NRC-87-0268, Responds to NRC 871209 Telcon & Re Violations Noted in Insp Rept 50-341/87-28,updating 871113 Initial Response.Corrective Actions:Procedures Reviewed by 880729 & Data Bases & Lists Updated by 880831
| ML20234D980 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/30/1987 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-87-0268, CON-NRC-87-268 NUDOCS 8801070356 | |
| Download: ML20234D980 (6) | |
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- 8. Ralph Sylvia Group Vice President Detroit 64IJO North Owe Highway e
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December 30, 1987 NRC-87-0268 i
i U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555
References:
1)
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 2)
Detroit Edison Letter, NRC-87-0243
" Response to Notice of Violation 50-341/87028", dated November 13, 1987 3)
NRC Letter dated December 16, 1987 4)
Detroit Edison Letter, NRC-87-0256
" Response to NRC Restart Letter j
Item 2",
dated November 30, 1987
Subject:
Response to Notice of Violation 50-341/87028 Revision 1 l
Reference 2 provided Detroit Edison's initial response to Notice of Violation 50/341-87028. Detroit Edison committed to provide an update to this initial response by December 31, 1987. Detroit Edison also committed in a pho;. : call with NRC Region III on December 9,1987, to provide additional information related to the Fermi 2 Preventive Maintenance Program.
Subsequent to the phone call request, the NRC followed up its request for additional information on the PM Program in a written transmittal (Ref erence 3).
These updates are attached.
Please contact Mr. Lewis P. Bregni at (313) 586-4072 if you have any further questions.
Since rely.
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Enclosure cc:
Mr. A. B. Davis Mr. E. G. Greenman Mr. W. G. Roge rs Mr. J. J. Stef ano USNRC Region III 8801070356 871230 3
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l Enclosure to NRC-87-0268 Page 1 RESPONSE TO NOTICE OF VIOLATION 50-341/87028 REVISION 1 STATEMENT OF VIOLATION 10CFR50, Appendix B, Criterion II, as implemented by Detroit Edison Company Operational Quality Assurance Policy 2. " 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 af fecting quality shall be accomplished under suitable controlled conditions, including assurance that all prerequisites for the given activity have been satisfied.
Contrary to the above, the licensee f ailed 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 saf ety-related and non TS related and the licensee f ailed to provide adequate controls consistent with the components importance to safety.
This is a Severity Level V violation (87028-04)
CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT RECURRENCE Detroit Edison has evaluated the tentative plan described in Reference 2 and will implement the steps outlined below to ensure that Technical' Specification related instruments are properly worked.
The plant Technical Specification Limiting Conditions for Operation and associated surveillance requirements and procedures will-be revicaed to identify the instruments and associated loops that are used to meet the Technical Specifications.
The procedures that will be reviewed include Operations and I&C surveillant
,cedures that implement Technical Specification surveillance requ25ements.
In addition, IST procedures will be reviewed to identify the instruments and associated loops that are normally used to meet IST program requirements.
Once the instruments have been identified, the Central Components (CECO) data base and Master Instrument List (MIL) will be updated to indicate that these instruments are Technical Specification or IST related, as appropriate. Also, the instruments will be identified as Quality Assurance (QA) Level IM in the CECO data base, MIL and Q-List 1
if they are not designated as QA Level I.
The QA Level IM designator a
Enclosure to NRC-87-0268 Page 2 will result in an instrument being treated as though it was safety-related in the work procers.
These instruments will also be reviewed to ensure they are included in either the PM or surveillance program.
In'the interim, until the above work is completed, Procedure 12.000.53
" Identifying Systems / Equipment Safety Level" is being revised to provide clarification on how to identify which instruments should be considered as Technical Specification related and thus would be treated like safety-related equipment.
Maintenance and Planning and Scheduling personnel involved in the preparation of work packages will be trained on the new procedure.
DATE OF FULL COMPLIANCE The reviews will be completed by July 29, 1988 and the resulting information will be incorporated into the data bases and lists by August 31, 1988.
Procedure 12.000.53 will be revised by January 30, 1988, and personnel training will be completed by February 29, 1988.
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Enclosure to NRC-87-0268 Page 3 Response to NRC request for additional information on the Detroit Edison response to Notice of Violation 50-341/87028 Violation 87028-01.
Item 1 Results of the evaluation of the effect that never perf ormed and past due preventative maintenance (PM) activities have on the reliability and operability of af fected systems.
Detroit Edison Response As stated in a previous transmit tal on the status of the Preventative Maintenance (PM) Program and in the response to Notice of Violation 50-341/87028 (Reference 2 and 4), an evaluation was performed in August 1987 to determine the ef fect that never performed and past due FM activities had on the reliability and operability of af fected systems. No adverse ef fects on equipment reliability or operability were identified. Another outcome of that evaluation was the assignment of priorities (A or B) to PM activities on the basis of safety significance.
The evaluation resulted in the identification of 757 safety significant, or Priority A, PM activities that had never been perf ormed or were past due.
In the previous transmittals (Ref erence 2 and 4) on the PM Program, the 757 Priority A PMs had been incorrectly characterized as "never been performed only, when in f act some of the 757 PMs were "past due".
Of these 757 priority A PMs Detroit Edison performed 183 during the 87-06 outage in Aagust and September 1987, and the remainder were rescheduled.
The 183 PMs ware performed to reduce the becklog, and in some cases, to obtain information on the actual field condition of equipuent that was representative by manuf acturer and model of the 757 Priority A PMs.
Having performed these PMs Detroit Edison found that the equipment was generally in good condition which further supported the outcome of the PM evaluations that deferring the remaining PMs would not adversely ef fect equipment reliability or operability.
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sure to 1-0268 5ma4 Item 2 What actions you have taken to reduce the backlog of past due Priority A PM activities.
Detroit Edison Response In August 1987 there were 757 Priority A PMs that were identified as having been never completed or.past due.
Since then, 349 of these PMs have been worked. The remainder are scheduled to be worked during Divisional outages or the LLRT outage scheduled to begin in March 1988.
However, PM activities are now treated differently with the issuance of revision 7 of procedure 12.000.17, which is the administrative procedure that controls the PM program.
Under the new procedure all Priority A PM activities that are scheduled each month must be worked, otherwise an evaluation must be performed to determine the ef fects of not perf orming the PM has on reliable equipment operation. These evaluations are documented on a form included in the procedure.
If rescheduling is not readily justified using this form, a Deviation Event Report (DER) must _ be completed to evaluate the condition and provide corrective action.
If on the other hand the evaluation shows there is no adverse ef fect, then the PM can be rescheduled to be worked at a later date. Using-this method of evaluating Priority A PM activities to determine adverse ef fects before rescheduling is authorized provides added assurance that critical PMs are completed and alleviates any PM backlogs by rescheduling the activity. This process is applied to all Priority A PMs, including the 757 PMs identified during the August 1987 evaluation.
Item 3 What actions you have taken in the area of justification for postponed PM activities, in that the evaluation documented on the " Incomplete PM.
Form" will be based on defined engineering criteria; recognizing that the evaluation should include the affect on the operability and reliability of the component and associated systems.
Detroit Edison Response The PM evaluation form requires the evaluator to document w'nat the plant reliability and operability impacts would be and what the safety significance is if the PM activity was not performed. The form
Enclosure to NRC-87-0268 Page 5 requires the approval of an SRO (currently licensed at Fermi 2).
Additionally, the Superintendent. Maintenance and Modification and an engineer concur with the justification to reschedule any Priority A PMs.
This review process was selected :Un lieu of predefined criteria-because the variety and scope of PM activities precluded development of predefined criteria. As discussed previously, should rescheduling not be justifiable, a Deviation Event Report (DER) is ' initiated.
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