NRC-88-0220, Responds to NRC Re Violations Noted in Insp Rept 50-341/88-24.Violation Denied
| ML20195B542 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/27/1988 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-88-0220, CON-NRC-88-220 NUDOCS 8811020067 | |
| Download: ML20195B542 (3) | |
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Oct obe r 27, 1988 NRC-88-0220
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l U. 5. Nuclea r Regula t ory Consis sion
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Attention:
Document Control Desk l
Nashington D.
C.
20555 t
l References (1)
Fermi 2 l
L h." Docket No. 50-341 t
NRC License No. NPF-43 t
(2)
NRC Inspection Report No. 50-341/8 8024 da ted i
l September 27 1988 l
Subject:
Response t o Notice of Viola tion l
Attached is the reply to the Notice of Violation contained in NRC Inspection Report 48024 The violation was issued for
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perceived procedural inadequacies in the controls f or vendor technical information.
The inspector did not cite any specific instances where the perceived procedural tradequecies led to safety reisted work being perf ormed using unreviewed vendor f
f information.
Therefore. Detroit Edison denies this violation.
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l If you have any question, contact Patri:ia Anthony at
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(313) 586-1617.
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i RESPONSE TO NRC INS?ECTION REPORT $0-341/86024 Statement of Violation 50-341/88024-01 During the course of a routine safety inspection which i
examined implementation of commitments t o Generic Le tte r 83-28 an apparent violation was identified in the area of centrol of vendor technical information.
The Notice of Viciation states l
- 10 CFR 50 Appendix B.
Crit e rion VI. requires that measures shall be established to control the issuance of documents and shall assure that documents. including changes, are reviewed and approved and used at the loca tion where the activity is performed.
The Fermi 2 Updated Safety Analysis Report.
l Chapter 17.2.6 requires that documents defining the l
performance of quality related activities are controlled to ensure that only current and correct information is used at the work location.
f Contrary to the above, procedur es e stablished t o cont rol vendor equipment technical information were not adequate to ensure that only reviewed, approved, and cur rent vendor t
technical information is used at the work location."
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This violation addressed two conce rns
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l 1)
Procedures THD DC1 Revision 0 "D o c' 4-it Control". and l
l NE 2.5.10 Revision 3 "Vendor Manu. a
have no requirerent to collect. review, and control existing l
vendor technical information pertaining t o plant l
saf e ty-relat ed st ructures, systems, and components that
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are in possession of individuals, shops, or departments I
onsite.
The inspector observed vendor information in
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each building visited but there was to indica tion t hat the information had been reviewed *o determine its L
applicability t o plant co.3.-.nts.
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One of the manuals the in s pe c t o r selected for review was j
the vendor manual for the core spray pump dis charge l
check valve. a safety-related code valve that was
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included in t he licensee's in s e rv ic e inspection j
program.
The inspection report states that the inspector was inf ormed by pers onnel in the Production f
l Information Center (FIC) that the manual was in use and j
had not been reviewed and appr oved.
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Response
After an extensive t ev iew of the facts and int e rviews wit h
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j all personnel involved. Detroit Edison does not agree that a t
violation exists on this matter.
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In THD DC1 step 4.6.4 states:
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RESPONSE TO NRC INSPECTION REPORT 50-341/88024 Response (con't)
"Uncontrolled copies m ay b e p r ov id e d for general reference use.
Recipients shall ensure that such copies are not used to perform any activity for which knowledge of the most current revision of the document is required.
Uncontrolled copies of documents shall not require a control level stamp."
During his inspection, the inspector did not identify any instances where this was not adhered to.
The requested vendor nanual for the core spray nump discharge check valve was classified as informational use only and the New Automated Record Management System (NARMS) database correctly reflected the designated control level.
Prior to the use of this manual in safety related activities, the existing program requires that the manual be processed through the Vendor Manual Review Group.
Although the individual manuals are r ev iew e d on a pre-established schedule, the priority of a specific manual review can be increased <n an as needed basis.
In the case of the core spray pump discharge check valve vendor manual, high priority for review was not considered necessary since use of t his manual for safety related activities was not yet required.
Criterion VI, requires that controlled documents be used for performance of safety-related activities.
By procedure FMD DC1, step 4.11.6, Detroit Edison's program requires the following:
"On3y CONTROLLED or VASD (CONTROLLED - V01D AFTER STAMPED DATE] copies of vendor instructions and manuals that have been approved by Noclear EngAnoering shall be used to perform safety-related work or to develop safety-related proceduresh.
Therefore, DECO's procedures fullfill the requirements of Appendix B.
C rit e rio n VI.
The results of our investigation into this matter will be documented and made available at the site for the inspector's raview if you have any further questions on t h is.
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