NRC-88-0094, Forwards Results of Util & S&W Investigations of Allegations Re Control Practices Discussed in NRC 880125 & 0212 Ltrs

Forwards Results of Util & S&W Investigations of Allegations Re Control Practices Discussed in NRC 880125 & 0212 Ltrs

ML20207A913
Person / Time
Site:	Fermi
Issue date:	04/19/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20206L553	List: ML20206L549 ML20206L559 ML20206L565 NRC-88-0094, Forwards Results of Util & S&W Investigations of Allegations Re Control Practices Discussed in NRC 880125 & 0212 Ltrs
References
CON-NRC-88-0094, CON-NRC-88-94 NUDOCS 8804250252
Download: ML20207A913 (6)

Text

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April 19, 1988 NRC- 88-0094 i U. S. Nuclear Regulatory CormisJ ion ,

Attention: Document Control Desk '

Washington, D. C. 20555 Referencest 1) Fermi 2 [

NRC Docket No. 50-341 NRC License No. NPF-43

2) NRC letter to Detroit Edison, dated January 25, 1988

3) NRC letter to Detroit Edison, dated February 12, 1988

Subject:

Material control Allegation Allegations regarding material control practices at Fermi 2 were verbally transmitted and confirmed by reference 2.

Further  !

allegations were transmitted in reference 3. All of the concerns identified in both letters have betu investigated and corrective i actions are being taken as necessary. The itens contained in reference 2 were investigated by an independent team from Stone &

Webster Engineering Corporation. The subsequent concerns contained in ,

reference 3 were investigated by Detroit Edison personnel. The l attachment to this letter contains the results of both investigations.

The allegations have been grouped into eight seneral categories.

Specific findings in each of the general categories will be addressed within this response. Some of the findings from the investigations are not identical to the original concerns, but were identified during the investigation.

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. ?mC-88-0094 Page 2 If you have any questiona, Detroit Edison will discuss them at your conveniense. For further information on thene catters, please contact Robert Stafford at ('13)

586-5618.

Sincerely.

Attachment cct A. B. Davis R. C. Knop

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T. R. Quay W. G. Rogets Region III t

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Attachment to NRC-88-0094

. Page 1 ATTAC11 MENT This document is a summarization of the findings from the investigations relating to allegations about material control practices at Fermi 2. The allegations have been grouped into eight general areas of concern. Each of the specific findings in the general areas will be addressed in this response.

1. Concerns Expressed About Engineering Evaluations Conducted by the Material Engineering Group (MEd)

a. The MEG Spare Parts Reference System (SPRS) review methods were

found to be incomplete. The irvestigation is being performed in accordance with the plant nooconformance program under deviation event report (DER) 88-0015. The significant data portions will be reviewed and administrative controls are being revised. Also, as an interim measure NQA is currently performing an additional review of all "Q" and commercial 4

quality parts when SPRS is referenced on the Requisitions on

, Stores form to verify that they are appropriate for the application. The practice of verifying parts by means other than SPRS will continue until SPRS has been validated.

b. NQA had previously identified shelf life discrepencies in Audit Report A-QS-P-87-35 and some of the allegations appear to address this same concern. Based on the investigation, some related items which are being addressed via Audit Finding l Report A-QS-P-87-35-01 and DER 88-0585 are shelf life for

safety class 1M applications. Safety class 1H components are

, those that can augment the function of a safety system or their failure could jeopardize the safety function of a safety related component or system. Also, shelf life for consumable j material and non-stock material is being addressed as part of

DER 88-0585. Evaluation of these discrepancies is expected to

be completed within May of 1988.

c. HEG personnel failed to follow procedures by not issuing a

, Potential Design Change when a part number was changed. This I

is being addressed by DER 88-0053. In the future, in d

accordance with engineering procedures. MEG will issue a Potential Design Change for evaluation when a part number is

changed. Also related to this concern, non-Q parts

.; specifications were allewed to be changed by Procurecent without Engineerfoe approval prior to 1986. This is not a I

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( (' j o Attachment to i URC-88-0094

. Page 2 i

concern for Q and commercial quality parts and is being ,.

addressed by DER 88-0239.  :

d. A potential deficiency is still being investigated where KEG ,

may have specified a nonconservative shelf life between March  ;

9.1987 and January 5.1988 for equipment qualification items. l This is being addressed by DER 88-0166. Tho evaluation of this potential deficiency is expected to be completed in May of  :

1988. This deficiency was not part of the allegations, but was  ;

discovered during the investigation by Stone & Webster,

e. None of the other concerne in this area were substantiated upon  ;

investigation, j

2. Plant Control and Implementation Concerns

a. The Requisition On Stores (ROS) forms have not been completed  !

in accordance with their controlling procedure. 12.000.029.

This is being evaluated and resolved via DER 88-0017. As part of the resolution of this problem, the initiators of ROSs  ;

received training on the requirementa for completing the form.

b. Discrepancies were observed in the ROSs associated with controlled materials. These are being addressed via DER 88-0585 and are expected to be evaluated within May of 1988.  :

Additionally, the use of Furmanite which is a controlled

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material was previously addressed in DER 87-275. SPRC was L revised to state that Furmanite must be evaluated by the l engineering staff for each appilcation in the future.

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c. No other concerns in this area were substantiated upon  :

investigatien.  :

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3. MEG Supervision Concerns i

a. The Stone & Webster team did have concerns with the timeliness '

of SPRS problem resolution. Resolution of SPRS accuracy is now being addressed by DER 88-0015. Actions in this area were j described in pcrt 1.a. }

b. KEG supervision had issued a memorandum which conflicted with [

the approved procedures with regard to placing parts on hold pending a complete design document review for part number l changes. Investigation determined that the memorandum was '

issued prematurely since it described actions being included in  !

a proposed revision tc a procedure. The revised procedure is l

now scheduled to be a; proved by May 1.1988 to reflect the  ;

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, Attachment to NRC-88-0094

. Page 3 content of the memorandum. DER 88-0088 is addressing the use i of memorandums by MEG. [

c. None of the other concerns in this area were substantiated upon  ;

investigation. i 4 SPRS Concerns t

a. SPRS was confirmed not to have been accurately maintained.

only a small percentage of the inaccuracies could lead to ,

safety problems. Pecults of an investigation of a random sample of SPRS entries for safety related appilcations [

indicated at least a 96% confidence of an error rate of less  !

than 5%. For the investigation, an error was defined as an [

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, SPRS entry which would lead to a field hardware problem which [

could adversely affect the safety related function of the l component. Actions are being taken as necessary to verify that  !

parts used in safety related applications are acceptab1 'y ,

means other than solely SPRS until SPRS has been valida  ;

This is being addressed via DER 88-0015 and actions are being i taken are described in item 1.a. (

b. A specific SPRS inaccuracy cause was that design change ,

procedures did not specifically require updating of the SPRS. '

I This is being addressed in DER 88-0015 and the actions being taken are deceribed in item 1.a. f l c. Another specific ESRS inaccuracy (non-safety related) was apparently due to an inadequate review that wts performed in i 1981. SFRS reflected the 1981 information which dif fered from [

the Master Instrument List (MIL). This deviation is being i addressed via DER 88-0032. The procedure for the technical  !

review of procurement documents (NE 6.11) currently includes ,

Le MIL as a docunent the evaluator refers to when performing i the technical review.  !

d. None of the other concerns in this area were substantiated upon investigation, l

5. Concerts Related to Timeliness of Resolution of Nonconformances I

a. The timeliness of nonconformance resolution had been previously  ;

recognized as an atea of concern. Consequently, much management and plant personnel attention is currently being  ;

devoted to timely DER resolution. The current DER program is [

considered to be adequate. DERs are now reviewed by the Plant Manager who assigns the appropriate priority level for the i

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!!RC-88-0094

,. Page 4 response. In all caces. the response cust be within 30 days.  !

Each assigned evaluating organization is responsible for j tracking and/or implementing the corrective actions.

The Plant Safety Group is responsible for verifying that timely ,

responses are received. Additionally. Plant Safety verifies the adequacy of the remedial corrective action and corrective

• actions to prevent recurrence along with the Plant !!anager. [

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6. MIL Concerns

a. The allegation regarding the MIL not reflecting plant [

conf *guration changes made because of SPRS information was .

addressed in item 4.c. of the letter. For the example given, 1 the MIL was determined to be correct with respect to the design j J configuration and SPRS was incorrect.  ;

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). QA Program Concerns [

s. This concern was not substantiated upon investigation. '

8. Uncategorized Concerns

a. Two SAFETEAM reports on use of cuntract persor.nel and training of new employees for shelf life review were reviewed and ,

a determined to be satisfactory. j i b. Item g. of reference 3 was not sufficiently clear as to the ,

1 esaning of the concern. However. Detroit Edison believes it to l be a restatement of the concerns regarding SAFETEAM which is i i item 8.a. [

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Docket No. 50-341 RIII-88-A-0001  !

l The Detroit Edison Company

ATTN

B. Ralph Sylvia i

Senior Vice President i

.1 Nuclear Operations 6400 North Dixie Highway i Newport, MI 48166 Gentlemen: ,

i l This refers to the special inspection conducted by Mr. L. R. Wharton of 4

the Office of Nuclear Reactor Regulation from March 8 through September 20,

1988, at the Fermi Plant, Unit 2, authorized by NRC Operating License No. NPF-43 and to our findings, which were discussed with Mr. W. Orser i[ and others of your staff at the conclusion of the inspection. This special inspection was conducted to follow up on previously identified items, review your response to the allegations regarding material control activities, and review the material control program. ,

During this inspection, certain of your activities appeared to be in violation }

i of NRC requirements, as specified in the Notice of Violation (Enclosure 1). A  ;

written response is required.

i

. The enclosed copy of our inspection report (Enclosure 2) identifies areas examined. 'dithin these areas, the inspector reviewed a sampling of procedures

- and representative records, observed related activities, and interviewed i licensee personnel, j l t i In accordance with 10 CFR 2.790 of the Commission's regulations a copy of i thisletter,theenclosures,andyourresponsetothisletterwIllbeplaced in the NRC Public Document Room. r The responses directed by this letter and the accompanying notice are not l

! subject to the clearance procedures of the Office of Management and Budget  !

as required by the Paperwork Reduction Act of 1980, PL 96-511.  ;

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The Detroit Edison Company 2 NOV 2 81989 1

] We will gladly discuss any questions you have concerning this inspection.

• Sincerely, R. C. Knop, Chief ReactorProjectsBranch3

Enclosures:

, 1. Notice of Violation

2. Inspection Report i No. 50-341/88008(DRP) cc w/ enclosures:

Patricia hthony, Licensing P. A. Marquardt, Corporate Legal Department DCD/DCB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII

< Ronald Callen, Michigan Public Service Commission l Harry H. Voight, Esq.

Michigan Department of Public Health Monroe County Office of Civil Preparedness PDR i DCS

QAB Reading 1- JWRoe NRR

! JAZwolinski,NRR

. SHWeiss, NRR FCHawkins, NRR u

o i i i NOTICE OF VIOLATION The Detroit Edison Company Docket No. 50-341 4

As a result of the inspection conducted between March 8 and September 20, 1988, '

and in accordance with Appendix C to 10 CFR Part 2, "General Statement of Policy 4

and Procedure for NRC Enforcement Actions (1987)," the following violations  !

vere identified:

1. Appendix B to 10 CFR Part 50, Criteria III, as implemented by the Fermi [

Unit 2updatedFinalSafetyAnalysisReport(UFSAR)lonofstandardSection 17.2.4.2, [

requires design reviews be performed for the select ,

commercial or previously approved items with safety-related functions 1 to ensure that the characteristics of such items sitisfy the requirements i of the intended application and that appropriate quality standards are [

clearly delineated, j Contrary to the above, the engineering evaluations used to select diodes, valves and gears that were not safety-related for applications that were

, l j safety-related did not ensure that the iter.s' critical characteristics f satisfied their intended performance requirements, j i

This is a Severity Level IV violation (Supplement I).

j 2. Appendix B to 10 CFR Part 50, Criteria XV, as implemented by the Fermi

Unit 2 UFSAR, Section 17.2.15, requires that nonconforming items in storage i i be clearly identified with appropriate tags or other appropriate mcasures t 4

to indicate unacceptable status and segregated until proper disposition has i been made, i Contrary to the above, safety-related Okonite tape, RTV foam, and  !

- grout with expired shelf lives were stocked in the warehouse without [

being clearly identified as unacceptable or segregated. [

l l This is a Severity Level IV violation (Supplement I).  !

Pursuant to the provisions of 10 CFR 2.2C1, you are required to provida a I

' written response to the Region III Office of the Nuclear Regulatory Cosiission, I I within 30 days of the date of this notice. Your reply should include for }

each violation (1) the correctiva action taken and the results achieved,  ;

l (2) corrective action to be taken to avoid further violations, and (3) the  !

' date when full compliance will be achieved. Consideration mA be given to I

( extending your response time for good cause shown. l l f I

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! Date p R. ReactorProjectsBranch3 C. Knop, Chief j l

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U.S. NUCLEAR REGULATORY C0liMISSION REGION III Report No. 50-341/88008(DRP)

Dockat No. 50-341 License No. NPF 43 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name: Fermi 2 Inspection At: Fermi 2 Site, Newport, Michigan Inspection Conducted: March 8 througt September 20, 1988 Inspector: L. R. Wharton l

Reviewed By: F. C. Hawkins, Chief Quality Operation Section, NRR Approved By fNh tL W. Cooper, lef

.P/

Projects Section 3B D' ate Inspection Summary Inspection from March 8 to September 20, 1988 (Report No. 50-341/88008(DRP)J Area Inspected: An inspector of the Nuclear Regulatory Commission's (NRC's)

Office of Nuclear Reactor Regulation (NRR) conducted a special announced ,

inspection of the circumstances with regard to and licensee actions in r response to material control allegations that were reported to the NRC in January and February 1988.

Results: Two violations were identified (See Sections 3.7 and 3.131. and three open items wert identified (See Sections 3.1, 3.3, and 3.7). Open ,

items are matters that have been discussed with the licensee, will be ieviewed '

further by the inspector, and will involve some action on the part of the NRC, the licensee, or both. [

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e DETAILS

1. Persons Contacted

a. Detroit Edison Company D. Gipson, Plant Manager

• W. Orser, Vice President, Nuclear Operations

• S. Catola, Vice President, Engineering and Services B. Sylvia, Group Vice President "L. Goodman, Director, Licensing

• T. Riley, Supervisor, Compliance

• P. Anthony, Licensing, Compliance Engineer

• R. Stafford, Director, Quality Assurance L. Grant, Senior Erigineer, Quality Engineering Section

• W. Ackerman, Senior Engineer, Quality Er.gineering Section J. Fischer, Senior Inspector, Plant Safety L. Bugoci Associate Engineer, CA Program Assurance

• R..May, Director Nuc

• R. Bryer, Supervisor, lear Material ManagementMaterial Engineering Grou

. C. Emanuelle, Principal Engineer Material Management Division .

Y.Sabir,SeniorEngineer, Materia 1 Management H. Valenta, Engineer, Materials Management D. Prakash, Engineer, Plant Engineering Section B. Stone, Maintenance Suppcrt Engineer, Maintenance Department J. Bragg, Supervisor, Plant Quality Assurance - Quality Control B. Hravatic, Principal Buyer, Nuclear Procurement S. Kremer, Supervisor, Procurement Section

5. Hassoun, Senior Engineer, Plant Engineering Section G. Sharma, Principal Engineer, Plant Engineering Section T. Bird, Senior Quality Specialist, QA Program Assurance J. Shafer, Supervisor, General Materials R. Root Supervisor, Nuclaar Tools Section, Maintenance L. Washington,AssistantNuclearMaterialsGeneralSupervisor S. Vandevelde, Materfals Clerk, General Materials

b. U.S. Nuclear Regulatory Commissior.

• R. Wharton, QJality Operations Enginee*, NRR

• W. Rogers, Senior Resident Inspector, Fermi 2

• S. Stasek, Resident Inspector, Fermi 2 P. Pelke, Project Irispector, Region III

• F. Hawkins, Chief, Quality Operations Section, NRR

• Denotes those personnel who attended the exit on September 20, 1988.

The inspector also interviewed -*hers of the licensee's staff during this inspection.

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2. Backg n _ on Material Control Allegations In January and February of 1988, a series of allegations was reported to the NRC Region III Office with regard to material control practices at Fermi 2. There was a total of 16 allegations, 13 by one alleger ar.d 3 by another. On January 6, 1988, two NRC inspectors conducted a sample inspection of the allegations. Upon confirmation of some of the alleger's concerns, the allegations were submitted to the Detroit Edison Company (DECO) for investigation and disposition. The licensee established a task force to investigate the allegations, evaluate the impact of these allegations on nuclear safety, and deterraine the appropriate actions for resolution to any resulting problems. The licensee had an independent contractor perform part of the investigation. The licensee identified and documented additional problems that surfaced du,'ng this effort.

The results of the licensee's review are documented in a letter dated April 19, 1988 (attached).

On April 6 and 7, 1988, the NRC inspector met with both allegers to obtain as much specific information as possible regarding the alle.ations. These interviews were transcribed. Each allegation consisted of technical concerns related to material control practices and program implementation.

The intent of this inspection was to review the circumstances surrounding the technical concerns, determine whether or not the allegations were substantiated, and address any resulting technical issues.

3. Allegation Review (AMS No. RIII-88-A-0001) 3.1 Allegation No. 1 Components that were not safety-related and had not been evaluated by the material engineering group (MEG) were installed in the plant in safety-related applications.

NRC Inspection Scope and Results During a transcribed interview conducted by the NRC, the alleger expressed conccrn that items that were not safety-related had been instd ied in safety-related applications without a technical review by the MEG to determine their acceptability. The alleger further stated that these items had been installed in safety-related applications for up to two years before they were discovered and documented on deficiency event reports (DERs). The alleger was unable to identify additional examles other than those that had been documented by the licensee on DERs. The following DERs were identified:

a. DER NP 85-324, "Non-Q Equipment Installed in QA-1 System"

b. DER 87-049, "Non-Q Component Used in Q Application"

c. DER 87-055, "Non-Q Components in Q Application"

d. DER 07-109, "Non-Q Lube Oil Ciralation Pump Motor in Safety-Related Application"

e. DER 87-361, "Non Safety-Related Actuator Diaphragm installed in Safety-Related Application"

f. DER 87-381, "Ina:iequate Review of Parts for Safety-Related Applications" 3

The NRC inspector reviewed these DERs with regard to components that are not safe?.y-related being installed in safety-related epplications and determined that all the DERs, except DER 87-381, addressed specific misapplications of nonsafety-related components. DER 87-381 identified a programmatic deficiency regarding Procedure 12.000.29, Revision 17, Step 6.2.4.2, which allowed parts that are not :sfcty-related to be used in safety-related applications without an MEG evaluation to determine the acceptability of the proposed part. The licensee had issued Procedura 12.000.29, Revision 18, on November 10, 1987, to specify that a technical evaluation by MEG is required for a part to be used in a safety-related application. Additional action taken in response to DER 87-381 is specifically addressed in Section 3.4 of this report (Allegation No. 5).

As part of its investigation of the material control allegations reported "

to the NRC, the licensee reviewed several requisitions of stores and found that they were incomplete. The licensee discovered an instance where it had not complied with Procedure 12.000.29, Revision 18, and documented this in DER 88-0017. DER 88-0017 further related a question as to the adequacy of the reviews of the issue document (requisition on stores) portion of the safety-related work packages performed by the Production Quality Assurance (PQA) Section. The licensee determined that the proposed action to ensure correct installation of parts, as noted in DER 87-381, also was appropriate for the procedural r.oncompliance portion of DFR 88-0017.

Although the licensee determined that PQA personnel had adequately reviewed the issue document portion of the work package to verify use of the correct material, Procedure NQAP 0503, "Review of Work Packages," was revised to clearly define PQA's review responsibilities and to more closely ensure that administrative deficiencies were identified.

On the basis of the NRC inspector's review, it appears that the licensee's actions taken to correct the programmatic deficiencies are adequate, and if completely implemented, these actions will prevent components that are ,

not safety-related from being misapplied in the future. However, the inspector is concerned that part of the licensee's proposed resolution to DER 87-381 was not sufficient as planned. The technical review of Requisition of Stores No. N0027143 that resulted from DER 87-381 was not appropriate remedial corrective action because it only addresses the identified discrepancy and does not consider any previous similar occurrences (components previously installed in the plant) and their potential effect on safety. Ad<iitionally, although MEG reviewed 25 requisitions of stores to determine any generic concern, they reported no results of the review but only indicated that the review was conolete.

It appears to the inspector as if the MEG relied on the Maintenance Department to respond to the DER without performing any independent investigation. Thus, the NRC inspector did substantiate this allegation.

Components that are not safety-related were installed in safety-relat d applications with .t the MEG performing a technical evaluation. Pend og the MEG's completion of appropriate corrective action in responn to DER 87-381, this matter is considered open (0 pen Item 50-341/88 08 @ ).

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.k 3.2 Allegation No. 2 Components that are identified as nor. conforming are always found acceptable by the MEG during their review.

NRC Instsc tion Scope and Results, During a transcribed interview conducted by the NRC, the alleger expressed concern because the MEG reviews of nonconforming components always resulted in the component being found acceptable by some method.

The alleger stated that the licensee routinely upgraded components that were not safety-related as a way to disposition nonconforming components.

The alleger provided as an exarr.ple an occurrence that had been previously identified and documented by the ilcensee.

DER NP 86-0287 documented where a valve stem that was not qualified by the American Society of Mechanical Engineers (ASME) was installed in an ASME Code Class 1 valve. According to the licensee, the stem had been originally ordered safety-related (Procurement Code Q), but the purchase order was erroneously changed to commercial quality (Procurement Code CQ).

The stem was procured CQ, then accepted and stoc,ad incorrectly as not safety-related (Procurement Code NQ).

( During its review of the work package (PN 21 No. 985307), the Maintenance <

Department identified that the valve stem did not meet the ASME Code requirements for the valve. The manufacturer was contacted and asked to provide nondestructive examination results

• d the certified material test report associated with the subject valve .. Concurrently, the licensee had a spare valve stem with the same heat ,. .ber tested; it failed to meet l The Systems Engineering Section performed Charpy V Notch test requirements.

a safety evaluation of the specific application of a nonconforming valve stem. The results of the safety evaluation and the inanufacturer's concurrence trade it possible for the licensee to allow the valve stem to remain installed temporarily (24 months) because the valve stem was installed in a locked open valve that was used only for maintenance purposes. The licensee replaced the valve stem as part of Temporary Modification 86-147 during the spring 1988 outage. This valve stem was later reclassffiad by the manufacturer as nonpressure retaining. The Authorized Huclear Insurance Inspector (ANII) concurred with this modification and signed off on the DER to close out this deficiency.

The NRC inspector revi v ed numerous engineering evaluations used to disposition nonconforming items ar.d noted none that appeared questionable.

Most items were designated as nonconforming while awaiting either required documentation or pending results of material veri <ication testing. The inspector also noted that the MEG had dispositioned nonconforming items as scrap or salvage (unacceptable) in their evaluations.

' On the basis of the details provided by the alleger and information reviewed, the inspector did not substantiate this ailegation. This f matter is sonsidered resolved.

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3.3 Allegation No. 3 The MEG revises shelf-life requirements for a specific component, but the shelf-life requirements for identical comnonents stored in the warehouse arn not similarly revised.

NR': Inspection Scope and Results During a transcribed interview conducted by the NRC, the alleger expressed concern that different shelf-life requirements (durations) existed for identical components. The alleger stated that when the MEG revises shelf-life requirements, the revision is only applied to that specific component and to future purchases and that identical items are stocked in the warehouse with different shelf-life durations. The alleger did not provide any specific examples of this concern.

The NRC inspector reviewed engineering evaluation disposition forms (EEDFs), the spare parts reference system (SPRS) parts expiration report, warehouse file stock cards, and material stored in warehouses A and 8 to verify that shelf-life requirements were properly established, revised, and extended. The inspector reviewed DERs, HEG shelf-life policy memoranda, and QA audits and interviewed the coordinator of shelf-life items, the General Materials Supervisor, the MEG Supervisor, and other personnel to verify tat shelf-life requirements were understood and reflected established requirements.

Before being rotified of this allegation, the licensee had icumented this concern U an observation in Audit A-QS-P-87-35, "Quality Assurance Audit of NE/hnarials Engineering Group." MEG Shelf Life Policy Memorandum NE-NS-87-0082 (March 19, 1987) states that the policy regarding shelf-life is not to revise a previously established shelf life for material already stocked in the warehouse. The audit report stated that this practice results in different shelf-life durations for the same types of material.

The licensee pioposed no corrective action to this condition because it was noted as an audit observation and not an audit finding. In addition, the conflicting shelf life durations noted in the observation were more conservative than the manufacturers recommended shelf life. The audit observation resulted in two recommendations: (1) revise the MEG documentation file to reflect the MEG Shelf Life Policy Memorandum and (2) revise NE 6.13, ' Shelf Life Control," to incorporate the MEG Shelf Life Po! icy Memorandum requirements. At the time of this inspection, the MEG documentation file did not reflect the HEG shelf-life policy and the revision to NE 6.13 had not been completed. Additionally, the licensee reported that when shelf-life requirements are revised, the new requirements are not currently being backfitted to stored material.

On the basis of this review, the NRC inspector substantiated this allegation. The inspector is concerned that when the established shelf lives of items are conservatively revised (shortened) that the identical items with less conservative (longer) shelf lives remain in i

storage and are available for use until the end of their unrevised shelf life. If the reasoning used to shorten the shelf life of an item is

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technically valid, then that reasoning must hold true for all other

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identical items. Prudent engineering practice appears to dictate that shelf lives for all identical items should be the same. This concern was discussed with licensee personnel who stated that this practice will be discontinued. Pending NRC verification of the licensee's action, this matter is considered open (0 pen Item 50-3:i/88-08-02).

3.4 Allegation No. 5 Requisitions on stores, used to withdraw material from the warehouse, do not identify how the material is to be used.

NRC Inspection Scope and Results During a transcribed interview conducted by the NRC, the alleger expressed concern that when material is w.ithdrawn from the warehouse for maintenance activities that are not safety-r21ated, the specific applications are not identified on the requisitions. The alleger believes the plant identification system (PIS) number and work request number, tying the material csed to a specific activity, should be referenced on all requisitions. The alleger did not provide any specific examples of this concern.

Before being notified of this allegation, the licensee had documented problems with regard to the proper preoaration of requisitions on stores.

DERs86-009, 87-381, and 88-0017 identified procedural noncompliance, personnel errors, and lack of attention to detail by material suitability reviewers as the root causes of problems with preparation of requisitions on si. ores. DER 87-381 addressed the programmatic weaknesses that contributed to the problem. However, because the licensee has taken a comprehensive approach to improve the program this issue is still open.

The licensee's planned actions include (1) complete revision of Procedure P0M 12.000.029, "Material Issue and Return," (2) revision to the requisit.,n of stores (ROS) form to make it user friendly, (3) one-on-one training, for all R0S initiators, material suitability reviewers, and authorizers, and (4) periodic review of selected requisitions until the preparation error rate is acceptable (below 5 percent). The NRC inspector believes that when the proposed actions are completed, they should adequately address the programmatic weaknesses identified in the DER.

The NRC inspector selected approximately 50 recent requisitions of stores from the warehouse 8 file room. The requisitions included items with procurement code classifications of nonsafety-related (NQ), commercial quality (CQ), and safety-related (Q) components. Each R05 referenced a PIS number or work request number to provide direct correlation between the material or item and the specific maintenance activity in which it was used. The inspector did not identify any material accountability problems with material withdrawn from the warehouse.

l On the basis of thc review the inspector did not substantiate the allegation. This matter is considered resolved.

l 7

i 3.5 Allegation No. 6 Approximately 50 percent of the information in the spare parts reference system (SPRS) is inaccurate.

NRC Inspection Scope and Results During a transcribed interview conducted by the NRC, the alleger expressed concern that information listed in the SPRS was not accurate and, as a result, unacceptable parts were requisitioned from the warehouse and installed in the plant. The alleger gave several examples where incorrect parts had been requisitioned and later installed; these examples were all previously documented on DERs by the licensee.

The SPRS is a computerized list of cross-referenced information regarding stock items (spare and replacement parts) that are available from the warehouse for installation in the plant. The list includes data, such as part descriptions, procurement codes, part numbers, approved applications, and other user information. The purpose of the SPRS is to assist material users in identifying the proper item to be requisitioned from the warehouse for any specific use.

Before being notified of this allegation, the licensee had documented numerous instances where the SPRS data base was inaccurate. In these instances, most of the inaccuracies were identified as data entry errors and were not believed at the time to have resulted in the requisition of any incorrect stock items. Later, during the resolution of DER 88-0015, the licensee noted that there was no mechanism for routinely incorporating the resulting part changes into the SPRS data base when engineering design packages and as-built notices (both types of design changes) were implemented. This weakness, in combination with the data base entry inaccuracies discussed earlier, contributed to the issuance of unacceptable parts from the warehouse for installation in the plant.

The licensee's immediate corrective action to resolve this weakness in the SPRS was to discontinue the use of the SPRS as an independent reference or source of information for determining the acceptability of a part for a proposed application. Licensee personnel stated that the restricted use of SPRS would continue until the accuracy of the SPRS is validated. As an interim measure, quality control group must review all work packages that require safety-related or commercial quality parts to verify that use and application of the part is consistent with the plant's design-basis requirements. Additionally, the licensee established a task force consisting of quality engineering, maintenance, and materials engineering personnel. The task force was assigned to address the SPRS programmatic dtficiencies and develop a plan to update and verify the SPRS data base (SPRS validation plan).

The licensee performed Surveillance 88-0026, "Spare Parts Reference System," to determine the accuracy of the SPRS. A random sample of 100 quality assurance Level 1 stock components was selecteo and reviewed to verify that the MEG had approved the applications of these components 8

and to verify the accuracy of SPRS data. The errors that were found with the MEG files and SPRS data were subsequently addressed b 88-0511, "NoDocumentedApprovalofComponentApplicationinSPRS.yDER The DER is still open.

The NRC inspector reviewed the SPRS data base to verify the accuracy of selected data field entries. The inspector also reviewed the task force's efforts, related surveillances, DERs relating to SPRS inaccuracies, and the proposed validation plan developed to resolve DER 88-0015. The validation plan addressed the major goal of the SPRS, which is to ensure that spare and replacement parts are properly designated so they can be accurately requisitioned and installed. The inspector reviewed the detailed instruction to the plan and found it technically adequate to accomplish the objective of verifying the applicable SPRS data field. However, the instruction needs to be formally approved and properly implemented.

On the basis of the review, the inspector substantiated this allegation.

SPRS information was inaccurate and was used to requisition parts for installation in the plant. The licensee's proposed SPRS validation plan, if properly implemented, should address the issue. The licensee had committed to completing the SPRS validation in response to a previous NRC violation (Violation No. 50-341/88-06-03). This violation involved the installation of incorrect parts in that a diesel fire pump alternator was replaced with an alternator of different make and number without being evaluated for suitability. NRC review of the licensee's corrective actions is currently ongoing.

3.6 Allegation No. 7 When nonconforming components are identified, identical components stored in the warehouse are not segregated.

NRC Inspection Scope and Results During a transcribed interview conducted by the NRC, the alleger provided

• i.wo examples that supported his concern about identical components to those identified as nonconforming not being segregated in the warehouse. Both had been previously documented by the licensee in DERs NP-86-287 and 87-109. The alleger stated that the licensee of ten separately ducks identical items and assigns them different procurement code classifications, such as not safety-related and safety-related.

The NRC inspector reviewed the referenced DERs. DER NP-86-287 identified an instance where a valve stem that did not meet ASME Code requirements was incorrectly installed in a ASME Code Class 1 valve application. The DER was later dispositioned use-as-is based on safety review and vendor concurrence with the application. For more specific information regarding this DER, see Section 3.? of this report (Allegation No. 2).

Similarly, DER 87-109 identified an instance where a motor that was not safety-related was used in a safety-related application. The li shorsepower lube oil circulating pump motor was classified on the Q-list as 9

e safety-related because it is electrically fed from a QA Level 1 power supply. Although the motor was stocked as though it was not safety-related, the original technical and quality requirements had been imposed by the supplier, Colt Industries. An engineering evaluation to determine if the motor could be used in the safety-related applicatior, was performed by the Maintenance Department. Maintenance personnel compared the installed motor with the original motor and found that both motors were identical except for the code letters and bearing type designation. The differences between the two motors were determined to be inconsequential, and the motor was dispositioned use-as-is based on the engineering analysis and vendor information.

The NRC inspector could not make a connection between the allegation and the examples that were provided. In both cases, the installed items were nonconforming because they failed to meet the requirements of a specific incorrect application, not because the items were inherently deficient. There was no need or requirement to segregate the identical items (stems and motors) stored in the warehouse because they were not intended for the same applications as the items provided in the examples.

On the basis of the review, the inspector determined that the practice v stocking identical items with different procurement codes is allowable as 'ong as proper controls exist to ensure that items are properly [

res isitioned and installed. However, the inspector notes that a violation for failure to identify and segregate nonconforming items in the warehouse is identified in Section 3.13. This matter is considered resolved.

3.7 Allegation No. 8 MEG supervision occasionally disregarded procurament program requirements.

NRC Inspection Scope and Results  !

During a transcribed interview conducted by the NRC, the alleger gave two  !

examples of verbal directives purportedly given him by MEG supervisors to bypass the required procurement review. The alleger also provided MEG l policy memoranda to support his concerns.

The MEG is responsible for reviewing procurement actions to ensure that technical and quality requirementt are appropriately addressed for items and services that are both safety-related and not safety-related. In both examples given, the alleger stated that the required activities were ,

accomplished, contrary to the verbal directives. The alleger did not provide enough specific information about the two instances to permit the NRC inspector to independently verify that the work had been properly accomplished.

t In an attempt to identify other instances where directives were given to bypass required activities, the inspector interviewed selected MEG personnel. They stated that they were not aware of any verbal directives l

10

given by MEG supervision to bypass required HEG procurement activities.

Thus, no additional similar instances were identified.

During its investigation of this allegation, the licensee conducted ,

a surveillance of MEG activities. As a result, the licensee issued DER 88-0087, "MEG Procedures Do Not Require Retention of Technical Review Documents," and DER 88-0088, "Failure to Comply With FMD PRI, Revision 0, Procedure, Manuals and Orders." DER 88-0087 referred to instances where MEG file information and checklists related to engineering evaluations had not been treated as quality assurance (QA) records. The proposed corrective action to resolve the deficiencies identified on DER 88-0087 (still open) required escalation to licensee management for MEG to agree with the action recommended by the Plant Safety section. These actions include (1) revising Procedures NE 6.11, "Technical Review of Procurement Documents," NE 6.12 "Engineering Evaluation of Onsite Material," and NE 6.14, "Spare Parts Reference System," and (2) submitting the existing backlog of MEG documents to the Information Systems group as QA records by April 1, 1989. It appears to the NRC inspector that the action proposed for the resolution to DER 88-0087 will be sufficient if properly implemented.

DER 88-0088 referred to instances where the MEG had issued policy memoranda

, that conflicted with approved rocurement procedures. One example, MEG Policy Memorandum NE-88-0002, p' Shelf-Life Policy," specified a shelf-life start date that conflicted with that specified in Procedure NE 6.13, Revision 0, "Shelf-Life Control." The immediate action was to revise the ,

MEG policy memorandum to ensure its consistency with the approved procedure.

However, the lionsee stated in the DER that the underlying cause of the problem was that policy memoranda had been und by MEG in lieu of controlled procedures. To correct the preolem of DER 88-00M (still open), the licensee proposed i'o incorporate the appropriate M6 policy memoranda into procedures by September 30, 1988. This proposed action also required  !

management attention before the MEG and the Plant Safety section came to agreement. The NRC inspector believes that the action proposed to resolve DER 88-0088 will be satisfactory if properly implemented.

The NRC inspector reviewed DERs and MEG policy memorands to evaluate the l MEG's interface with the procurement process. The inspector interviewed MEG personnel regarding HEG file information and reviewed engineering evaluation disposition forms (EEDFs) and checklists to verify that technical and quality requirements were properly established for safety-related items  !

and services. The inspector found that EEDFs used to upgrade commercial quality (CQ) mater.'1 did not establish specific engineering i l

criteria and verification requirements with regard to the performance characteristics of the items. The EEDFs rationalized that verification of the part number would ensure that the item was c&pable of performing l

its intended safety-related function. The following are typical examples '

l of CQ material that was upgraded on the sole basis of part number

verification:

I

a. EEDF 4986, limitorque worm gear

b. EEDF 4988, limitorque worm shaft gear j

c. EEDF 4978, thyrector diode -

l l d. EEDF 5063, cage valve 11

's These failures to establish that materials, parts, and equipment that are essential to safety-related functions are reviewed for suitability of application and that appropriate quality standards are specified is considered to be in violation of 10 CFR 50 Appendix B, Criterion III (Violation 50-341/88-08-03).

On the basis of the review, the inspector determined that the MEG did not comply with the administrative controls established for the procurement program and that these deficiencies were properly documented by the licensee on DERs. Thus, that part of the allegation was substantiated; although, no instances were identified where MEG supervision instructed personnel to circumvent the procurement system in such a way as to affect installed equipment or components. Pending ceview of the specific actions implemented by DERs 88-0087 and 88-0088, this matter is considered open (0 pen Item 50-341/88-08-04),

3.8 Allegation No. 9 When the MEG reviews requisitions of stores to verify that commercial quality (CQ) electrical switches and relays are being properly applied, it does not consider the seismic properties of the parts.

NRC Inspection Scope end Results During the transcribed interview conducted by the NRC, the alleger expressed concern that the MEG's review of requisitions of stores for CQ switches and relays did not include a seismic evaluation. The alleger stated that the licensee dedicated CQ components for safety-related use without considering whether the intended application of the item required seismic properties. The alleger did not provide any specific examples of this concern.

The NRC inspector reviewed engineering evaluation checklists (EECs) to determine whether the licensee considered swismic requirements in its evaluations. ECCs are used for dedicating components for safety-related use. The inspector verified that seismic requirements were considered on each of the EECs that were reviewed. The inspector also reviewed DERs to j

- determine if the licensee had documented any deviations related to seismic i applicability or seismic qualifications of CQ components. No DERs related l

to seismic issues were identified.

On the basis of the review, the inspector did not substantiate this

(

allegation. The MEG does consi:.er seismic requirements in its reviews.

This matter is considered resolved, l

t i

3.9 Allegation No. 10 l

The material management system (MMS) is not updated and item stock l numbers are not changed when engineering design packages (EDPs) or as-built notices (ABNs) are implemented.

l 12 L

NRC Inspection Scope and Results During a transcribed interview conducted by the NRC, the alleger expressed concern that obsolete spare parts could be incorrectly installed in the plant because the M S is not updated to reflect changes in item stock codes. The alleger stated that spare parts are rendered obsolete as a result of part changes or replacements implemented by EDPs and ABNs.

The alleger gave an example of an obsolete Rosemount transmitter, Model 1151, that had been incorrectly installed in the plant, but did not provide the specifics of where the transmitter had been installed or whether the incorrect installation had been documented on a DER.

The NRC inspector interviewed Nuclear Procurement section personnel and discussed the use of the MMS with them. The HMS is a Detroit Edison Company (DECO) computerized inventory control system used primarily for contracts management, budgeting purposes, and tracking accounts payable.

The HMS is not a source of design-basis information and the licensee does not use ths system to select parts for installation.

The NRC inspector reviewed DERs to determine if the example provided by the alleger had been previously documented by the licensee. DER 87-139 documented a problem that fit the description related by the alleger. The DER stated that the use of an obsolete stock code had resulted in the requisitioning of scrapped material, an 0-ring, for installation in a Rosemount transmitter. Two different stock codes, one obsolete and the other reclassified (new), had both referenced the vendor's part number for the 0-ring. The obsolete stock code had not been deleted in the SPRS; therefore, the scrapped 0-ring was still approved for installation.

A review was performed by MEG to verify the suitability of the installed item for its application.

On the basis of the review, the NRC inspector found no clear connection between the allegation and example provided by the alleger. The allegation described MMS updating problems that could potentially affect correct part installation. The exaniple depicted an SPRS updating problem that resulted in an incorrect installation. The inspector determined that this concern is of no safety significance because the HMS does not affect part application, installation, or design-basis configuration control. This issue is considered resolved. However, with regard to the concern that obsolete parts can be incorrectly installed in the plant, the inspector determined that this concern is valid. Installation of incorrect parts in the plant becauce of an inaccurate SPRS data base is addressed in Section 3.1 of this report (Allegation No. 1).

1 3.10 Allegation No. 11 The DER process is inadequate and unable to resolve problems. Ccerective actions taken by MEG in response to DERs do not address the root cause of the deficiencies.

13

NRC Inspection Scope and Results During a transcribed interview conducted by the NRC, the alleger expressed concern that the DER prccess was ir, adequate because problems identified by DERs were not resolved. As an example, the alleger referred to DER 85-324, which the MEG completed in 1986. The alleger maintained i. hat the DER was not properly resolved and did not, correct the parts classification problem.

Before being notified of this allegation, the licensee had made numerous changes in the DER process. These changes have continued throughout the first half of 1988. The process was initially revised through the issuance of FIP-cal-01-SQ, "Deviation and Corrective Action Reporting,"

Revision 0, December 30, 1987. The revised procedure (1) required evaluation and tracking of regulatory and industry findings and notifications; (2) required evaluation for adequacy of root cause determination, disposition, and corrective actions by the Nuclear Production Department after completion but prior to closure; (3) increased the Plant Manager's role to an in process review of DERs; (4) incorporated the LER process; and (5) incorporated the operating experience report program. This procedure (FIP-cal-01-SQ) was revised again on May 23, 1988. This latest revision (1) allows Nuclear Organization personnel to initiate DFRs anonymously, (2) adds provisions for escalating DERs when the initiating individuals and their supervisor cannot agree whether the DER should be processed, (3) adds guidelines for reporting events -

through '.he Nuclear Network, (4) allows for conditional release of items on hold, (5) adds a mechanism to identify DERs that are significant conditions adverse to quality, (6) expands the scope to include personnel safety items, (7) reassigns responsibility for DER number designation and~~

tracking to the Plant Safety Director, and (8) requires an SR0 to $creen DERs.

The NRC inspector reviewed various DERs related to material control to see if the responses routinely addressed root causes. The inspector also interviewed HEG, Plant Safety, and Quality Engineering personnel with regard to the DER process. For the DERs reviewed, the inspector noted that the MEG did not always completely respond to DERs. The NRC Open Item 50-341/88-08-01, referenced in Section 3.1, Allegation No. 1, is an example of an incomplete MEG response to a DER. However, improvement was noted on recent DERs. Other instances were noted of DER issues assigned to the MEG that required escalation by the Plant Safety group to management for agreement to proposed corrective action. The DERs referenced in Section 3.8, Allegation No. 8, are examples that required escalation to management. The evaluations of DER responses performed by the Plant Safety section sufficiently ensure that the underlying causes of deficiencies are addressed.

On the basis of the reviews, the NRC inspector found no connection between the allegation and the example provided by the alleger. The allegation dealt with the entire DER process. DER 85-324 identified a specific problem with the classification of General Electric parts and was not indicative of a programmatic breakdown of the DER process. To address DER 85-324, the MEG performed a complete evaluation of all stocked 14

-e General Electric parts and corresponding safety classifications; thus, the licensee's action to address the DER was proper and complete.

However, the inspector did substantiate this allegation to the extent that the MEG's response to OERs did not always address the root cause of the problem. It appears the licensee's substantial changes in scope definition and reassignment of responsibilities will improve the responsiveness and effectiveness of the DER process. This matter is considered resolved.

3.11 Allegation No. 12 The master instrument list (MIL) is not correct.

NRC Inspection Scope and Results During a transcribed interview conducted by the NRC, the alleger expressed concern that the MIL does not reflect the design changes as they are implemented by engineering design packages (EDPs) and as-built notices (ABNs). The alleger stated that when an instrument is replaced with a new or different model, the change does not apply to all identical instruments used in the same application. The alleger did not provide any specific examples of the concern.

The NRC inspector reviewed DERs to identify any incorrect MIL information that had been documented by the licensee. The inspector identified DERs 88-C016 and 88-0415 as being related to incorrect MIL information.

DER 88-0016 was written as a result of the licensee's investigative effort to address these allegations and identified a wrong component number in the MIL for a Rosemount transmitter. The same transmitter was listed in the SPRS and the MIL, but with different part numbers.

A field verification revealed the MIL to be in error. The underlying cause of the deficiency was attributed tc the old Nixdorf irout terminal /

program (data input), which did not allow verification of the input before the hard copy was printed. However, the hardcopy information was verified and maintained as a controlled document. The licensee corrected this problem by issuing ABN 7371 to update the MIL.

DER 88-0415 identified instrument set points documented in the MIL that were not consistent with the set points documented on the instrument specification sheets. The original set points for the B emergency diesel generator low level lube oil temperature alarm had never been changed because the Operations Department had determined that they were acceptable.

The corrective action was to issue an ABN reflecting the field set points.

Although it was thought to have been cancelled, an ABN (written in 1985),

had been issued and incorporated the new set points into the MIL. These DERs do not appear to indicate a programmatic breakdown that would have rendered the MIL inherently incorrect.

The MIL no longer exists because in March 1988 the licensee began consolidating the separate base configuration design documents, which consisted of the master instrument list (MIL), master valve list, Q list, and seismic qualification review team list. The accuracy of the individual i

15

design documents, such as the MIL, were not verified before they were combined to form the CECO data base because they were maintained as source documents for controlling plant design configuration.

The NRC inspector interviewed the Nuclear Engineering Division and Nuclear Production Division personnel responsible for implementing the guidelines for the data transfer and update. The inspector verified that each organization had defined a controlled process for updating their respective CEC 0 data fields. The inspector also reviewed selected CECO data fields to verify that plant equipment and identification had been incorporated into CECO from the MIL. The administrative controls established for transferring, updating, and maintaining the CECO data base appear sufficient.

On the basis of the review, the inspector did not substantiate the allegation. The lack of specific information provided by the alleger, in conjunction with the MIL's incorporation into CEC 0, precluded identification of any incorrect instrument listings. This matter is considered resolved.

3.12 Allegation No. 13 The DECO Engineering Research engineer, referred to by the alleger as the Warren Service Center engineer, maintains the approved / controlled '

materials list (A/CML) and is frustrated with trying to approve consumable material after it has been installed.

NRC Inspection Scope and Results The A/CML specifies limitations and restrictions for the applicability and use of consumable materials approved by the Nuclear Engineering /

Engineering Technology Section. The purpose of the list is to minimize '

the likelihood of equipment and system failures resulting from an environmentally assisted breakdown of consumables. Requests for changes to the A/CML are processed using an A/CML change notice. The list is maintained by a DECO Engineering Research engineer who works part time for the Nuclear Engineering / Engineering Technology Section at Fermi 2.

During a transcribed interview conducted by the NRC, the alle er stated that a DECO Engineering Research engineer responsible for rev ewing and approving consumable material to be added to the A/CML was frustrated by the Fermi 2 practice of requesting approval to add material to the A/CML after the material had been installed in the plant. The examples provided by the alleger were the use of furmanite for valve leak repairs and the use of castor oil as a cutting aid. The alleger did not provide specifics as to where the consumables were used, only that the furmanite example had occurred approximately 18 months ago.

The NRC inspector interviewed the Deco Engineering Research engineer to determine if consumable material was installed before it was approved for use. The engineer stated that he had been approving consumables for use at Fermi 2 for approximately four years and could not recall any 16

~~

e post-installation approval requests. He further stated that he did not '

feel he had been pressured to approve consumable materials for use at the plant.

The NRC inspector interviewed Nuclear Engineering / Engineering Technology Section personnel and discussed the use of the A/CML with them. The inspector also reviewed the A/CML and A/CML change notices to verify that appropriate restrictions and limitations had been imposed on the use of consumable materials. The inspector reviewed DERs to determine if the examples provided by the alleger had been previously documented by the licensee. The inspector identified DER 87-275 that was related to the use of furmanite. No DERs were identified that related to the use of castor oil. DER 87-275 documented a misapplication of the A/CML for the use of.furmanite for a valve leak repair. The problem had been initially identified by the NRC as a violation (Violation No. 50-341/87-31-01) because a safety evaluation had approved the use of furmanite for a 4 specific application based solely on its inclusion in the A/CML and not on the ability of the material to meet the requirements of the actual ,

application. The inspector determined that this example did not support the allegation that consumable materials are approved after installation

. in the plant.

On the basis of the review, the inspector did not substantiate this i allegation. This matter is considered resolved.  ;

3.13 Allegation No. 14* ,

The shelf-life program is not adequately implemented.

NRC Inspection Scope and Results ,

During a transcribed interview conducted by the NRC, the alleger expressed concern that 2500 items, some of which were purchased safety-related (Q),

have not had shelf-life requirements established by the MEG and that shelf-life reevaluations (extensions) were only performed on an emergency basis. The alleger further stated that the SPRS parts expiration report (shelf life expiration report) was inaccurate and that shelf-life durations were inconsistent for identical items. The concern regarding the

! inconsistency of shelf-life durations is addressed in Section 3.3 of this report (Allegation No. 3); the other concerns are addressed below.

Before being notified of this allegation, the licensee had performed an audit of the MEG's activities. The purpose of the audit was to verify the adequacy and effectiveness of the engineering activities perfor.med

by the MEG, which included the evaluation and control of shelf-life items, i

• Denotes allegations made by the second alleger.

I 17

The audit identified two findings: (1) items tagged with shelf-life expiration dates were not listed on the shelf-life expiration report and (2) quality control acceptance tags had not identified shelf-life expiration dates for stock items. Additionally, the audit identified one observation: identical shelf-life items have different shelf-life durations. Audit Finding Reports A-QS-P-87-35-01 and 02 were issued to evaluate the findings and to track the corrective action. At the time of the inspection, the observation had not been addressed.

The NRC inspector reviewed engineering evaluation disposition forms (EEDFs),

the shelf-life expiration report, warehouse file stock cards, the MEG activities, and material stored in warehouses A and B to verify that shelf-life requirements had been properly implemented. The inspector found that EEDFs for shelf-life extension were completed on an as needed (emergency) basis. For the EEDFs reviewed, the inspector found an acceptable justification was provided to establish and extend shelf-life durations. The justifications referenced shelf-life requirements for different categories of material as presented in MEG policy memoranda.

The licensee provided the Military Standardization Handbook MIL-HOBK-695 C, "Rubber Products: Recommended Shelf Life," as the technical basis for the shelf-life requirements delineated in the MEG shelf-life policy memoranda. Although the MEG shelf-life policy memoranda are not an appropriate reference for shelf-life determinations, the inspector determined that MIL-HDBK provided the necessary technical basis for shelf-life requirements. Additionally, the inspector verified that the shelf-life expiration report was inaccurate with respect to storage locations, shelf-life durations, and shelf-life expiration dates.

These inaccuracies were discussed with licensee personnel who stated that the report would be corrected.

Section 17.2.15 of the Fermi 2 UFSAR requires that nonconforming items in storage be clearly identified to indicate their unacceptable status i and be segregated until they can be properly dispositioned. During a l walkdown of warehouse B, the inspector noted the following safety-related material with expired shelf life that had not been identified as such by the licensee: (1) stock code 790-0533, Okonite tape; (2) stock l code 920-0587, RTV foam; and (3) stock code 101-0054, grout. These I failures to identify and segregate expired (nonconforming) shelf-life items are considered to be in violation of 10 CFR Part 50, Appendix B, Criterion XV (Violation 50-341/88-08-05).

On the basis of the review, the inspector has determined that the controls established for the shelf-life program are not adequately implemented. Thus the allegation is substantiated.

3.14 Allegation No. 15*

(

A quarterly inventory revealed that 200 feet of safety-related pipe could not be accounted for.

l l

t l

l l

, 18

NRC Inspection Scope and Results During a transcribed interview taken by the NRC, the alleger stated that there was no installation record for 200 feet of steel pipe that had been purchased for safety-related use at Fermi 2. The a11eger was concerned that if the licensee received a 10 CFR 21 notification the material could not be located. The alleger said there had been two DERs issued that would support his concern although he did not provide the specific DERs or any specifics on them.

The inspector interviewed Plant Safety section personnel with regard to the traceability requirements for safety-related material. Licensee personnel stated that traceability requirements for safety-related material only apply to that material used in safety-related applications. It was further stated that the steel pipe in question was assumed to have been used in an application that was not safety related. This assumption was based on the fact that the licensee procures all steel pipe safety-related (Q) and uses it for both safety-related and nonsafety-related applications.

If the pipe is used in an application that is not safety-related, its traceability is not maintained. The inspector reviewed several DERs to identify any that fit the description of the two mentioned by the alleger.

However, none of the DERs reviewed by the inspector documented the unaccountability of steel pipe.

On the basis of the review, the inspector did not substantiate the allegation. This matter is considered resolved.

3.15 Allegation No. 16*

All oils and greases that were previously in the shelf-life program are not included in the preventive maintenance program.

NRC Inspection Scope and Results During a transcribed interview taken by the NRC, the alleger expressed concern that the new guidelines that had been established for lubricants l

were not being followed. The alleger stated that tne responsibility to maintain lubricants, all of which were originally included in the shelf-life program, had been transferred to the preventive maintenance l program. He was concerned that because the transfer of responsibility I had never been formally or procedurally implemented, lubricants with l expired shelf lives were being issued for use in the plant. The alleger did not provide any specific examples of this concern.

The NRC inspector reviewed oil and grease pmventive maintenance activities and several DERs to determine if the licensee had documented any deviations from the established lubricant guidelines. Before being notified of this allegation, the licensee had issued DER 86-123, which was related to shelf-life extension for a stored gresse. To correct this problem, the licensee established two sampling programs to annually test lubricants, one for oils and one for greases. The NRC inspector verified that preventive maintenance personnel had performed the annual lubricant 19

• e sampling, which began in January 1987. As a result of the most recently performed lubricant samplings, two DERs were issued: DER 88-0077 documented unacceptable oil based on visible settling and separation in the simples and DER 88-0427 documented contaminated oil based on the results of the chemistry report that analyzed the samples. The licensee determined that the underlying cause of these deficiencies was oil contamination by intermixing, which occurred from the poor practice of drawing different types of oil through the same pump and piping system.

The licensee proposed to change the pumping scheme, discard any contaminated oil, and incorporate cautions against intermixing into the lubrication manual to prevent recurrence of this problem.

The NRC inspector verified that bulk-stored lubricants at the turbine building lube oil issue station and warehouse C (oil and grease warehouse) had been accurately identified and labeled. However, the inspector noted that lubricants had not been deleted from the SPRS shelf-life expiration report and that shelf-life expiration tags remained on the lubricant drums stored in warehouse C.

The NRC inspector interviewed warehouse and maintenance personnel and discussed the inclusion of lubricants into the preventive maintenance program. Questions were raised by the inspector regarding oil and grease shelf lives and the DECO Engineering Research Department (ERD) reports that established the shelf-life. In response to the questions, licensee personnel identified a problem with the implemented shelf-life for greases, which resulted in DER 88-1179 being issued to document the indeterminate quality of sealed grease stored in the warehouse. The root cause of the DER was a misinterpretation of ERD Report 86B73-7, which provided the basis and established the selection criteria for the lubricant sampling plan.

The licensee's immediate action was to have all sealed grease containers tagged and placed on hold pending sample analysis or disposal.

On the basis of the review, the inspector did not substantiate this allegation because lubricants are included in the preventive maintenance program. This matter is considered resolved.

4. Exit Meeting The inspector met with licensee representatives (denoted in Section 1) throughout the inspection and at the conclusion of the inspection on September 20, 1988. The inspector summarized the scope and findings of the inspection activities, and the licensee acknowledged the inspection findings.

The inspector also discussed the likely content of the inspection report with regard to the documents or processes reviewed during the inspection.

The licensee identified proprietary information that had been disclosed to the inspector during the course of the inspection. However, after discussions with the licensee, the inspector has determined that there is no proprietary information contained in this inspection report.

Attachment:

Detroit Edison Ltr NRC-88-0394 dated April 19, 1988 20

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O April 19,1988 URC-88-0094 U. S. Nuclear Regulatory Commiss ion Attention: Document Control Deck Washington, D. C. 20555

References:

1) Ferial 2 NRC Docket No. 50-341 NRC Licence No. NPF-43

2) NRC letter to Detroit Edison, dated January 25, 1988

3) NRC letter to Detroit Edison, dated February 12, 1988

Subject:

K1terial Control Allegation, Allegations regarding material control practices at Fermi 2 were verbally transmitted and confirmed by reference 2. Further allegationa were transciitted in reference 3. All of the concerns identified in both ic! tera have bem investigated and corrective actions are being taken is necessary. The items contained in reference 2 were invest / gated by an independent team from Stone &

Webster Engineering Corporation. The subsequent concerns contained in reference 3 were investigated by Detroit Edison personnel. T1.e attachment to this lett er contains the results of both investigations.

The allegations have been grouped into eight general categories.

Specific findings in each of the general categories will be addressed within thic responac. Some of the findings f rom the investigations are not identical to the original concerna, but were identified during the investigation, e, en n , nm ,

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April 19, 1988 j

. ImC-88-0094 Page 2 If you have any questions. Detroit Edison will discuss them at your convenience. For further information on these aatters, please contact Robert Stafford at (313) 586-5618.

Sincerely, Attachment cc A. B. Davis R. C. Knop

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T. R. Quay W. G. Rogers Region III

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o Attachm nt to NRC-88-0094

- Page 1 ATTACHMENT This document is a summarization of the findings from the investigations relating to allegations about material control practices at Fermi 2. The silegatinns have been grouped into eight general areas of concern. Each of the specific findings in the general areas will be addressed in this response.

1. Concerns Expressed About Engineering Evaluations Conducted by the Material Engineering Group (MEG)

a. The MEG Spare Parts Reference System (SPRS) review methods were found to be incomplete. The investigation is being performed in accordance with the plant nonconformance program under deviation event report (DER) 88-0015. The significant data portions will be reviewed and administrative controls are being revis ed . Also, as an interim measure. NQA is currently performing an additional review of all "Q" and commercial quality parts when SPRS is referenced on the Requisitions on Stores form to verify that they are appropriate for the application. The practice of verifying parts by means other than SPRS will continue until SPRS has been validated.

b. HQA had previously identified shelf life discrepancies in Audit Report A-QS P-87-35 and some of the allegations appear to address this same concern. Based on the investigation, some related items which are being addressed via Audit Finding Report A-QS-P-87-35-01 and DER 88-0585 are shelf life for safety class 1M applications. Safety class 1H componenta are those that can augment the function of a safety system or their failure could jeopardize the safety function of a safety related component or system. Also, shelf life for consuma)19 material and non-stock material is being addressed as part of DER 88-0585. Evaluation of these discrepancies is expectei to be completed within May of 1988.

c. MEG personnel failed to follow procedures by not issuing a Potential Design Change when a part number was changed. This is being addressed by DER 88-0053. In the future, in accordance with engineering procedures MEG will issue a Potential Design Change for evaluation when a part number is changed. Also related to this concern, non-Q parts specifications were allowed to be changed by Procurement without Engineering approval prior to 1986. This is not a

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'6' Attachm2nt to NRC-88-0094 Page 2 concern for Q and commercial quality parts and is being addressed by DER 88-0239.

d. A potential deficiency is still being investigated where MEG i- may have specified a nonconservative shelf life between March

9. 1987 and January S. 1988 for equipment qualification items.

This is being addressed by DER 88-0166. The evaluation of this potential deficiency is expected to be completed in May of 1988. This deficiency was not part of the allegations, but was discovered during the investigation by Stone & Webster.

e. None of the other concerns in this area were substantiated upon investigation.

2. Plant Control and Implementation Concerns

a. The Requisition On Stores (ROS) forms have not been completed in accordance with their controlling procedure, 12.000.029. ,

This is being evaluated and resolved via DER 88-0017. As part of the resolution of this problem, the initiators of ROSs received training on the requirements for completing the form.

b. Discrepancies were observed in the ROSs associated with controlled materials. These are being addressed via DER 88-0585 and are expected to be evaluated within hay of 1988.

Additionally, the use of Furmanite which is a controlled ,

material was previously addressed in DER 87-275. SPRS vas revised to state that Furmanite must be evaluated by the engineering staff for cach application in the future,

c. No other concerns in this area were substantiated upon j investigation.

3. MEG Supervision Concerns

a. The Stone & Webster team did have concerns with the timeliness t of SPRS problem resolution. Resolution of SPRS accuracy is now being addressed by DER 88-0015. Actions in this area were i described in part 1 a,

b. MEG supervision had isaued a memorandum which conflicted with

the approved proced"res with regard to placing parts on hold

, pending a complete design document review for part number I changes. Investigation determined that the memorandum was issued prematurely since it described actions being included in a proposed revision to a procedure. The revised procedure is now scheduled to be approved by May 1,1988 to reflect the i

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%' Attcchment no NRC-88-0094 Page 3 content of the memorandum. DER 88-0088 is addressing the use of memorandums by MEG.

c. None of the other concerns in this area were substantiated upon investigation.

4. SPRS Cor.nerna

6. SPRS was confirmed not to have been accurateAy maintained.

Only a omell percentage of the inaccuracies could lead to safety problems. Results of an investigation of a random sample of SPRS entrfes for safety related applications indicated at least a 96 confidence of an error rate of less than 5%. For the investigation, an error was defined as an SPRS entry which would lead to a field hardware problem which could adverse 1Ly affect the safety related function of the component. Actions are being taken as necessary to verify that parts used in safety related applications are acceptable by means other than solely SPRS until SPRS has been validated.

This is being addressed via DER 88-0015 and actions are being taken are described in item 1.a.

b. A specific SPRS inaccuracy cause was that design change procedures did not specifically require updating of the SPRS.

This is being addressed in DER 88-0015 and the actions being taken are described in item 1.a.

c. Another specific SPRS inaccuracy (non-safety related) was apparently due to an inadequate review that was performed in 1981. SPRS reflected the 1981 information which differed from the Master Instrument List (MIL). This deviation is being addressed via DER 88-0032. The procedure for the technical review of procurement documents (NE 6.11) currently includes the MIL as a document the evaluator refers to when performing the technical review.

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d. None of the other concerns in this area were substantiated upon I investigation.

! 5. Concerns Related to Timeliness of Resolution of Nonconformances

a. The timeliness of nonconformance resolution had been previously l

recognized as an area of concern. Consequently, much

management and plant personnel attention is currently being devoted to timely DER resolution. The current DER program is i considered to be adequate. DERs are now reviewed by the Plant Manager who assigns the appropriate priority level for the l

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Attachm2nt to NRC-88-0094 Page 4 o

response. In all cases, the response must be within 30 days.

I Each assigned evaluating organization is responsible for tracking and/or impler.enting the corrective actions. l t

The Plant Safety Group is responsible for verifying that timely responses are received. Additionally, Plant Safety verifles <

the adequacy of the remedial corrective action and corrective actions to prevent recurrence along with the Plant Manager.

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6. MIL Concerns i

a. The allegation regarding the MIL not reflecting plant configuration changes made because of SPRS information was addressed in item 4.c. of the letter. For the example given, the MIL was determined to be correct with respect to the design configuration and SPRS was incorrect.

7. QA, Program Concerns ,

. t I a. This concern was not substantiated upon investigation. I

8. Uncategorized Concerns

a. Two SAFETEAM reports on use of contract personnel and training of new employees for shelf life review were reviewed and determined to be satisfactory,

b. Item g. of reference 3 was not sufficiently clear as to the i meaning of the concern. However, Detroit Edison believes it to j

be a restatement of the concerns sogarding SAFETEAM which is item C.a. ,

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