NRC-87-0028, Responds to Violations Noted in Insp Rept 50-341/87-09 on 870202-0303.Corrective Actions:Control Room Personnel Counseled About Requirement to Comply W/Requirements of Plant Operations Manual 21.000.18, Out-of-Spec Log
| ML20206H179 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/13/1987 |
| From: | Agosti F DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-87-0028, CON-NRC-87-28 NUDOCS 8704150280 | |
| Download: ML20206H179 (6) | |
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April 13,1987 NRC-87-0028-U. S. NLiclear. Regulatory Camission Attn: Doctnent Control Desk Washington, D. C.
20555
Reference:
Fermi 2 NRC License No. NPF-33 NRC Docket No. 50-341
Subject:
Detroit Edison's Pesponse to InsDection Reoort 50-341/82H39, h is letter. responds to your Inspection' Report No. 50-341/87089. his inspection was conducted by Messrs. W.. G. Rogers and M.
E., Parker of NRC Region III on February 2, through March 3,1987.
We trust this letter satisfactorily responds to the notice of violation cited in the violation report. If you have any questions regarding this matter, please contact Mr. Frank H. Sondgeroth at
.(313) 586-4270.
Sincerely, n
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Enclosure cc: Mr. A. B. Davis Mr. E. G. Greennan Mr. M. E. Parker Mr. W. G. Rogers Mr. J. J. Stefano USNBC Region III a\\
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'INE DETROIT EDISON CmPANY FERMI 2 NUCLEAR OPERATIONS ORGANIZATION RESPONSE 'IO NBC INSPECTION REFORP NO. 50-341/87009 DOCKET NO. 50-341 LICENSE NO. NPF-43 INSPECTION AT: FERMI 2, NEWPORT, MIGIGAN.
INSPECTION cot 00CTED:- FEBRUARY 2 'IERCUGH MARCH 3,1987 1
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Enclosura to NRC-87-0028 April 13, 1987 Page 2 RES'?ONSE TO NRC INSPECTION REPORI' NO. 50-341/87009 Statanent of Violation 87-009-01 Technical Specifications 6.8.1.a requires that written procedures shall be established, implemented, and maintained covering the applicable procedures.recomended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.' Appendix A of Regulatory Guide 1.33-states the following activities require procedures:
o Equipnent Control (e.g. locking and tagging) o Plant Fire Protection Progran Technical Specification 6.8.1.a is inplenented by the Detroit Edison Canpany Plant Operations Manual (PCM). PCM 21.000.18, paragraph 5.1.1 states, "When a system, subsysten, train, component, or device which is safety related or is otherwise required to be operable to satisfy Technical Specifications or IST is determined to be out of specifications, the NSS/NASS shall initiate Attachment 1, Out-of-Specification Log Sheet.
Contrary to the above:
a.
On February 17, 1987, the licensee failed to identify in the Out-of-Specification Log the status of the inoperable masonry fire wall and that a continuous fire watch was posted as required by Technical Specifications.
(87-009-01(A))
b.
On February 7, 1987, the licensee failed to make an Out-of-Specification Log entry for the inoperable division II EESW pump.
(87-009-01(B))
Corrective Action Taken and Results Achieved (87-009-Ol(A))
An Out-of-Specification Log entry, OSL-86-0355, was made on February 17, 1987 which covered the subject block-wall. removal in order to perform HPCI work in accordance with PN21 985579. 'Ihe necessary 10CFR50.59 evaluation was prepared to address the i
I Enclosure to
-Nqc-87-9928
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. April 13, 1987-
'Page 3 L
_l RESPONSE 'IO INSPECTION REPORT NO. 50-341/87099 degrada' tion the flood boundary and a continuously posted fire watch-was implemented on February _17, 19M.
Corrective Action to Avoid Furhr Violation (87-999-GlfA))
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_00ntrol Roan personnel were counseled about the requirement to comply
,with the requirenents of_21.999.18 "Out-of-Specification Log" and that breach of Technical Specification fire barriers requires an OSL entry-and satisfaction of the applicable Technica1' Specification action-statement.
Date When Full emnliance will be Achieved (87 ""^ "lfA)) ~
Fermi 2 is now in full compliance.
Corrective Action Taken and Results Achieved (87-999-GlfB))
1 OSL 87-99991 was written on February 9, 1987 stating'that Div. 2 of EESN was inoperable effective February 7, 1987 at 1599 hours0.0185 days <br />0.444 hours <br />0.00264 weeks <br />6.084195e-4 months <br />. 'Ihis
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equipment was returned to operable status on February 19, 1987 9199 hours0.106 days <br />2.555 hours <br />0.0152 weeks <br />0.0035 months <br />.
Corrective Action to Avoid Further Violation '(87-999-91(B))
i PCM Procedure 12.999.61 "Inarvice Testing Progran for Pumps and Valves," step 6.2.6.2, clearly states, "the NSS shall declare the punp i
inoperable," and then take action to restore the equipment to operable status. Corrective action was taken before' declaring the equipment' -
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POM Procedure 21.999.18 "Out-of-Specification Log" was revised to provide instruction on the use of an OSL for tracking purposes, system
. outage conditions, and a definition of provisionally operable-equipnent.
Enclosura to NRC,87-9028:
April 13, 19 0 Page 4
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RESPONSE '10 INSPECTION REPORT No. ' 50-341/87099 During periodic reviews of ISI pung operability surveillance procedures (24-series), potentially degraded pung performance may be-identified. Based on the results of the periodic review, corrective actions may include calibration.of instrumentation, contacting ISI for further. evaluation, or performance of corrective maintenance. 'Ibe niclear Shift Supervisor will be notified of any degraded punp conditions and t w corresponding corrective action.
Control roan personnel were counseled about the requirement to declare ~
ISI punps inoperable as soon as surveillance test results indicate in the." required action range." - Also, memorandun NP-CP-87-9042' dated February 9,1987 was issued discussing the inportance of canpliance with initiating and maintaining the out of specification log.
Date Nhen Full Cm nliance will be Achieved (87-999-91 B)
Fermi 2 is now in full canpliance.
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Enclosure to
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' BC-M-9028 N
-- April 13, 1987 Page 5 5A RESPONSE 'IO NRC INSPECTION REPORP NO. 50-341/87999' Statement of violation 87-999-93 f
18CPR50,' Appendix B, Criterion V,' " Instructions, Procedures, and-Drawings," states; " Activities affecting quality shall be prescribed-by doctanented instructions, procedures, or drmings, of a type appropriate to the circumstances and shall'be-accouplished in 1
accordance with these instructions, procedures, or drawings.-
- Instructions, procedures, or drawings shall-include appropriate quantitative or qualitative acceptance criteria for determining that inportant activities have been satisfactorily accouplished."
Contrary to the above,~ PCM 41.999.11, " Process Instrumentation Calibration step'4.1.2.2 did not appropriately prescribe the organization entity designated to inform Inservice Test personnel of out-of-calibration equipnent.
Corrective Action Taken and Resu22 Achieved Procedure 41.999.11 was revised on March 27, 1987 to indicate the individuals responsible for notifying ISI personnel.
Corrective Action to Avoid Further violation j
Affected: personnel were trained on the revision to Procedure 41.999.11. '1he training was canpleted March 30, 1987.
Date inthen Full (hnnliance will be Achieved' Fermi 2 is now in full compliance.
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