NRC-88-0233, Requests Review of Proposed Commitment Change Re Sys Cleanliness Insps

Requests Review of Proposed Commitment Change Re Sys Cleanliness Insps

ML20195E438
Person / Time
Site:	Fermi
Issue date:	11/01/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-88-0233, CON-NRC-88-233 NUDOCS 8811080055
Download: ML20195E438 (3)

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Novenber 1,1988 10C-b8-0233 U. S. !Alclear Regulatory Commission Attnt Document Control Desk Washington, D. C.

20555 neferences:

1)

Fermi 2 NIC Docket No. 50-341 fBC License No. NPF-43 2)

NIC Letter, Spessard to Jens, dated October 21, 1983 3)

IBC Letter, Streeter to Wells, dated Novenber 10, 1983 4)

Detroit D31 son Letter, EF2-67,208, Jens to Spessard, dated Febrtnry 6,1984 5)

Imc Letter, qmssard to Wells, dated January 18, 1984 6)

Detroit Edison Letter, EF2-67177, Jens to Streeter, dated February 17, 1984 7)

NIC Letter, Streeter to wells, dated March 15, 1984 8) tmC Intter, Spessard to Jens, dated June 26, 1984 9)

NIC Letter, Chrissotinus to Agosti, dated March 13, 1986

10) Detroit Filison Letter, EP2-69,279, dated Auquat 27, 1984

11) Detroit Edison Letter, Jens to Keppler, EF2-68,541, dated May 11, 1984

Subject:

Systm C1eanliness Insrections In response to Referencer 2 and 3, Detroit Edison prcnided a su=ary of act. ions taken to improve the preoperational test progra:n (Reference 4). Che of the comitments nale was to perfom a OA inspection prior 8811og0055 881201 DR ADOCK 05000341 i

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M Novenber 1, 1988 NRC-88-0233 Page 2 to closure of open pressure boundaries. At the time preoperational testing was underway and construction was nearing conpletion. The 4

concern was that construction and rework activities were being l

conducted and there was a need to ensure construction materials did not enter systems when they were opened for maintenance or rework.

1 References 5-11 also discussed problems with system conpletion and closure during construction and corrective actions. One of the corrective actions listed in Reference 6 was visual verification of systen cleanliness by QC prior to closure of OA 1 piping systens.

a References le and 11 reiterated that QA would perform a cleanliness inspection prior to closure of safety-related systans.

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i Today, the circumstances are different. Systems are opened for maintenance, inspection and testing uMer the control of work packages d

and/or procedures, as appropriate. Construction debris is not littering the plant. Because of the difference in conditions, the need for the previous ccurmitment for NQA to perform all post-maintenance closure inspections no longer exists.

Detroit D$ison recognizes the inportance of systen cleanliness. The proposed change to this comitment is to require the work group to perform a dccumented cleanliness inspection prior to closure of open pressure boundcries. Quality Assurance will continue to nonitor system cleanliness closures via surveillances, rather than 100%

inspection. Hold points will be inserted into selected work packages, rather than each system closure being a hold point.

A review of Deviation D/ent Reports (DERs) and Nonconformance Reports from 1984 through 1988 was conducted to determine the existing magnitude of system cleanliness problems and whether this change could be supported. A significant decreasing trend in DEP4 relating to deficient systen cleanliness closure itens was fouM. Deficiencies decreased from 11 in 1984 to 1 each in 1987 and 1988.

Based on this inproved cleanliness perferrence and that Fenni is now in an operational rather than construction c.nd preoperational testing phase, a change in the comitment is justified. Detroit Edison proposes to have the work group p rform a documented cleanliness inspection prior to closure of open pressure boundaries rather than Quality Assurance. Detroit Edison feels control of quality is a line.

organization responsibility. The requirenent to perform a documented inspection will not change, and so cleanliness will be maintainea.

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@E Novenber 1,1988 NRC-88-0233 Page 3 Your review of the propsed comitment charge will be appreciated. If you have any questions, please contact Lynne Goottem at (313) 586-4211 Sincerely, f1 cc Mr. R. W. Cooper Mr. R. C. Knop Mr. W. G. Rogers Mr. J. R. Stang LENRC Region III I

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