ML20236B253

Notice of Violation from Insp on 870713-0807 & 0813. Violation Noted:Licensee Failed to Implement Preventive Maint Program for Various Components Including RHR & HPCI & QA Program Failed to Identify safety-related Items & Audit

ML20236B253
Person / Time
Site:	Fermi
Issue date:	10/16/1987
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236B232	List: IR 05000341/1987028 ML20236B229 ML20236B253
References
50-341-87-28, NUDOCS 8710260035
Download: ML20236B253 (2)

Text

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1 NOTICE OF VIOLATION Detroit Edison Company Docket No. 50-341 l

As a result of the inspection conducted on July 13 through August 7 and 13',

1987, and in accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986)', the following violations were identified:

1. Fermi 2 Technical Specification, Section 6.8.1, requires that procedures for-preventive maintenance, which can affect the performance of safety-related equipment be established, implemented, and maintained.

Additionally, Fermi 2 Technical Specification, Section 6.8,4, requires .

4 that programs including. preventive maintenance, be established, implemented, and maintained to reduce leakage from those portions of systems outside-containment that could contain highly radioactive fluids.during a serious transient or accident.

Contrary to the above, the licensee failed to implement, or implement on schedule, the preventive maintenance program for a significant number of components (more than 5,000), including those associated with residual.

heat removal (RHR), high pressure coolant injection (HPCI), reactor core isolation cooling (RCIC), and emergency core cooling water (ECCW) systems.

This is a Severity Level IV violation (Supplement 1). (341/87028-01)

2. 10 CFR 50, Appendix B, Criterion II, as implemented by Detroit Edison Company Operational Quality Assurance Policy E, " Quality Assurance Program,"

requires that the Quality Assurance Program shall provide control over activities affecting the quality of the identified structures, systems, and components, to the extent consistent with their importance to safety, and requires that activities affecting quality shall be accomplished under suitably controlled conditions, including assurance that all prerequisites for the given activity have been satisfied.

Contrary to the above, the licensee failed to identify the EDG 13 fuel oil day tank level indicators as safety-related and TS related on WR No. 648693, which resulted in work instructions being prepared, work being performed and closed out as if the components were non safety-related and non TS related and the licensee failed to provide adequate controls consistent with the components importance to safety.

This is a Severity Level V violation (Supplement 1), (341/87028-04) h2gQ h G

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3. 10 CFR 50, Appendix B,: Criterion:XVIII, as implemented by Detroit Edison Company Operational Quality Assurance Policy 18, " Audits," requires that:

a comprehensive system of planned and periodic audits shall be carried out to verify' compliance with all aspects of the quality assurance 1 program and to determine the effectiveness of the program, and' requires- I that audits shall .be performed in accordance with written procedures or checklists.

Contrary to_the above, the licensee's auditors and audits' failed to ] '

identify the, preventive maintenance issue noted in Violation 341/87028-01 '

and failed to complete checklists, including the checklist item on material storage protection level, which resulted in failure of the licensee'to: .1 verify compliance with.all aspects of the QA Program; adequately determine. j the effectiveness of the QA Program; Land' identify :a significant condition  !

adverse to quality, j This is a Severity Level IV violation (Supplement 1). (341/87028-08) .

4. Fermi 2 Technical Specification, Section'6.5.2.8 requires that audits of.

unit activities be performed within specified frequencies. 1 Contrary to the above:

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a. Audits of unit activities, such as operations, corrective action, ,

and fire protection were not performed within specified frequencies. {

(341/87028-09A). '

b. Procedure QAPR 18 allowed the frequency.of audits required by the .

Technical Specification to be exceeded by +25%. -(341/87028-098) l l

, This is a Severity Level V violation (Supplement 1). j With respect to Item 4.b, actions had been taken to correct the identified violation and prevent recurrence. Consequently, no reply to the violation is required. With respect to items 1, 2, 3, and 4.a, pursuant to the provisions t of 10 CFR 2.201, the licensee is required 'to submit to this office within 1 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 violations; j and (3) the date when full compliance will be achieved. Consideration may be~. >

given to extending the response time for good cause shown.

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Dated It I&[f]

lWbYL Hubert J. Miller, Director  ;

Divi i n of Reactor Safety j l

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