
8709290512 870924 PDR FOIA MAXWELLS 7-413 PDR-
v s,
Mr. Richard E. Petticrew 2
June 16, 1987 1 arr enclosing the applicable insrection reports documenting our findings for your use.
As you may be av.6re, or. P.sy 7,1987, the Governsent Accountability Project tiled a request with the Comission pursuant to 10 CFR 2.206 on behalf of the Safe Energy Coalition of richigan and the Sisters, Servants of the 1meculate Heart of Mary Congregation regarding SAFETEAM. That request is currently under review and we will provide you with a copy of our decision.
Should you have any additional questions, please call me or Ed Greenman of my staff.
Sincerely.
Cr!g!neil ef rM W A. tert Davit A. Bert Davis Regional Administrator
Enclosures:
1.
Inspection Petert No. 50-341/85025(0RPi etc transtittri 'tr 2.
Inspection Report No.50-341/85037(DRP) and transa.ittal ltr Rill y R1 R1 RIII RI R.11 eth A
ello Da 's dan ho us Pe g6/ly/87 6/Ib/87 6/p /87 6// 0 87 Lickus/tst B
n 6/,6/E7 6/gg/87 4
l l
..e see -
UNITED 8?cTES 9,
NUCLE AR REGULATORY COMMIS$10N MEGION til 799 ADOSEVELT ADAD j
o u... m.... u......., n N....
001 2 5 1985 1
1 Docket No. 50-341 The Detroit Edison Company ATTN:
Wayne H. Jens Vice President Nuclear Operations 6400 North Dixie Highway Newport, MI 48166 Gentlemen:
This refers to the routine safety inspection conducted by P. M. Byron, M. E. Parker, D. C. Jones, S. G. DuPont, and J. M. Ulie of this office on July 1 through September 30, 1985, of activities at Fenni 2 authorized by Facility Operating License No. NPF-43 and to the discussion of our findings with R. S. Lenart at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection.
Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
During this inspection, certain of your activities appeared to be in violation of NRC requirements, as specified in the enclosed Appendix. A written response to violation 1 is required.
With respect to violation 2, inspection activities have determined that appropriate corrective action has been taken to correct the identified violation and to prevent recurrence.
Consequently, no reply to this violation is required and we have no further questions regarding this matter at this time.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
, h-lo n W,; 4 1,,
} }-O,
v ya w 1 Y _ _ __ -- __
The Detrrdt Edison Company 2
1.ysc r
.J u
/
We will gladly discuss any questions you have concerning this inspection.
Sincerely, 1
Original signed by N. J. Chrissotimos" N. J. Chrissotinos, Chief Reactor Projects Branch 2 l
Enclosures:
l 1.
Appendix, Notice I
of Violation 2.
Inspection Report i
No. 50-341/85037(DRP)
~
cc w/ enclosures:
L. P. Bregni, Licensing l
Engineer l
P. A. Marquardt, Corporate Legal Department DCS/RSE (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission Harry H. Voigt, Esq.
Nuclear Facilities and Environmental Monitoring Section Monroe County Office of Civil Preparedness 1
RII]
R111 l
W gh /tja C
ss'otimos 5V6 /X%/tth nu,e l
l
)
1 i
Appendix i
IOTICE OF VIOLATION Detroit Edison Company Docket No. 50-341
)
As a result of the inspection conducted on July 1 through September 30, 1985, and in accordance with the General Policy and Procedures for NRC Enforcement 1
Actions (10 CFR Part 2, Appendix C), the following violations were identified:
1.
Technical Specification 4.3.1.1 states, "Each reactor protection system instrumentation channel shall be demonstrated OPERABLE by the performance i
of the CHANNEL CHECK, CHANNEL FUNCTIONAL TEST, and CHANNEL CALIBRATION operations for the OPERATIONAL CONDITIONS and at the frequencies shown in Table 4.3.1.1-1."
Table 4.3.1.1-1 requires the channel functional test to be performed weekly for shutdown conditions (Modes.3 & 4) for the intermediate Range Monitors (IRMs).
Contrary to the above, on September 6,1985, the licensee failed to perform the required weekly channel functional tests on IRMs B, G, and H within the required time interval as required by T.S. 4.3.1.1.
This is a Severity Level IV violation (Supplement I).
'2.
10 CFR 50 Appendix B, Criterion V, as implemented by Deco procedure QAPR 5, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures,... appropriate to the circumstances." Detroit Edison procedure QAPR 5 implements Criterion V.
Contrary to the above, the procedure governing maintenance on the diesel generator (NI-M136) was not appropriate in that it did not specify the material to be used to cleanup oil which allowed an inappropriate material to be used which resulted in the diesel generator being inoperable.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violation; and (3) the date when full compliance will be achieved.
Consideration say be given to extending your response time for good cause shown.
YW Ic ti BC V byi N. J.jthrRsoMoos, Chief Dated Reactor Projects Branch 2
,e
- g f
s
U. S. NUCLEAR REGULATORY Co m ISSION REGION III Report No. 50-341/85037(DRP)
Docket No. 50-341 License No. NPF-43 Licensee:
Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name:
Fermi 2 Inspection At:
Fermi Site, Newport, MI Inspection Conducted: July 1 through September 30, 1985 Inspectors:
P. M. Byron M. E. Parker D. C. Jones S. G. DuPont J. M. Ulie
/
I Approved by:
7Wpight,C f
/,. n.s s R actor Projects Section 2C Date l
l Inspection Stamary Inspection on July 1 through September 30, 1985 (Report No. 50-341/85037(DRP))
Areas Inspected: Routine, unannounced inspection by resident inspectors of licensee action on previous inspector identified itess; licensee action on 10 CFR 50.55(e) items; headquarters requests; operational safety; maintenance; l
surveillance; plant trips and operational events; systematic appraisal of licensee performance; sustained control room and plant observation; startup test witnessing and observation; independent inspection; and fire protection.
The inspection involved a total of 687 inspector-hours onsite by five NRC inspectors, including 221 inspector-hours onsite during off-shifts.
l-Results: Of the 12 areas inspected, no violations or deviations were i
identified in 10 areas. Within the remaining areas, two violations were I
identified (Paragraph 6 - inadequate procedure and Paragraph 8 - failure to perform technical specification surveillance testing) which, due to plant I
status, were of minor safety significance.
)
,~
jd O
DETAILS f
1.
Persons Contacted
{
q
- F. Agosti, Manager, Nuclear Operations
}
S. Booker, Assistant Maintenance Engineer
- L. Bregni, Compliance Engineer
- J. Conen, Licensing Engineer J. DuBay, Director, Computer Service & Information Systems
)
O. Earle, Supervisor, Licensing R. Eberhardt, Rad-Chem Engineer P. Fessler, Maintenance Engineer "E. Griffing, Assistant Manager, Regulation & Compliance
- W. Jens, Vice-President, Nuclear Operations
- 5. Leach, Director, Nuclear Security J. Leman, Superintendent, Maintenance and Modification Engineer 1
- L. Lessor, Consultant to the Assistant Manager, Nuclear Production
{
- R. Lenart, Assistant Manager, Nuclear Production l
R. Mays, Outage Management Engineer l
- W. Miller, Supervisor, Operational Assurance S. Noetzel, Assistant Manager, Nuclear Engineering J. Nyquist, Supervisor, Independent Safety Engineering Group l
T. O'Keefe. Supervisor, Me:hanical Civil Engineering
- G.Overbeck,AssistantPlantSuperintendent,Startui)
J. Plona, Technical Engineer E. Preston, Operations Engineer W. Ripley, Assistant Operations Engineer - Aditinistrative C. P. Sexauer, Nuclear Production Administrator "G. Trahey, Director, Quality Assurance
- R. Wooley, Acting Supervisor, Licensing
- Denotes those who attended the exit meetings.
The inspectors also interviewed others of the licensee's staff during q
this inspection.
2.
Followup on Inspector Identified Items (92701)
)
a.
(Closed) Open Ites (341/84-07-01(DRP)):
Failure of CR8 Rectifier in i
Energency Diesel Generators (EDGs).
During the 24-hour test of EDG No.12 at 3250 kw, rectifier CR8 overheated.
In earlier tests of EDGs 13 and 14, the same component (CR8) also overheated.
The CRB rectifier protected the EDGs from certain EDG output bus faults.
J The licensee's investigation of the CR8 rectifier failures concluded that the rectifiers were undersized and should be replaced by larger units.
The licensee issued Nonconformance Report No. 84-1199 which calls for the replacement of the present rectifiers with new selenium surge seppressors (rectifiers) which have thirty-two, 6"x8" i
plates each. The inspectors verified completion of replacement by l
review of work orders PN21-991742, 991743, 991744, and 991745 for EDGs 14,13,12, and 11 respectively.
This itas is considered closed.
b.
(Closed) Unresolved Item (341/84-2'0-13(DRP)):
Purchasing inspection report inadequacies.
A Deco source inspection report dated May 27, l
1975, for the Emergency Diesel Generators (EDG) revealed that testing delays were encountered.
A Deco inspector believed the sa1 functions should have been detected during preliminary inspection and functional testing.
Since control malfunctions and termination deficiencies were documented in the May 27, 1975, report, the licensee should have been alerted to the potential for problems.
However, the discrepancies were not identified until Checkout and Initial Operation (CAIO) testing and not during installation.
Therefore, it appeared as though source inspections were not adequate and the findings in the source inspection reports were not followed properly.
To determine if there was a probles, the licensee looked at 1191 (100%) of the Purchase Inspection Reports (PIR) written before July 1981 on QA level I material.
The purpose of the review was to assure that all problems identified in the PIRs were resolved.
After reviewing the PIR, if there was an unresolved "open loop", an investigation was conducted to determine if actions had been taken for closure.
Ris included a documentation search and, if required, physical inspections to verify that work which was to be done had been satisfactorily completed. When it was concluded that an item lacked objective evidence of satisfactory resolution, a Deviation /
Event Report (DER) was issued. Of the 1191 PIRs, 12 DERs were written covering 15 PIRs.
The DEts will provide for adequate resolution of the 15 identified "open loops."
The inspectors reviewed a sample of 10 PIRs that were detemined not to have an "open loop." The results of the review indicated that the licensee's study provided adequate resolution of the concern.
It should also be noted that current QA program implementing procedure prevents recurrence of this problem.
This ites is considered closed.
c.
(0 pen) Open Ites (341/84-49-04(DRS)):
The licensee was requested to reassess each FSAR commitment to the NRC's fire protection criteria and identify all areas of violation, deviation, and exception. By letters dated February 4 and March 4,1985, the licensee submitted information regarding deviations from either previous commitments or from NFPA codes to provide justification and resolution of certain fire protection issues.
By letter dated February 18, 1985, the licensee indicated that. a specific walkdown was to be conducted by a third party knowledgeable in the IFPA codes by June 30, 1985, to identify any potential deviations from the NFPA codes. This walkdown is considered an ites required to be performed prior to exceeding f've percent of full power.
The licensee submitted for e
Region III'information and review, the completed "NFPA Code Compliance Summary Report" dated June 14, 1985, prepared by the licensee's l
consultant.
This suunary report included a review of thirteen NFPA
- t. odes and identified eight deviations with seven of the NFPA codes.
According to the report the identified deviations were dispositioned for corrective action by an appropriate Detroit Edison procedure.
In discussions between the NRR fire protection reviewer and Region III personnel on August 19, 1985, it was determined that I
these deviations need not be submitted to NRR for formal review and I
acceptance.
Since the NFPA code reassessment has been performed I
and only minor deviations were identified, the five percent
]
requirement is considered to have been met.
However, this item will remain open until the corrective actions covering the eight deviations have been completed.
d.
(Closed) Open Itera 341/85014-02(DRS)):
During plant tours, the i
inspectors noted that a Conditional Release (CR) Card No. 83-41 was attached to a relay'inside the switchgear cubicles for RHR service water pumps A and C.
Further review revealed that the Conditional Release had been closed.
The presence of CR tags in the plant for 1
CRs that are actually closed could lead to confusion.
Therefore, the licensee was requested to determine which QA conditional release numbers were still outstanding and ensure those were the only ones j
still attached to their respective components.
)
The licensee corrective action included the issuance of a memo from the Director of Nuclear Quality Assurance (NQA) and the Superintendent of Nuclear Production to the NQA Staff and the Nuclear Production Section Heads concerning the subject of I
Conditional Release Tags.
The meno requests the personnel to assist in the removal of tags associated with closed CRs.
This is to be accomplished in the course of assigned activities by noting the tag number and location of any CR tags observed.
This information is then phoned in to Procurement QA so that a check of the Conditional Release Log can be done to verify that the CR is indeed closed and the equipment is acceptable for use.
Following verification, the tag is then removed and mailed to Procurement QA for filing with the original CR records. The corrective actions provide for the proper handling of CR tags when they are found in the plant.
Implementation of the corrective action will resolve the problem of closed CR tags in time and this item is considered closed.
e.
(closed) License Condition 2.C.9.(e):
Fire Protection.
License l
Condition 2.C.9.(e) required the licensee to complete the installation of all early warning fire detectors, have all fire door assemblies labeled or listed by a nationally recognized testing l
laboratory (unless accepted by NRR), and rehydro the fire protection yard piping prior to exceeding 5% power.
See Inspection Report i
50-341/85025 for additional details concerning this item.
A
'4 (1) Detectors During a walkdown of several fire detection systems for interference from mechanically induced air flows,:the inspectors noted three areas which did not strictly confors to NFPA 72E.
As corrective action, the licensee conducted a study of Fermi 2's fire detection system _ to determine confomance to NFPA 72E and committed to relocate affected existing detectors and install additional detectors to meet the requirements of NFPA 72E.
As a result of the study, 50 existing detectors required relocation and 54 additional detectors had to be added.
The inspectors visually verified the relocation of 16 detectors and the addition of 17 new detectors as per the design i
drawings.
Also, the inspectors reviewed all Surveillance Performance Forms (SPF) to verify proper operation of 100% of the new and relocated fire detectors.
No problems were noted in either area.
The licensee is continuing to update all affected drawings.
License Condition 2.C.9(e) regarding fire detectors has been satisfied.
(2) Fire Doors During a fire protection / safe shutdown capability inspection, the inspectors observed several designated fire doors either not having an Underwriters Laboratories (UL) label identifying the doors' fire resistance capability or the doors had 11/2 hour UL labels affixed instef.d of the required 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistive rating as stated in the FSAR. License Condition l
2.C.9.(e) required the labeling or listing of all fire door assemblies by a nationally recognized testing laboratory prior to exceeding five percent of full power.
The licensee's corrective action included issuing a contract to UL to investigate, evaluate, and fire test where necessary, to assure the doors in question will satisfactorily perform their intended fire protection function. To conform to i
acceptable UL design criteria many fire door assemblies required modifications such as filling screw holes where signs had been removed, adding steel bar stock to the frame, and installation of a sill plate on the floor in the door assembly opening.
Also, thirteen fire doors were replaced with new doors. All UL required modifications were completed for the applicable fire door / frame assemblies with the I
exception of four doors.
These four doors were approved by NRR for exemption.
The inspectors visually verified that all 55 fire doors and their frames were properly labeled by UL. No problems were noted and License Condition 2.C.9(e) regarding fire door assemblies has been satisfied.
e-
)
(3) Hydrostatic Test of the Underground Fire Main As documented in Inspection Report 50-341/84049, a review of pre-operational test results indicated inconsistent pressures and flows recorded for the ten year old underground fire main system hydrostatic test.
The licensee acknowledged the inconsistencies in the test and agreed to retest the system at 200 psig. This was completed on May 31, 1985, - and the measured leakage rate was 253 gallons for two hours.
NRR accepted the licensee's hydrostatic test and License Condition 2.c.9 (e),
regarding the hydrostatic test was satisfied.
Additional details on this issue are contained in Inspection Report 50-311/85025(DRS).
3.
ticensee Action on 10 CFR 50.55(e) Items (92700) a.
'(0 pen) 50.55(e) Item 50-341/84-03-EE (Licensee No.111): " Design Deficiency on the Residual Heat Removal (RHR) Reservoir Freeze Dver." On December 28, 1983, water in the RHR reservoir which a
serves as the ultimate heat sink, froze to a depth of two to three j
inches.
Safety-related Diesel Generator Service Water, Emergency l
Equipment Service Water, and Residual Heat Removal Service Water
{
(RHRSW) deep draft pumps take suction from these reservoirs.
Ice formed around the column of these pumps and had the potential to render the pumps inoperable.
The RHR complex design did not provide an adequate method to prevent freezing of the reservoirs for the period between the end of construction and initial plant operation. The licensee corrective action originally was to run the Emergency Equipment Cooling Water system and/or the Emergency Diesel Generators (EDGs), while the unit is operating, to maintain the water temperature above 43*F.
While the unit is not operating, the decay heat from the reactor l
core would supply adequate heat.
)
After discussions with NRC Region III and NRR staff, the licensee made a decision to use a temporary auxiliary boiler to add any heat necessary to prevent freezing of the RHRSW reservoirs. Therefore, the EDG's would not be operated to provide heat to the reservoirs.
The licensee's compensatory measures were considered adequate for the interia period. However, this ites will remain open pending NRC Buclear Reactor Regulations' (NRR) written response.
b.
(Closed) 50.55(e) Item 50-341/85004-EE (Licensee No.147),
" Additional Fire Dampers Required." By letter dated February 28, 1985, the licensee identified deficiencies in fire barriers betwt.en fire zones in the Auxiliary Building.
The Fire Hazards Analysis
)
drawings identify the walls which are required to be fire barriers but some drawings do not clearly indicate that a floor may also be a I
fire barrier. Therefcre, some HVAC ducts which penetrate floors l
uere not identified as crossing a fire barrier and the required l
dampers were not installed.
The licensee's corrective action j
included:
l
4 A drawing verification, which supplemented the walkdown inspection, of the HVAC duct penetrations, pipe chases, and other unusual fire barrier configurations to detemine if other fire zones required additional barriers.
The installation of six additional HVAC fire dampers and one pipe chase fire barrier.
The expansion or modification of the Fire Hazards Analysis drawings to identify which floors, or parts of a floor, are fire barriers.
The inspectors verified proper installation and operation of the six HVAC. fire dampers and the pipe chase barrier. Also, the inspectors verified that the Fire Hazards Analysis drawings are being revised and expanded to illustrate complete fire zone boundaries including floors, walls, ceiling, chases, and doorways. This item is closed.
4.
Followup on Headquarters Requests (92704) a.
Commissioner Asselstine Tour Commissioner Asselstine, with his technical assistant, the Deputy Regional Administrator and members of his staff, accompanied by senior licensee management and site management toured Femi 2 on July 1, 1985.
The tour was conducted by the Senior Resident Inspector and included individual discussions with licensed operators and members of the shift staff by Commissioner Asselstine.
Commissioner Asselstine met with the resident staff and licensee management prior to and subsequent to the tour, b.
Commission Briefing for the Full Power License l
The Region III Deputy Regional Administrator, the Femi 2 Section Chief, and the Senior Resident Inspector were at headquarters July 8-10, 1985, to assist the NRR staff in their preparation of the presentation for the Femi 2 full power license briefing.
The emphasis of the Region III support focused around the completion of license conditions, plant operational history and the SAFETEAM.
The staff briefed the Commissioners on July 9,1985, regarding the SAFETEAM and its effectiveness. The program's strengths and weaknesses were identified. The findings of the resident, Region III, and NRR/IE inspections were discussed.
The Commission voted on July 10, 1985, to grant Fermi 2 a full power license after being briefed by IE, NRR, and Region III management.
The full power license was issued July 12, 1985.
No violations or deviations were identified in this area.
l-l^
5.
Operational Safety verification (71707) i The inspectors observed control room operations, reviewed applicable logs and conducted discussions 'with control room operators during the pariod from July 1 to September.30,1985.
The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components.
Tours of the j
reactor building and turbine building were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance.
4 During the inspection period the inspectors verified that surveillance i
tests were conducted, containment integrity requirements were met, and l
emergency systems were available as necessary.
The inspectors, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the i
station security plan.
The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls.
During the inspection, the inspectors walked down the accessible portions of the following systems to verify operability by costparing system lineup with plant drawings, as-built configuration or present valve lineup lists; observing equipment conditions that could degrade performance; and
-verified that instrumentation was properly valved, functioning, and calibrated.
High Pressure Coolant Injection Systes The inspectors also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barreling.
On August 27, 1985, the inspector witnessed Radwaste Shipment No.85-007, the l' censee's first radwsste shipment.
This shipment consisted of condensate polisher resins, solidified in concrete with a total activity of approximately 8.5 millit uries. The inspectors observed radiation and contaxiination surveys which were well within the limits established by the Department of Transportation.
These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications,10 CFR, and administrative procedures.
No violations or deviations were identified in this area.
6.
Monthly Maintenance Observation (62703)
Station maintenance activities of safety-related systems and components listed below were observed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, and industry codes or standaids and in conformance with Technical Specifications.
The following items were considered during this review:
the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; the procedures used were adequate to control the activity; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire
' prevention controls were implemented.
Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to' safety related equipment maintenance which may affect system performance.
The following maintenance activities were observed:
EDG-14 Lube Oil Filter and 011' Change Crossover Cable Fire Stop Seal Maintenance The inspectors witnessed the lube oil filter replacement on EDG No.14.
After the filters were removed from the filter housing, there was still approximately an inch of oil in the bottom that had to be cleaned out.
The procedure did not specify the type of material to be used for cleanup and as such the maintenance personnel opted to use paper disposable wipes.
The paper rags promptly dissolved in the oil, thus rendering the EDS systern Division II inoperable due to foreign material contamination of the lube oil system.
10 CFR Appendix B, Criterion V, as implemented by the licensee's procedure QAPR 5, requires that procedures appropriate to the i
circumstances shall be used to control activities affecting quality.
Contrary to the above, the licensee's procedure governing preventive maintenance on the diesel generator was not appropriate in that it failed j
to specify the type of material to be used in cleaning activities l
resulting in the diesel generator being inoperable (341/85037-01).
J In response to the event the licensee issued Deviation / Event Report (DER)
No. NP-85-0392 and hung a Deficiency Notice tag No.1827 on the systas.
Also, Maintenance Instruction MI-M136 " Emergency Diesel Generator -
Preventive Maintenance" was revised to include a caution against using unauthorized materials in the filter housing and specifying cloth rags for cleanup.
The inspector has reviewed the licensee's corrective actions and considers them adequate.
No other violations or deviations trere identified in this area.
1
(
7.
Monthly Surveillance Observation (61726)
The inspectors observed surveillance testing required by technical specifications and verified that: testing was performed in accordance with adequate procedures, test instroentation was calibrated, liatting f
conditions for operation were met, removal and restoration of the 1
9 i
affected components were accomplished, test results conformed with technical specifications-and procedure requirements and were reviewed by personnel other than the individual directing the test, and any deficiencies identified during the testing were properly reviewed and resolved by appropriate' management personnel.
The inspectors witnessed portions of the following test activities:
Start and Load Test - Emergency Diesel Generator (EDG) No.13
-.DG5W and DFOT Pump and Valve Operability Test - (EDG) No.13 Division I Core Spray System Pump and Valve Operability Test High Pressure Coolant Injection Pump Operability and Flow Test at 1000 psig and Valve Operability The inspector observed the performance of the HPCI surveillance and verified that the surveillance was conducted in accordance with an approved procedure (POM 24.202.01).
The purpose of the surveillance was to verify operability after maintenance.
However, the HPCI system was not made operable because the system valve lineup was not performed for an additional two shifts.
Because HPCI had not been made operable, a later shift entered a Technical Specification Limiting Condition of Operation (T.S. 3.0.3) when the Low Pressure Coolant Injection cross-connection valve was shut for a surveillance.
The licensee recognized the condition within approximately 30 minutes and the operator opened the valve per the shift supervisor's direction, thus removing the unit from the LCO.
The HPCI valve lineup was performed and the HPC) system was made operable.
This is another example of the operating shift not being aware of equipment status.
No violations or deviations were identified in this area.
8.
Plant Trips and Followup of Operational Events (93702) a.
Plant Trips Following the plant trips on June 28, July 1, July 5, and July 9, September 3, and September 27, 1985, the inspectors ascertained the status of the reactor and safety systems by observation of control room indicators and discussions with licensee personnel concerning plant parameters, emergency systes status, and reactor coolant chemistry. The inspectors verified the establishment of proper consunications and reviewed corrective actions taken by the licensee.
All systees responded as expected, and the plant was returned to operation for startup testing on June 29, July 2, and July 6, July 10, September 13, and September 28, 1985, respectively.
10
b.
Operational Events On September 9,1985, at 6:00 p.m. the licensee discovered that they failed to perfore the weekly channel functional test for Intermediate Range Monitors (IRMs) B, G, and H within the prescribed time interval.
IRM B became inoperable on September 6, 1985, at 7:30 a.m. due to failure to perform the channel functional test.
IRM G-became inoperable on September 6, 1985, at 12:32 p.m.
and IRM H became inoperable on September 6,1985, at 6:28 p.m. for the same reason.
The licensee was unaware that the IRM surveillance had expired and were, therefore, considered inoperable.
The licensee had the IRM surveillance scheduled but the surveillance were not performed.
They were subsequently completed on September 7,1985.
IRM B functional surveillance was successfully completed at 2:46 a.m.,
IRM G at 1:58 a.m. and IRM H at 5:48 a.m.
As a result of two out of the four IRMs in Division II (IRM B & H) being inoperable, the licensee was in T.S. 3.3.1 action statement and should have placed the trip system in the tripped condition within one hour.
The action statement also required the lic5r see to verify all insertable control rods to be inserted in the core and lock the reactor mode switch in shutdown position within one hour.
Both IRMs were inoperable for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and 18 minutes during which time the plant was in cold shutdown.
The failure to perform the surveillance in a timely manner is l
considered a violation of T.S. 4.3.1.1 (341/85037-02).
9.
Systematic Appraisal of Licensee Performance (990218)
The Systematic Appraisal of Licensee Performance (SALP) was given to the licensee at Fermi on July 2,1985.
The appraisal period for SALP VI, October 1, 1984, through June 30, 1985, was abbreviated in order that i
an appraisal be made prior to the issuance of the full power license.
The Deputy Regional Administrator and members of his staff made the presentation to senior licensee management with public attendance. The I
licensee's overall performance was average with above average performance j
in three functional areas and below average performance in one functional area. The SALP is documented in Inspection Report 50-341/85027.
10.
Sustained Control Room and Plant Observation (71715)
The licensee restarted the reactor on August 10, 1985, after being in an outage since July 23, 1985.
The reactor was shut down after the South Reactor Feed Pump turbine failed. The inspectors increased their coverage of control room activities such that control room activities were monitored on a three shift basis August 9-15, 1985.
The resident effort was supplemented by a Region III inspector commencing August 12, 1985. The inspection focused on all aspects of control room activity such as briefings and turnovers, log keeping, communications, operator response, and administrative controls.
1 C_____________
9 t
The inspectors identified several weaknesses and observed conditions which had been previously identified.
The most significant items were:
~ The tagging system was weak.
The plant status system was inadequate.
The work order system was weak.
Preventative maintenance must have a higher priority.
- The number of open work orders was excessive.
The operating crews needed to function as a team.
j l
The inspectors met with licensee management to discuss their concerns.
The licensee's response to these concerns was addressed in their September 10, 1985, presentation in Region III.
No violations or deviations were identified in this area.
11.
Startup Test Witnessing and Observation (72302)
The inspectors reviewed portions of startup test procedures, reviewed procedure results completed to date, toured the areas containing system equipment, interviewed personnel, and observed test activities of those startup tests identified below.
During this review, the inspectors noted that the latest revision of the test procedure was available and in use by crew members, the minimum crew requirements were met, the test prerequisites were met, appropriate plant systems were in service, the special test equipment required by the procedure was calibrated and in service, the test was performed as i
required by approved procedures, temporary modifications such as jumpers
{
were installed and tracked per established administrative controls, and test results for the tests observed by the inspectors indicated that acceptance criteria were met.
a.
Scram Time Testing
)
The inspectors observed the performance of portions of STUT.HUC.005, I
Revision 2, " Control Rod Drive System - Scram Timing":
Insertion j
time testing of Sequence A and Sequence B control rods at 600 psig, 800 psig, and 950 psig (rated pressure).
]
b.
Insert / Withdrawal Timing and Friction Testing i
The inspectors observed the performance of portions of STUT.HUA.005, j
Revision 2, " Control Rod Drive Systee - InsertNithdrawal Timing" l
and STUT. HUB.005, Revision 2, " Control Rod Drive System - Friction Testing." These tests were performed at rated pressure (950 psig) during initial heatup.
No violatiens or deviations were identified in this area.
l l
l w
1 I
l 12.
Independent Inspection (92706) a.
Valve Accessibility License Condition Attachment 1 B.I.a. required the licensee to l
provide accessibility to safety-related valves for manual operation.
Compensatory measures were subsequently implemented and the item was closed. The corrective action included placing portable stands, air hoists, and ladders in strategic locations. These accessibility aids were to be locked in their established storage areas and all operators would have keys and be briefed on the operation and locations of these devices.
It was believed that since only operators have the correct key to unlock these devices, adequate control would be maintained providing the operators properly returned the devices after use.
However, the inspectors have identified several instances of air hoists and ladders missing from their storage location.
Af ter further investigation it is believed that Operations may be unlocking the devices for use by other departments, using the devices themselves and not returning them to the storage area, and there may also be keys held by unauthorized personnel. This is an open item (50-341/85037-03(DRP)) pending review of licensee corrective action for maintaining control of valve accessibility aids.
b.
Open PN-21s (Work Orders)
The licensee has consistently had a large number of open PN-21s (Work Orders) in the control room.
There were 423 open orders as of June 30, 1985, and the number peaked to 481 on July 28, 1985.
The inspectors consider that the magnitude of open PN-21s contributed to some of the recent problems such as the status of equipment.
The inspectors also consider the number of the open PN-21s to be unacceptable.
The inspectors have observed several PN-21s that were still open three sonths after the work had been completed.
The inspectors brought their concerns to the licensee who took corrective action by making a concertive effort to complete the required actions and to closeout the PN-21s.
The licensee had 345 open PN-21s on September 29, 1985, and work had been completed on 198 of these.
This results in 147 actual open PN-21s.
The licensee's goal is to have a maximum of 120 active PN-21s with half being preventative maintenance items.
The licensee is including the control of open PN-21s in their Operations Improvement Program.
The inspectors believe that the licensee must make the effort to successfully control the number of open PN-21s in order to reduce the probability of equipment status problems.
(
13 i
1 c.
Temporary Solid Radiowaste System The Safe Energy Coalition (SECO) requested additional information concerning the temporary NUS solid radiowaste equipment to be used at Fersi from the Director of NRR at the February 20, 1985, meeting held at Fermi (Inspection Report 50-341/85013).
The NUS process is considered to be proprietary and SECO was told that they could not review the information and NRR would review the process for effectiveness.
Subsequent to this meeting, SECO and NRR came to an agreement that members of SECO could review the NUS submittal in the presence of the Senior Resident Inspector (SRI) provided that those who reviewed the document sign a nondisclosure agreement.
The NUS document was sent to the resident office on April 18, 1985, and SECO was notified that it could be reviewed at Fermi 2.
SECO made arrangements with the SRI to view the documents at 1:00 p.m. on July 2,1985.
Four members of SECO reviewed the documents in the presence of the SRI on July 2,1985.
SECO requested that the SRI retain the documents as other members of SECO wanted to review the documents.
The resident office had no other communication with SECO regarding the NUS documents and returned them to NRR on July 29, 1985.
d.
Turbine Roll The licensee successfully rolled the main turbine to synchronous speed (1800 rpm) on September 30, 1985.
Both inspectors were in the control room during the event.
No significant problems were revealed during the run.
e.
SAFETEAM This inspection into the SAFETEAM activities is a result of concerns raised during the licensing process of another utility.
This inspection is a followup of an initial inspection documented in Inspection Report 50-341/85029(DRP).
The inspectors reviewed the SAFETEAM findings to detersir.e if investigative effort adequately addressed the concern and if correcthe action had been completed.
At the same time, the licensee perfomed an independent inspection of the SAFETEAM findings to verify adequacy of investigation and corrective action.
Through discussions with the licensee, the licensee agreed to review fifty percent of the hardware and software safe 5 /-related concerns.
The inspectors reviewed a sampling of the remaining fifty percent of the safety related concerns.
The inspectors reviewed over 10% of the total hardware and software safety-related concerns identified to the SAFETEAM.
During the inspection, DECO expanded their review to include additional concerns, resulting in the licensee looking into approximately 67% of the safety-related concerns and over 50% of the non-safety related hardware concerns.
As a result of the 14
l
{
i additional inspections, there was an overlap between the Deco review i
and that performed by the NRC resulting in approximately 85% of the concerns reviewed and inspected by the NRC being previously reviewed j
l by Deco.
The inspection identified some problems in the system which are believed to be isolated examples and programmatic in nature.
They included the following:
Inadequate interviews (unable to channel the problem; vague generic concerns)
Packages did not address the whole concern Packages incomplete (inadequate documentation)
Packages should have been provided with additional closure information (i.e. 50.55(e)'s, NRC Inspection Reports, Duke Inspection Reports, Deco Reports)
Investigators unable to receive engineering support Although some flaws were identified in the SMETEAM, an overall good effort went into the SAFETEAM project.
With the supplemented and augmented inspection effort by both DECO and the NRC, we were able to reach the same conclusions, although the inspectors found it difficult for the SAFETEAM to reach their conclusions on some concerns based upon the originally available documentation in the packages.
Overall the inspectors believe the packages were complete and well documented and the concerns were adequately addressed.
The licensee has since committed to improve the weaknesses identified in the NRC and Deco inspections.
The results of this inspection and Deco inspection were provided to NRC Region 111 and were used as the basis for regional input to the Cossission briefing on July 9,1985.
See paragraph 4.b. for additional information on the Commission briefing.
f.
Bypass Crack Piping The licensee observed leakage in the East Stear Bypass line on September 17, 1985, while operating at 4.1%.
The licensee removed insulation and observed cracks in the 30-inch bypass line and cracks in har.ger retainer and lug welds. Damage appeared to be restricted to locations to which hangers or snubbers were attached.
Subsequent investigation by the licensee revealed similar occurrences in the West Steam Bypass Line.
Licensee actions are being monitored by Region 111 specialists and additional information will be documented in a subsequent inspection report.
No violations or deviations were identified in this area.
l L
15
1 L
13.
Fire Protection (64704)
License Condition 2.C.9.(e):
Inspection Report 50-341/85025, Paragraph 4.a., License Condition 2.C.9(e), " Detectors", last pragraph, stated, in part, "The fire detector study will be docketed....
The word
" docketed" should be changed to " approved by management." The.. licensee indicated that the word " official" as used in the telephone conversation on July 3,1985, was not intended to imply " docketed" but " approved by management".
No violations or deviations were identified in this area.
14.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both.
Open items disclosed during the inspection are discussed in Paragraphs 2 and 12.
15.
Exit Interview (30703).
The inspectors met with licensee representatives (denoted in Paragraph 1) on July 29, September 30, 1985, and informally throughout the inspection period and summarized the scope and findings of the inspection activities.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents / processes as proprietary.
The licensee acknowledged the findings of the inspection.
1 16
/," su,,\\ -
uwitto sitats
(
NUCLE AR REGULATORY COMM!$$lON
[s nacioN sei j
l ne moosevett moao eten ettv=, stuwois sot a -
JUL 29 $85 l
1 i
Docket No. 50-341 The Detroit Edison Company ATTN: Wayne H. Jens Vice President Nuclear Operations 6400 North Dixie Highway Newport, M1 48166-Gentlemen:
This refers to the routine safety inspection conducted by Hessrs. P. M. Byron, M. E. Parker, D. C. Jones, and R. A. Paul of this of fice on June 1-30, 1985, of activities. at Termi 2 authorized by Tacility Operating License No. NPF-33 and to the discussion of our findings with R. S. Lenart at the conclusion of the inspection.
Tne enclosed copy of our inspection report identifies areas en mined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
No violations with NRC requirements were identified during the course of this inspection.
Although no violations of NRC requirements were identified during this inspection, we do request that you respond to the unresolved item identified in the enclosed report. This item is related to your maintenance activities and specifically involves the failure to follow procedures during Reactor Water Cleanup pump "A maintenance.
We believe this issue is significant and warrants particular attention.
Your response is requested within thirty days of receipt of this letter.
Additionally, we request that you respond to the unresolved item concerning the program developed to address the serviceability of safety-related valves.
Your response on this issue is also requested within thirty days of receipt of this letter.
In accordance with 10 CTR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
The Detroit Edison Company 2
We will gladly discuss any questions you have concerning this inspection.
Sincerely, h0d$I9ME b[E.$.~$1'[6SEdh%
Charles E. Norelius, Director Division of Reactor Projects
Enclosure:
Inspection Report No. 50-343/85029(DRP) cc w/ enclosure:
L. P. fregni, Licensing Engineer P. A. Marquardt, Corporate Legal Department DMB/ Document Control Desk (RIDS)
Res ider.t Inspector, RIII Rer:a:d Ca:ler., Michigan Public Service Commission Harry F..
Voigt, Esq.
Nuclear Tacilities and Environmental Monitoring Section i
h8gd,rr Aotmos N.,es,usik 07/24/65
4 l
U. 5. NUCLEAR REGULATORY. COMISSION l
REGION III l
Report No. 50-341/85029(DRP)
Docket No. 50-341 Operating License No. NPF-33 Licensee: Detroit' Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name:
Termi 2 Inspection At:
Termi Site, Newport, MI j
l
. Inspection Conducted: June 1-30, 1985 j
l Inspectors:
P. M. Byron j
I M. E. Parker D. C. Jcnes l
R. A. Paul l
i Approved by:
G.
3 C ief
/d Projects Section 2C Date i
Inspeetion Summary Inspection on June 1-30,1985, (Report No. 50-341/85029(DRP))
Areas Inspected: Routine, unannounced inspection by resident inspectors of licensee action on previous inspector identified items; independent inspection; maintenance; surveillance; operational safety - ESP system walkdown; fire prevention / protection prog' ram implementation; allegations, management meetings, SALP, and initial critic 611ty. The inspection involved a total of 323
- inspector-hours onsite by four NRC inspectors, including 82 inspector-hours onsite during off-shifts.
Results: Five open items, three license condition attachments (one of which l
was also an open item), and one noncompliance were closed. 'nto unresolved and one open ites resulted from this inspection. Within the areas inspected, no violations, deviations, or significant safety issues were identified.
1 p.--
4 DETAILS 1.
Persons Contacted
- F. Agosti, Manager, Nuclear Operations
- L. Bregni, Licensing Engineer J. DuBay Director, Planning and Control
- 0. Earle, Supervisor, Licensing R. Eberhardt, Rad-Chem Engineer P. Fessler, Assistant Maintenance Engineer
- E. Griffing, Assistant Manager, Nuclear Operations W. Jens,. Vice-President, Nuclear Operations W Kaczor, Director, SAFETEAM, (Deco)
R. Kunkle, Director, SAFETEAM (UTS)
S. Leach, Director, Nuclear Security
)
J. Leman, Maintenance Engineer L. Lessor, Advisor to the superintendent, Nuclear Production
- R. Lenart, Superintendent, Nuclear Production R. Mays Director, Project Planning
- W. Miller, QA Supervisor, Operational Assurance S. Noetzel, Site Manager J. Nyquist, Assistant to Superintendent, Nuclear Production G. Overbeck, Assistant Plant Superintendent J. Plone, Technical Engineer E. Preston, Operations Engineer W. Ripley, Startup Director C. P. Sexauer, Nuclear Production Administrator G. Trahey, Director, Nuclear QA
- Denotes those who attended the exit meetings.
I The inspectors also interviewed others of the licensee's staff during this inspection.
2.
Tollowup on Inspector Identified Items (Closed) Open Item (341/84043-06(DR55)), and License Condition
- a. B.2.b:
Fabricate and install an intrinsic gennanium detector system post-accident collimator prior to exceedir.g five percent power.
The licensee fabricated several lead shield collimators for accident condition use with the detector system, and a calibration was perfonned for use with a multi-channel analyzer.
The licensee demonstrated the use of the collimators for the inspectors.
The inspectors also reviewed selected sections of Radiological Engineering Report No. 85-02, " Calibration of High t
Purity Gennanium Detector for Use with Lead Pollinators to Analyze High activity Post-Accident Samples."
[
l i
1 9
b.
(Closed) Open Itam (341/84039-01(DRP)), and License Condition, 3.1.a: Accessibility of safety-related valves for serviceability and manual operation. This item identified numerous inaccessible safety-related valves that would require ladders or platforms to operate, inspect, and maintain the valves.
(1)
Concerning the manual operation of safety-related valvas, the licensee conducted a program that reviewed 217 safety-related valves for accessibility. Of the 217 valves, 69 or 32 percent required some form of accessibility aid. The resultr of this accessibility program are as follows:
g Temporary scaffolding and ladders have been installed in several cases which will provide an interim resolutio:
until permanent design changes can be implemented.
Portable stands, air hoists, and rolling pistforms beve been chained and locked in strategic locations for the other cases, which will provide a more permanent accessi-bility. All operators have a key to the locks and here been briefed on the operation and the locations of these devices.
(2)
Although the accessibility of safety-related valves for operation was the pricary issue of concern, the licensee has developed a program which will address the issue of serviceability. The program will consider the same 217 safety-related valves as the operability program, but froe a maintenance perspective. This will be accomplished through the Engineering Evaluation Request (EER) process which shall provide an evaluation and design for the permanent installation of serviceability aids.
This item requires further review and evaluation and is considered an unresolved item (341/85029-01(DRP)) pending completion of the serviceability program and subsequent NRC inspection.
The Ifeensee has demonstrated adequate accessibility to all con-cerned safety-related velves.
This satisfies the license condition for criticality and this item is considered closed.
c.
(Closed) Open Item (341/84043-05(DRSS)):
Complete Installation cf Standby Gas Treatment System (SGTS) sample line beat tracing prior to exceeding five percent power. The heat tracing has been installed, and the functional tests have been completed and reviewed. The inspectors verified the installation of the best
- tracing, i
3
J b
d.
(Closed)~ Open Ites (341/84043-10(DRSS)), and License Condition
., 8.2.c:
Complete a comprehensive review of technic'al._
adequacy, commitment compliance, necessary corrective actions and
~
associated training for the accident radioactive effluent ralease
~
quantification program prior to' exceeding five percent power. 'Ihe licensee has. completed-the comprehensive review of technical adequacy and commitment compliance.and taken corrective. action by revising certain emergency response and plant procedures. These actions are described in a licensee internal document entitled." Accident Radio-active Release Quantification.*rogram, which' the inspectors resiewed.
Also completed are the approval of revised procedures and the training of personnel on these revised procedures.
e.
(Closed) Open item -(341/85010-02(DRP)): Verification'of the prc<per operation of 24 single coil Target Rock solenoid valves.
The 24 single coil Target Rock valves consist 'of 16 valves in the Post
' Accident Sampling System, and 8 valves in the MSIV Leakage Control Systee. Preoperational_ Test Precedure PRIT.P3323.001, " Post
. Accident Sampling System," included proper operation verification for 14 of the valves.
Plant Operations Manual (POM) Surveillance Procedure 24.127.20, "MSIV Leakage Contr21 System Local Valve i
Position Indication Verification Test," included proper operation verification for eight of the valves.
POM Surveillance Procedure 43.40).3E3, " Local Leakage Rate Testing For Penetration X-215,"
included proper operation verification for tre of the valves.
All sing:e ceil Target Rock solencid valves operned properly. This ites is considered closed.
f.
(Closed) Noncompliance (341/65021-01(DRP)): Inadequate implementa-tion and review of Engineering Design Package EDP-1996 and the accompany-ins Engineering Change Requests (ECR's) used to verify installation of test, vent, and drain connection caps. This resulted in:
(a) the EDP verification sheet not' adequately reflecting the EDP and its accompanying ECR's, (b). not: all test, vent,' and drain (TVD) caps being installed, and (c) Plant Operations Manual (POM) Procedure 47.000.77, " Test, Vent, and i
Drain ('IVD) Cap and Plug Verification," omitting a penetration (X-220)
J which consists of eight 'JVD caps. The following licensee corrective action was faplemented:
(1) The EDP verification sheet was corrected to incorporate all revisions to EDP-1996 and the walkdown was reperformed.
- Also, the EDP Implementation Plan was revised as required by POM l
Procedure 12.000.64, "EDP leptementation." The individual who incorrectly implemented this procedure was instructed to read the procedure again and fully acquaint himself with all of its l
requirements.
l:
I 4
(2)
Completion of_PN-21 No. 992725 and.the revised verification
- walkdown documents that all caps are now installed in accordance with EDP 1996 and ECR's 1996-1 and 1996-2.. Surveillance Pro-cedure 47.000.77 bas been issued to administratively control the subject caps. -Also, all associated plant drawings will be updated in accordance with proper procedure to reflect as-built conditions.
(3) The preparer and the technical reviewer reanalyzed all informa-tion used to generate Procedure 47.000.77 auui corrected the procedural deficiency.. They were then instructed by their immediate supervisors of the importance of checking and auditing large amounts of technical data systematically and logically to preclude recurrence of this type of error.
The licensee has ' guidelines to follow in writing procedures which.
are used to ensure correct technical and work content. The individual was also instru:ted to acquaint himself with all the requirements of this procedure.
The plant drawings shall be updated to reflect.the as-built condition of the TVD connection caps by November 30, 1985.
This ites is con-sidered closed.
g.
(Closed) License Condition 2.c.(12): Operability of the permanent liquid radwaste treatment syste: prior to exceeding five percer.t power. The licensee has completed the preoperational tests and demonstrated that the system is operable. The systes has been turned over to operations. Several test exceptions which do not affect the operability of the system remain open.
A selected review.
of preoperational test results (G1120.001 and G1125.001) was made by the inspectors.
In addition the inspectors walked down several sections of.the liquid radweste system.
h.
(Closed) License Condition 2.c.(16): Operability of the Post-Accident Sampling System (PASS). TMI Action item 11.3.3.
The SER, Supplement No. 5 dated March 1985, states that the applicant must demonstrate the capability of promptly obtaining a reactor water coolant saeple in the case of an accident, and that the PASS meets all the requirements of Task Action Item 11.B.3 and is therefore acceptable. Since the SER was written, the licensee has:
demonstrated the PASS operable; approved PO.M procedure 78.000.14 which provides detailed instructions Yor the collection and analysis of samples obtained by the PASS; provided training in the required procedures; and performed a time and motion study to demonstrate that PASS samples can be collected, transported, and analysed in accordance with NUREG 0737, Regulatory Guide 1.97, and GDC-19 dose criteria.
Selected review of the procedures, training records, and the time and motion study was made by the inspectors.
5
3.
Independent Inspection a.
Temporary solid Redweste System The licensee intends to use a portable solid radvaste treatment system (HTS) to meet their technical specification requirements until the completion of the preoperational tests and final approval of the permanent solidification system. The syste.s, which is located in the radwasta building, is operable and vill be used by HTS contractor personnel in accordance with approved licensee procedures. The licensee tested the portable syster by solidifying 86 cubic feet of mixed bed bead resin froe floor drain and waste collector tanks to verify the system met the licensee acceptance criteria.
Selected results of these tests were reviewed by the inspectors; no problems were noted. The inspectors also:
discussed the results of a licensee conducted AIARA review of the temporary system with radwaste personnel; walked down the system to verify installation; and observed selected components to identify potential radiological problen, areas. No significant problees were identified.
In a letter tc the Ideensee from the NRC dated July 3,1985, NRR approved the licensee Process Control Program (PCP) for the temporary radwaste system.
Based on the acceptance of the PCP, the-demonstration test of the system, and the inspector's review of the systee, it appears the portable systee vill functier. as described in the vendor's topical report (HTS Top 2 cal Report PS-53-00378) which s
was submitted to the NRC by the licer:see.
No violations or deviations were identified in the review of this program area.
b.
Onsite Storage Facility (OSST)
The licensee's onsite storage facility is described in Section 11B.1 of the TSAR. The facility is intended to provide interim storage capacity for an amount of waste which could be generated in five years of plant operation.
During this inspection, and a previous inspection (Report No. 50-341/85017(DRSS)), tours and discussions concerning the OSST were made. The tours were made to verify that selected systems and components (including area radiation and effluent monitors) were installed in accordance with the TSAR and to identify any potential radiological probles areas. No problems were noted.
During these tours and discussions with the licensee, special atten-tion was given to the handling, decontamination, smearing, and surveying of dry active and solidified waste drums; to the HVAC 6
system; to the design features to ensure A1 ARA; and to the portable solid radweste system located in the truck bay area of the OSSF.
Radiation protection features of the OSSF include:
protective barriers around the stored waste to prevent uncontrolled releases to the environment, remote handling of the vaste drums, routing of all potentially contaminated drains froe the OSSF to plant liquid radweste system (the licensee verified each floor drain from the
' OSSF is routed to the liquid radweste systes), and monitoring and filtration of gaseous and particulate effluents.
One AIARA problem was noted in that no shielding had been provided in the radwaste barrel readout area, nor had provisicas been made to read out the barrels remotely. The licensee stated they would review the read out system and make improvements where feasible.
This program ares requires further review and evaluation and is considered an open Aten, (50-341/85029-02(DRP))
i No violations or deviations were identified in the review of this program area.
c.
SATETEAM The Office of Investigation (OI) reviewed the investigative results of SATETEAM concerns based on issues raised during the licensing process of another utility.
June 11-13, 1965, 01 investigators reviewed the SATITE/J: investigators' p6deges for those concerns which had been identified as wrongdoing. The wrongdoing concerns had been forwarded to Region Ill as they had been identified.
OI investigators expanded the scope of their review when they returned June 18-20, 1985, to include the completed investigative. packages of those concerns which the investigators deemed as potential wrongdoing based on the description listed in the SATETEAM computer printout.
The review included listening to the tapes, reading the transcription, and reviewing the documentation in the packages.
The Director of 01, members of his staff, and h1R attended a briefing at the site on June 19, 1985, by the licensee and the 01 investigators.
f As a result of the 01 concerns, a task force composed of individuals 4
froc NRR, IEE, and Region III were at the site June 27 and 28,1985, to perform a more detailed investigation of SAFETEAM concerns for technical merit and a comparison of the SATETEAM effort with that of a similar undertaking by another utility.
The inspectors supported the 01 and task force efforts.
In conjunction with this effort, the inspectors and the licensee performed an inspection of the safety-related SAFETEAM findings at the request of Eigion III. The inspectors reviewed the SAFE 1EAM findings to dettraine if investigative effort adequstely addressed the concern and if the corrective action had been completed.
7
Also, the licensee performed an independent inspection of the SATETEAM findings to verify adequacy of investigation and corrective action. Through discussions with the licensee, the licansee agreed to review fifty percent of the hardware and software safety-related The inspectors reviewed a sampling of the remaining fif ty concerns.
percent of the safety-related concerns.
The results of these inspections will be documented in Inspection Report 50-341/85037.
No violations,or deviations were identified in the review of this program area.
d.
Operational Readiness The licensee continues to make progress in its preparations for power ascension. Fire detector installation, fire door inspection, and the off gas system appear to be the most significant critical path items.
Senior Region 111 management met with licensee management twice during the inspection period to review the status of items affecting initial criticality and power ascension, Ifcense conditions and other areas of mutual interest.
No violations or deviationt were identified in the review of this prograz erea.
e.
Independent Operational Readiness Assessment Inspection A Region 111 team coeposed of experienced resident inspectors per-formed an operational readiness inspection at Fermi 2 during June 17-22, 1985. The purpore of the team inspection was to observe the licensee's operations and review procedures to identify strengths and weaknesses. The team conc 19ded that there were no significant weaknesses observed and the plant was ready for power ascension.
This inspection is documented in Inspection Report 50-341/85031(DRP).
No violations or deviations were identified in the review of this program area.
4.
Fire Prevention / Protection Program Implementation The inspectors observed the progress of License Condition 9.e. which requires that prior to exceeding five percent power, all early warning fire detectors shall be installed and all fire door assemblies shall be labeled or listed by a national ~iy recognized testing laboratory. The inspectors additionally performed a more detailed examination of the corrective action by the licensee on a sample basis to determine if the programmatic requirements were being met.
l l
No violations or deviations were identified in the review of this program area.
8
5.
Monthly Maintenance Observatip3 Station maintenance activities of safety-related systems and components listed below were observed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, and industry codes or standards and in conformance with Techr.ical Specifications.
The following items were considered during this review:
the limiting conditions for operation were met while components or systems were removed froc service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; the procedures used were adequate to control the activity; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemented.
The following maintenance activity was observed:
Reactor n'ater Cleanup (RVCU) Recirculation Pump Rotating Assembly-Removal and Installation Removal of RWCU recirculation pump "A" rotating assembly was performed to replace seals and the impe'ller.
Plant Operations Manual (POM)
Maint enance Procedure 35.000.66, Revisjor. 1 dated Tebruary 21, 1979, "RWCL Recirculation Pump Rotating Assembly-Removal and Installation,"
was used to provide detailed instructions for removal, disassembly, inspection, assembly, and installation of the RVCU pump.
The inspectors witnessed portions of this maintenance and identified several areas of concern.
a.
Sections 7.1.4.1 through 7.1.4.4 of Procedure 35.000.68 describe the steps used in draining the bearing housing oil.
This was to be done prior to the removal of the back pull-out section of the pump.
Bowever, this was not done, resulting in the oil draining out onto the floor during transfer to the rolling cart, and oil draining out onto the rolling cart which, in turn, tracked the oil as it was rolled to the workshop.
b.
Eections 1.1.7 and 7.1.8 and Reference 3.30 (POM Procedure 32,000.06, " Rigging") of Procedure 35.000.65 provide instructions for the use of a chain hoist and suitable sling. The hoist and sling are used to support the back pull-out when the casing stud nuts are removed and to facilitate sinplified removal of the back pull-out section. However, the maintenance personnel transferred the back pull-out sect.fon to the rolling cart by hand. This resulted in three men lifting and carrying the heavy and awkward pump to the cart with oil draining significantly (see preceding paragraph). Also, Procedure 35.000.68 requires that reference 3.10, l
PON Procedure 32.000.06 " Rigging," is to be "used".
Sectio;a 3.0, l
" Rigging Preplanning," of this procedure states "... determine the weight of the load." The inspectors observed that the licensee did not observe this requirement of the procedure.
9
l i
c.
The note on page 3 of Procedure 35.000.68 states, " Procedure steps I
may be performed out of sequence with the prior approval of the Deco Maintenance Foreman (as a minimum). This statement is applicable until fuel load." However, section 7.5.11 which states..
"to refill the bearing house with Shell Vitrea Oil," was performed af ter Sections 7.5.12 and 7.5.13.
Therefore, the procedure was performed out of sequence which is a failure to adhere to procedural requirements.
d.
There is no procedural step requiring the removal of the casing studs. Removal of the back pull-out section is obstructed by the casing studs and might cause damage to the studs, the pump shaft, the motor sheft, or the coupling hubs. This item has been discussed with the licensee.
e.
There are two alignment screws on the pump that are used to slign the pump shaft with the motor shaft. These screws, once the pump is properly aligned, are maintained in their proper positions during operation by tightening dowr. the nut on each screw.
However, the inspector observed that this had not been done and subsequently requested the maintenance personnel resolve the problem.
In a discussion with the System Engineer and the Assistant Maintenance Engineer it was concluded that the vibration during operation could have shif ted the alignment of the pump and, in turn, possibly caused damage to the pump.
f.
The RWCU pumps receive reactor water at a temperature of up to 575' F.
This high temperature on the pump side may present a coupling alignment problee due to thermal expansion. This issue is not addressed in the coupling alignment section of Procedure 35.000.68. The licensee is performing an analysis that shall resolve this issue.
The inspector will perform. additional inspection of this program area to determine if there is a widespread probles. This shall be accomplished by further inspection of the adequacy of the licensee's maintenance supervision and performance of maintenance activities.
The above concerns in this program area are considered to be an unresolved itee (341/85029-03(DRP)) pending further evaluation as to whether these items are isolated cases are are more widespread.
6.
Monthly Surveillance Observation The inspectors observed surveillance testing required by technical speci-fications and verified that:
testing was performed in accordance with adequate Trocedares, test instrumentation was calibrated, limiting condi-tions for operation were met, reeval and restoration of the affected components were accomplished, test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and any deficiencies identi-fled during the testing were properly reviewed and resolved by appropriate management personnel.
10
.?
The-inspectors also witnessed portions of the following test activities:
Local'Imakage Rate Testing for Penetration X-13A RHR Pressure Isolation Valve Leakage Test Incal I4akage Rate Testing for Penetration 135B,C,D,E,F No violations or deviations were identified in the review of this program area.
7.
Operational Safety Verification The inspectors observed control room operations, reviewed applicable logs, and conducted discussions with control roce operators during the period froc June 1 to June 30.-1985.
The inspectors verified the operability of selected emergency systems, reviewed tagout records, and verified proper return to service of affected components.
Tours of the reactor building and~ turbine building were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance.
l During the inspection period the inspectors verified that surveillance tests were conducted, containment integrity requirements were met, and emergency systees were available as necessary.
The inspectors, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the station security plan.
The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the inspection, the inspectors walked down the accessible portions of the Iow Pressure Coolant Injection System and Core Spray System to verify operability by comparing system lineup with plant drawings, as-built configuration or present valve lineup lists; observed equipment condi-tions that could degrade performance; and verified that instrumentation was properly valved, functioning, and calibrated.
These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CTR, and administrative procedures.
No violations or deviations were identified in the review of this program area.
8.
Alleastion An anonymous allegation was made to Region III stating that frequent door checks by security personnel increase the potential for radiation exposure and therefore are contrary to ALARA guidelines.
i 11
-___.______-__-_-______-__--a
l l
This allegation was discussed with licensee personnel, who walked down euch vital ares door which is routinely checked by security personnel.
The results of the licensee's review indicated that of all vital area doors which are routinely checked by security personnel, only one is located in a potential radiation area (between the auxiliary and off gas buildings), and none are located in high radiation areas.
Entries into areas posted and controlled as radiation areas are routine and are not normally cause for significant ALARA concerns. No significant AIARA concern was identified in this case.
This allegation was not substantiated.
No violations or deviations were identified in the review of this program area.
9 Systematic Assessment of Licensee Performance (SALP)
A mid-term SALP was performed prior to the Commission briefing for the full power license. The assessment period was from October 1,1964, to June 30,1985. Major activities which occurred during the assessment period were the completion of preoperational testing, initial fueling and initial criticality. The SALP Board met on June 28, 1985, to review the assessments, rate each functional area, and make recommendations as to both licensee and NRC attention. The cid-term SALP will be presented on July 2,1985, at Newport, Michigan, and documented in inspection Report 50-341/85027.
No violations or deviations were identified in review of this progras area.
10.
Initial criticality The licer.see achieved initial criticality on June 21, 1985, at 5:19 a.m.
EDT. The event was witnessed by the Deputy Regional Administrator -
Region Ill, the assigned Section Chief, and a regional inspector in addition to the Senior Resident Inspector. Criticality was achieved within two steps of the predicted step of the rod pull sequence.
Additional details of this event are documented in Inspection Report 50-341/85036(DRS).
No violations or deviations were identified in review of this program
- area,
- 11. Management Meetings i
)
A management meeting was held at Region III on June 14, 1985, at the request of the licensee. The licensee discussed their proposed reorganization of Nuclear Operations. The current organization is I
considered to be structurally flat in that all organizations, with the exception of Quality Assurance, report directly to the Manager of Nuclear Operations. The licensee determined that the current organizational i
12
{
I' structure was unwieldy to manage and has proposed a more streamlined organization. The new organization has been segregated into four functional groups, Plant, Engineering, Services, and Regulation and compliance, all reporting to the Manager of Nuclear Operations. This should result in a more manageable and responsive organization.
In addition, the new organization incorporates " institutional memory" in the i
l proposed staffing.
The licensee plans to implement the new organization after the issuance of the full power license.
- 12. Unresolved Items Unresolvef items are satters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations. Unresolved items disclosed during the inspection are discussed in Paragraphs 2.b.(2). and 5.
13.
Open 1ters Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the h7C or licensee or both. An open item disclosed during the inspectior. is discussed in Paragraph 3.b.
14.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) on June 24, 1985, and inforreally throughout the inspection period and summarized the scope and findings of the inspection activities. The inspector also discussed the likely informational content of the inspectico report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietary. The licensee acknowledged the findings of the inspection.
l
)
t I
13
. /'ps u eg'o, -
UNITED STATES 8
l y,.j..
i NUCLEAR REGULATORY COMMISSION l
-l wassiwotow.o c.20sss
\\;..../
l June 29, 1987 Docket No. 50-341 L
i
]
Ms. Billie P. Garde. Director GAP Midwest Office 1555 Connecticut Avenue, N.W.
Suite 200 1
Washington, D.C.
20036 i
l
Dear Ms. Garde:
j This letter is to acknowledge receipt of your Petition dated May 7,1987, on
)
behalf of the Safe Energy Coalition of Michigan and the Sisters, Servants of-the Immaculate Heart of Mary Congregation.
Your petition sets forth several requests concerning alleged deficiencies of the SAFETEAM program established at Detroit Edison Company's Fermi-2 Nuclear Power Plant. As bases for the j
requested relief, you assert (1) that workers who turned over allegations to l
SAFETEAM were harassed, fired or otherwise discriminated against, (2) that the SAFETEAM was not being properly implemented and was ineffective, (3) that
(
SAFETEAM interviewers are inadequately trained, (4) that deficiencies reported to SAFETEAM are not recorded on non-conformance reports and are not evaluated by the _ site quality assurance / quality control staff, and (5) that there is no
, quality check or accountability for the SAFETEAM prograr.
Your Petition has been referred to the Staff for action pursuant to 10 CFR $2.206 of the Commission's regulations.
As provided by Section 2.206, action will be taken on your request within a reasonable time.
I have enclosed for your information a copy of the notice that is being filed with the Office of the Federal Register for publication.
Sincerely.
Thomas E. Murley, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/ enclosure and incoming:
)
See next page JW 61967 l4 3u l
__________________________J
[7590-01).
U.S. NUCLEAR REGULATORY COMISSION DOCKET NO. 50-341 DETROIT EDISON COMPANY FERMI-2 NUCLEAR POWER PLANT RECEIPT OF' PETITION FOR DIRECTOR'S DECISION UNDER 10 CFR 62.206 i
Notice is hereby given that by a Petition dated May 7,1987, the j
Government Accountability Project (Petitioner), on behalf of the Safe Energy Coalition of Michigan and the Sisters, Servants of the Immaculate Heart of Mary Congregation, requested that the Commission take certain actions with regard to Detroit Edison Company's (Licensee) " employee concern" program entitled SAFETEAM at Fermi-2 Plant or in the alternative modify,' suspend or revoke the facility's operating license. The actions Petitioner has requested the Commission to take with regard to SAFETEAM include (1) taking possession L
of all the SAFETEAM files, reviewing the safety-related allegations, and making these concerns public; (2) requiring that all SAFETEAM allegations be processed by the Licensee in accordance with 10 CFR Part 50, Appendix B; and (3) requiring the Licensee to inform all its employees about the SAFETEAM program before the employees chose to submit information to the program rather L
than submitting information to the Commission.
As bases for these requests, the Petitioner asserts (1) that workers who turned over allegations to SAFETEAM were harassed, fired or otherwise discriminated against, (2) that the SAFETEAM was not being properly implemented and was
e 4*
g l l
ineffective, (3) that SAFETEAM interviewers are inadequately trained, (4) that deff lencies reported to SAFETEAM are not recorded on non-conformance reports and are not evaluated by the site quality assurance / quality control staf f, and (5) that there is no quality check or accountability for the SAFETEAM program.
The Petition is being treated pursuant to 10 CFR S2.206 of the Commission's regulations and, accordingly, appropriate action will be taken on the request within a reasonable time.
A copy of the Petition is available for inspection in the Commission's Public Document Room, 1717 H Street, N.W., Washington, D.C.
20555, and at the Local Public Document Room for Fermi-2 Plant at the Monroe County Library System, 3700 South Custer Road, Monroe, Michigan 48161.
Dated at Bethesda, Maryland this 29th day of June,1987.
FOR TH NUCLEAR REGULATORY COP 941SSION
[
- g -f 1
Thomas E. Murley, Director Office of Nuclear Reactor Regulation _ _ _
l l
I
l 4)s- /
.+
l The result of the safet teams operational inaadequaceis GAP believes that the nrc has made serious error in judgement by providing the et program regulatory immunity.
our review of the law conviences us thet the nrc has exceeded its authority in es t this loop lhole in accountability.
we strongly recommend that seacom challenge the nrcs position at fermi, and recommddns the following specif ic actions' 1.
file a peititon purusuant to 2.206 requesting the nre take possesion.
of all saferteam files, review the allegations for all potental safety related deficiencies, determine w hich allegations were originally or now are inadequately dispositioned purusant to the original commitments of the site procedures and federal regulations, and conduct thorough indspendrnt investigations into sthose allegations.
(indepedent in thiy context means hiring a company within integrity and credibility tor review the allegations ac opposed to the nre or utility.)
2.
include in the position a srequest that ste nrc require this al and all employe allegation programs be subjected to the requirements of 10 cfr 50 appendix B.
3.
require that employees are given full disclosure about the safety cafeteam program.
this cisl discoure must include informing workers that their allegations will be given to a senior mgt. review team and invest igated by contacting the workers' supervisors for "their side of the st ory."
l i
i
DRAFT RESPONSE-T0 INQUIRY - SAFETEAh INVESTIGATION The Nuclear Regulatory Comission has released a report, prepared by its Office of l
Investigations, of a review of the SAFETEAM program at the Fermi 2 Nuclear Power Station. The review was started in June 1985 as a result of problems which were identified in a similar program at another nuclear power plant. It identified shortcomings in the program as a system for investigating the concerns obtained from employees at the facility. The review involved the SAFETEAM procedures for those allegations which identified potential wrongdoing, some of which previously had been provided to the NRC by the utility.
SAFETEAM was a voluntary program developed by Detroit Edison which went beyond the NRC's regulatory requirements.
Since it had no regulatory basis, 4WWM the program was not reviewed nor approved by the NRC.
The workers' concerns, identified through the program, however, were routinely reviewed by the NRC's resident inspectors at the Fermi 2 site.
The resident inspectors periodically reviewed the documents showing the allegations to determine if safety-related concerns were properly identified and to examine the basis for the resolution of the issues.
If the resolution shown in each case did not appear to be adequate, the inspectors advised the utility of their assessment.
The utility then readdressed the issues, and the NRC resident inspectors once again reviewed the results.
Because of the concerns raised in the 01 review at Femi and in the problems found at another construction site, the NRC and the utility performed separate reexaminations of the allegations covered in the SAFETEAM program.
The NRC in July 1985 examined 10 per cent of the SAFETEAM allegations which involved nuclear safety issues. The utility's review covered 67 per cent of the safety allegations.
Both of these reviews involved a full examination of the resolution of the allegations, including, where appropriate, inspections of components in the plant. (These reviews, combined with additional NRC examinations of some other SAFETEAM allegations, meant that 85 per cent of the safety-related SAFETEAM allegations were rechecked.)
The Office of Investigations report is critical of the SAFETEAM process for identifying allegations and for investigating them. The NPC technical staff concluded, B43
DRAFT through its own review and through the results of the utility's reexamination of the SAFETEAM safety-related allegations, that there were no safety questions that were not adequately addressed from a technical point of view.
In addition, the NRC did not reduce its inspection program because of the SAFETEAM program.
The safety and the readiness of the facility for operation were judged through the same NRC inspection program and licensing reviews utilized for all nuclear power plants.
i 2
DRAFT ADDENDUM TO FERMI RESPONSE TO INQUIRY The 01 review included 65 allegations of potential wrongdoing. Of these, 18 had previously been provided to the'NRC by the licensee. The 01 revies identified another 17 allegations which involved potential wrongdoing and should have been referred to the NRC for evaluation.
The original 18 were evaluated when received to determine what action should be taken.. The 17 were reviewed by both 01 and the Regional Office--and it was determined that no further action was appropriate. This decision was based on the nature of the allegations (e.g. vague or several years old) and
.the availability of inspection / investigation resources.
l I
f
(F____,,._,,.____m f
L
{ AIN l D.Y
( $ 5 hl.l,.{/hi.YliO/f
(;, j, p & f
/.,/
/
MO *[ (U f t-C. co g h ~1g [
9 II c on( e r c 5 4
l 1
f
~,,
[v-=www
- 4g.n. 44,, 4,w d y
'Py 441 o +ui to y, +.
~
r w c
} - l' p x.
~ ~, b A " " ' ) W L' & ~~.y.'i,? 3l a
. ) f,)
i j-a t
y
%mehs%
r&4/
y g
{
h 5 M e, flg $r',-;~."y'
'** % jl.-* Rh,6L, E f(5;t& jd 9, '~R Q
Muna ew a..,sf,I[{, ce-
.)ll o m e d w a -
/ ut-
~
~,
Q Q L.
~c w" C -
Itc
..,.<1 f
l 'Q"
.11 i T b:?ffd )ng)f;,1fPq q qsr3cwhQ g q' ; ;)* T "
g d. T.4 3%p,4 3*;
y j'
g
- QgRgv}yRM$$u M & 4, M ) g j.
Tw7 W M%R sgN 9 d / ~ :., & J b
- n w %a 10Mc O'>**-5dJamT2 o D% re'c{
nn
~
a
~
w:a r %gW w
1 r
M4 9_&.. ~ ~ J et-
., E. 'd'g.
~
up n
ama a.
. * ~
e gj -
w# ; w*~ p (:t L g N g g,g Qy etg..
fA, pgm m w a; y ve 4
4
$y %ea&D.a*.
ac
- pr m> m o o jh re @ @C cmc
-n m m m% g p l. -? hif
'N' j
- p. p& W h & w$ &; a PM s
s r
Q
)j
- L 'G ""P&aw.%5QQ
&D jdQ 6 %w*s m,a q ka w w; - n Mgi thM%mF461 n- % w w u l m i w% w y
% %'('w' r *' r 9 M A' w%p 5' M M. T ' M MtM '
}"$p W
[
fr
. r n
n a
~D n$
5
<U t
' p u hm; %.
~
d
', Y
.4 T'N
,y[.
q l
%m^ '-m W w w, n w.
e y
- x ':.
9g
- p w
w rn y% ya.w, g g*;
.m s
m pc&gfW)g'f J, Q
e4,
/ g~ ;"ff,fQ QH K
WV, t
(p WW
- h. W$MMWkf%a:hSW.
a
/
4 4n n
my W
\\Q
- , p;y d R &e. n O, J,$m.. Q. ?
g%W4,.
.. Q.
h& %
,,,d2Qm f
2 D g, A,.
y : mg 4m:x, Y;Y%gf:;rd$m,
3j, g
- M,k@T q N.
p/h
+M }tR
@M M
f/W-p 2
e -
zg m
ge.
yg gg h,.
M $pw
%k IhM;M
+k 3
w d qq n-a x
A qgghY_y
, a s
wwww~em, ikYY wYhEMn$Y kh hN4h Yh O
w w w w n,e m4 <nemn.
fr$$Q$y bfh+dW,OWqhw&Wi@m$M& ^:ly?,
n n..
e e
x
.~
i
% & Q + + 9 2 l w & g &v &, ? y$n & s f W W ( &a, h; w nWY ~,
1 kk q
E Q
i L
w.
m c: a w
m m
~amm h
wwwah {kN.k?
d W L a 4;g+ f h k Y h' Y$f$f a.19w, A ' x a g m a:M; m.f Shh k
_qqph'Ypp fh
~
~
J w
8pN 4 6 * * ', ? ' N E dn@w g w r,&m n 3 w
- w., wwfp,p gm:rW : ng; 2
U w v yM %;"~o'g 9 e w%g4 mw m'
w ax
~ -
mH
'fjy%w%
MyQ wy&q%samq y8$w&y& kQh u
hp mp a Mb mwww V W" M64$.Mp&&
4 g M T W $ TE
. MMS m. weca n ;.
& ump ep,hf;&ngC/MgW w
hNk?5Q
&K+h fhffff
- .fhphi hh5 p w[ epm pea n g\\s, mmm m y.
g g-map ~y:
y gwg s pyky%ws m g.
y a
y tw p.:
y
- y.
y g
, e v> w e gf.'y,} l j",'
so o t...
7er q w^ '
.'s I,
'l'
,t r Q:KM X
s;
,.s 4 -
pgggg+g w
l 57 <
,y.
,~
~
3-n
. i.
.rw.c
w
?dhf 5f%
4
- y e
,g r
r#
' * ? g*T*J ' >
- _L' "l$
,p_
" *Q s
rw e
~,
n 4'
3 gr h
.(
4
.=
0
'ir 4
A y Us]v 5 a ;. r M m o'J 5
& fwn
' ?
- ,q,, C Mf0/J e
e: c'."eff m
e
) * h )
l'* he) h f f qv, W.,yn p Q*
[
O qf t9 O $$ R 4 Orc W W ?) *
+.. -:- u.c wp. g pois.n-fo O.. a ). de e n.( l., ees % e,pss.w op J<
D cn-rw fel
- , :e.
. ser v.m d % e ; x v..
14 e,: ~
M%n-
- 6. Qjot oQ T~u ci's av (5/C-C 5 6
(< f fro:
c ', ['l5,ed,!ro
,y de 8,
c.%c r e.
n.; r -
4,mmm w m s. M g, f W y c -ws,J -
wuc.
M.a & & s S np,,d su prdk-4-k@ouh. $d
-1 1
@~ m_w;q, Ay)p _.g M,.. le9.3% ds.,erssik ~ _; m-e,,
a n
g e
we
~wwe V
.ar m
vm lacw,
t
!,.3
, :4 qip y, ' a s. }e ' '
/b.
- f.f}f][*j'& x,-
n-lf k: 0.,E'f.), ' '
). y.,' ',' l, ' hy,-
~,
+a
+
r
,,l} Q y.
l, i
+
. G.
I=
f e
- 4. e ^9 %~.g kun a k, k< w w &c 4
a s.,
v s.
,- m.
f ?! f } Q[ % c :f ' hh]if&yf f;&w(. b
.. gtQ gga g
, fhYfhg ?
Y
?'
fh &. ^
- Q f N
r n w n p gS.. =,,p a Mn.rm ba,%.+ y %w n f,v et
- ~ - ww+
twx n,$M% -
- w..
% [;rgN' f,'.k T' 9.[w m.
,k) m. *
%'[ mp.-[
N
,, ; [,
Y. [dLkb
'e
"(
U
'4.s=
'k,, d c ~ m 4 N f'
m. v.,- m d
u.--
/
-.-%-~.--o
<4
+
4%$
- m' W % ', y y Q:[- b,'#
2-I Nf v*N h L. Y h. ID 4
/,
- h. Q y,...AfQ hlf I
f z
y %,.l? A n@
k f-- o, ~
- p. yvfy. -
- f$N> a* %;WM-a;p D
- m< nn V t, ' e4.,Nf. ;3 t ph(t '
e n
+A 9 n
- n,' t e
- gN4=
$)h'": b ]y m
., k'p'-,.,,..r
,c p
2:.
e' bh+Q h
. $kh
- 3r 1
w.
Fin
- + " -
+; ;
e$$
5 21
.J
% g s e w h. n%g w p % u p p p m %y g g %n
< m A.g ~ f e
a pem W32MnGMk 3
M"n W
w m.
ww OQ,m s w + ~ 4 gy@y pv a w -wmum:pyqq gy
% d y?g g yg g g g.
i FfQ?HMjff n.
y
- f. n.. n( W.,.y j~.. ;.6 @.p:. M. & M s j %, f$ Qx., &,k 8, 3g9
, Nf p
7 " NMN P h?Q&#NMi-
,,w.., n a. n. n c.,
wgm.
n x.
.l
'I,,
I
{
L.
n w,-
s
. %< e., m_,n..mwn.
./:
w 3
_.~
l k(
l h^
h
. lff
^ _f
}
^
ju*
^*f, "l rD
+
g ;.sgymmy y a+w, myg%gg4g%g, gy.1 g
l 7
p v
.m
.r r
SC, 7f 4.
- TS
- [T or <
t h ir$ 'd if C C C 0.O ;
i u,
'6 h
p,oe A a. 4 A i d w i m ll o 4cAk%/WsM4 l
k, cst w p%etp aca m askic p.,g,=.,'
YJ A
1 h Mc
,e 4
'4*
1
[
4l
}
(
+
b.
w-~m-m,,,,, -, -,, - -
9 e
8 9
e '
- 1),s.( o fe e ca l bh, 2 p o '.*
- cc #t: iv rc' e*- w., >; c L hS tv0.
l.au.c 0 " b ;'T-Ni.*C -
N k 0-b p qt
's HCC-o124 7~c
<G hc Io C.= ~i c o !^ : - r. N -
. s-p '
^
< <.,v.s. [ @ lo&:
sa < e cd.
6 eJ ha.sr 6, JJ v} cow.D 4
7*(b(
b l..' e I >$
/.
y
,.t aril p
1s 14~
? }.:
7 40 *' V;,,
. T~ C V s((0, h R\\".1
- Q IfO' fe
$, ' O $$ v 2 O* 'E $
E(*
T&thed k)of '<
!)r,g,, & r
~"
m Prc g y u m, 2 K % Q L & d ee s de) SE uw. 'ed cdI J &a e
1I dese. coa.boherb ur6 c nessive M 6a'-ozos > c.,J % g sf /, y.od.;g 3m.,
mu m
'.Y... 1TvWi$N']$'j g fi.
- b 'a h
- f
.; htsaf), S&. hh;.Qlff el) s p e(,,.M,% Lsa us cfff6 @fywys,$ &
N u J a.. n u.w: K, c.w.M.M M Wns c
y.
- - 1 m
/
1 4
g 4
og w
,h/fo f$gY-l f.
.st - $
t' !$r 3 '
C 0 & $$* Ce. bO C E
t C
,p
.c.
s,x E
JA M M N M M M M 5M @ *09, " W N$'NO% a. x;w,;vJ1
(
0 N'
[$'
i.S es> '. >SN ff 0 D M T,"
mm.h<an u
%.w ;
v
% yA{ TO]g g u ~ g;/gg g a g g.sa-pr.. m pggtg ug g%
gdg.* % M dg j g~ggpyg{Tgyg
~
wy W
F Q-wW w %w$1 g&n e, nn;us.,a-yLp k
3p2 gg gggypg
.nn uv w-
~ s u
n e
n.
I 6A w!
. m'.,,,,
,y-.p ~ '
~
,,,I
'g; 1
i.
I
!j s
j
. g,n n n n A.
+v~-
mw4 w,
USN/,k
,/.d d h,'k
%h$ YS$ 20 k
- 6.. ", m g y> v. g.. z n mg &,f a gdq,g q;m,g.m g nn9ggy age
.wr4d y rn ywy.
.~
,o.ye.e. wp 4a~m w
4 1
~
w..
.!&S$~3-h _$$ _b _f o k.,YY
_YY A
illuG
~,
Y b
h
%.i os h.
s i'hY tY $ hbY._v,y;.M,.;9
-Ite.
c- %e g%) q y.
.cm i
moe :
' ' ) \\ A,'4, u '* ~o,g[c)a.s ' Q:
c/
c n m mg y y,, ;: : g.,
c 1
(L.p 'j
_7 X
LJ
'e
.re ~.
, w., s
't ^
\\
. c t,
.,$,aJ,. MCTro ^)
d 2:lD Qi' Vt941, &' )$
.]
&'t D' AX ;ck%& CN d.l ck.'p f qS r
.d er ? con p rN k! N W.' m A ny k N h & nya.As
-_--.-,----------____y..___.-.
G
.9 0
.,e
" Ed % 5.~y..:o;,r
- l r....J,
,.s,.,.
~
...;,o l
-l
\\~
~ '
f0
$ i.s C 'b t.. *J o s..>.1. e a g,, ) & S.
- l
- ~ntv(~.robfe.s.
. {. ^:03.* ph: e wi e, C t
o
~t 4;w r<.s a re p < %
oc ac,s.3.
c-
+
t*z -'o A,.s
- 9 5 S f t yv s e o r-f b y b d le,,,w /A p.., J, w y,,,
,F..,_> g> g-m /..
3 p ul,e>;< N.,
- m. + s :. V.lc,s -
.' t '. f, ' 4 8.
awa
/ 'l - Q e M W, f p c. N : < ',,,./
sa.L -
3
, g4gy t
gl h
k h, Y
?f h?Gg~..
7 ygyt4 W.L W;xs,.;gy;L yn.s p a:.s. % 'a e-R Q 7??y "
97, r" er-A,- A h e, z.,, f,.
n.
. ww.
., - ~
~
1 Mag %:::n)A-. cop %W O. r. i:<< <.
~,,4;,[< Q.f1. c,... P.,.
. ~
V g M & A.,. c./. ce s
f-
?ff f.C(f,, mpy' P W "* % $l W % Q c'*2 W p t%
f k fh i
'f hl.
e
$%&W jf}a g &gjQQi.;.g#J/p%
fygg f.,.qy~
.wma wee _p 4-.
g Sw-g
. A Adsd W.WMq%gayg _ '(
g W
W[A M{f' h fjiff k
- W4m
+:npug gVh i
J s
m[k d f
@y%O
$ l$
'.m,I. p m~,~ qi>
m 4
%jgkhyhf & W Mi
?$$
%f h
)
&i wk w24 i
1 a
+
n
% gyL A #dnFMN' th M bAM nh,
'rt TW i no,W 11: q s f,@u@y M g wdd 6 W't.M y t d,%h NN m
ma y
u Z. as @uly $yter,e m qe. m,,Nk.NT w
$f f
l
/mmwsw.
y WA s
e qqw 1
"WDMWcfy[yyfg h 4. c
%a m) M7@a,MY@1,yg;q p,[;p[m '
n n.
hfht
, n h
b7
'*N N Dr. '*
v w
7 :z y
y y
g,
- wgg g h,
,/,
,h.h,,.m b
.i
~ den
~..
n.w, 4x Wgp. w. 4:n -y %.e,J Q 4,gtgm s
e'j(:ee;nmgp a
. y h =h-n Mee 5.u%
S%.
i t
W'?htgs L 'h"0 }tc.' kee.
i"Om
"^
r j'
K., >
~
n e.s w
% 4 G,. j' fn
+
8 g-
?.
,e A
'~
[
[ ' N '...I 5
[ i h;I j
9
D/' K'6N6L'GGY Of* Al' ff+Ncri AWCA776W 8/27 /85 - //:60 a>, /itiecea cox78Tio Ndt desioe wr o.cr<ce v;9 ru n w ve rc, j c r v'O A ria 77df 3:uop
/tt Sutcon carissar Ado xe areivia per virw time AT
/kfc c 6.'k' dyt10eyr jyyptict$ c(pace-Bf28 SS ' ) 5714.;Wia:-r:
XI 6%:n tA,'4 7Kr 154r,4!te:M7tw dm7t*7~ fer.'AT Jitut
^
e occ.,
5,bi .l ~
4tt(?'l P(A/ AM-?.1'H-Y%'f U6!!J
'7/6/65 -
trn?c Ji vr 1D Mi m+vO.i MA wwr.ws' Xt:nri c,~~ /N.1 a eur7 twt c
LV173 r*.fr v7 70 16(4,Qzi t.3piett' gg.y; e ry (,
f.<,yngt <t pu.777(:pptw
/Cjh4/65-Cdek-t' th e 6 fs TMN Tc 4 fLuscit duccMM I
/
ffb
___--___-_---_-__-_______s
,~
n~..
7
~-V---
i<
)%
rW ok i Group assails l
m Edson response FROM PAGE1
. te concerns Whistleblower tco,,t.)
By C61ARLt.S SLAT Eycntng News staff wrtte, the nuclear mdustry and is tring clecking with other persontwl who used at other U.S. nuclear plants.
may kabt of the concern revies.-
A public interest group today criti.
Safeteem is not an independent. ir.g doctanentation if availab e and exa WRC; inspection analysis of worker allegations "-
cized a program Detroit Edison Co.
uses to pmpomt potential problems at add Billie Garde,a director for Ok to see if ancerns have its Enriev Fermi 2 nuclear plant and Washington, D.C.ibased.' GAP.
Identined andtvoolved.
saio n
,c launehm' g a prehminary "It's a re-verification of
- what's M6 aid it' fs rare that GAP inetg., into worker concerns at been done by muagement/{t doas becomteinvohed le nuclear plants the f ac.g,.
a good job of r,olvtrtg personnel that already ha re been heense problems, but in terms. of safety r nd operational, such as Tertni :
The Go5ernment Accountabillt'v 1ect (GAP) assailed the utility s and engineering e,cerra, it's just But she said the July 2 fact, oct a% ate "
then-planned reactor startup Steam" program, saymg it com.
worker confidentiahty ar,d She said her group has beer.
Ferms and "a trickling" of co.
p se*
istu n ada.quately addrts: worker
~ contacted by a few workers who plainte frem amtern has prc c0necens about the plant.
felt their concerns were not pro.
mpted the orgamzation to take a l
closerlook
' if Gwy'rt saying that the confiden.
periv addressed. "What we found as 61 W workers contacting us Ms. Garde said sha y as not sure flality of P ! program has been ha$e gone very unsuccessfully what GAP ultimately would do breached, tL's not INT.wponded through Safeteam. They feel their with worker all+g&tions it re-Martin I.
Bufallna, an Edison concerns were either covered up or ceives, tut added, "we probably r.gvkesman not addressed at all," shesaid, will take the concerns soout the Deltoll Ediwn develo d the USI"8 D plant first to the state ind ask the Safeteam propam in 1983, ft allows '
GAP now r.ewsp per advertising,
- t. tate to tske tlwm to the NRC.
s encouraging workers workers per.vanently leaving the job to bring their concerns about So far, GAP has heard concerns site to tuM uit interviews with third parties in..och they may confiden.
Fernu 2 tothe group.
about the "besitb phpics" section llIlly voice concerns about any arpect "If workers have parhelpated in at the plant, tbc department re-1 of the plant. The concerns then are-Safeteam, there should he no sponsible for deterrmning radia-pwed along to be mvestigated by the reason to go to GAP " Mr. Bufalini tionlevels and workerexposures.
said. He stressed that interviews Some of the concerns involve the
- company, radiation andh:1pment to measure adeguacy of em The program has been praised by the with workers are done by a third lack of training Nuclear Adulatory Commission and party consultant to the utility and are followed up based on code and experience of personnelin that numbers assigned the cloocers area.
r,*+ WHt$TLEttOWER, pag.14A GAP, which irnmersed itselr into She said fHek Dillon, a health allegations about the sbandoned ysics techruc>an who quit Fermi Mwand nuclear proiect was use his ewerns were not asked for assistance at ferm,i 2 by addr W b wg tho6e sbo the Safe Energy Coalition and the conta.tv W Sisters. Servants of the Immacu-Ot k,m
. involve a Monroe-the & A
. control late Heart of Mary, Both groups, -insp*ctka
. n safetv.
based religiou? ordcr.
Are npposed te Fermi 2 related civird cat >les, M's "Former Termi 2 workers have Garde said.
brought safety prvbfems to our She said the cmcerns*are voiced or anization, sald SECO by worker 2 wholeft the plant about qv; eswoman Jenm,fer Puntenney.
hential bo. "There is
.f.eara t these problems ave In order to ensure the Nuclest Wgulatory Commission properly n corrected, but when thase mvestigates these all at have sought GAP's thp. ions, we PeoP e left they.aaid the areas l
We are requestmg that any Fermi 2 y' rey qwration, she workers who have krmwle.dge of safety issues, which they believe Fermi 2 has been shut down for are not resolved properly, to con-malrdenance work since Oct.10, tact G APinvestigators.
but utility officials say they expect Ms Garde said worker concerns it to reach commercial operation would be followed up by GAP, later this year.
l
- r ci8 4 r 9
-Q
'~
ATTENTION L
FERMI WORKERS Only you know the problems at FERMI li l
Are You Ready To Talk?
The GovommOnt Actyxqq;!q p.3;g (34p) har Q;65N*d ta'ety cor.coms er : har pmtected woA
^
i
- 6M>' P'r#em at f/,hh:f. Unnxd r4 l
CALL: f.202-232 8550 (Washington, 0.0.) or 2416460 (Montoo) l l
.