NRC-89-0023, Revised Response to Violations Noted in Insp Rept 50-341/88-24.Corrective Actions:Requested Vendor Manual for Core Spray Pump Discharge Check Valve Classified for Inform Informational Use Only
| ML20235U004 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/02/1989 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-89-0023, CON-NRC-89-23 NUDOCS 8903090003 | |
| Download: ML20235U004 (5) | |
Text
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ye; B. RIlph SyMa Sencr Vice President 64@ North ome Highway ISO Newport, Michsgan 48166 (313158G 4150 March 2, 1989 j
NRC-89-0023 U.
S.
Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.
C.
20555
References:
(1)
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 (2)
NRC Inspection Report No. 50-341/88-024-01 dated September 27, 1988 (3)
Detroit Edison Response to Notice of Violation. NRC-88-0220, dated October 27, 1988
Subject:
Revised Response to Notice of Violation 50-341/88-024-01 Attached is our revised response to the Notice of Violation (NOV) contained in NRC Inspection Report 88024 (Reference 2).
The violation was issued for perceived procedural inadequacies in the controls f or v endor technical information.
In Reference 3
Detroit Edison Company (DECO) provided our original response to the NOV.
In Reference 3 DECO denied the violation on the basis that there was no specific instance where the perceived prou dural inadequacies led to safety related work being performed using unreviewed vendor information.
Subsequently, in telephone conversations between L.
S.
Goodman and T.
L.
Riley of my staff and J.
J.
Harrison and J.
H.
Neisler of Region III, it was determined that additional information was needed by the NRC to finalize your review of the violation.
Enclosed is a revised response to the NOV which incorporates the' requested information.
Although DECO still does not consider the circumstances involved to be a violation, management recognizes the need to ensure that unapproved vendor manual information is not used for safety-related applications.
Based on further review of this matter, the revised NOV response includes additional training of personnel on the programmatic requirements f or use of only controlled information and a discussion of our plan to stamp unreviewed 8903090003 890302 y
PDR ADOCK 05000341 E
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Nuclear Regulatory Commission March 2, 1989 NRC-89-0023 Page 2 vendor manuals to not be used for safety related work, to the extent practicable.
DECO considers these actions as enhancements to ensure proper implementation of the program requirements already in place at Fermi 2.
5 If you have any questions, contact Terry L.
Riley, Supe rv is or of Compliance and Special Proj ec t s, at (313) 586-4041 or 586-1684.
Sincerely, cc:
A.
B.
Davis R.
C.
Knop W.
G.
Rogers J.
F.
Stang Region III
REVISED RESPONSE TO NRC VIOLATION 88-024-01 Statement of Violation 50-341/88024-01 During the course of a routine safety inspection which examined implementation of commitments to Generic Letter 83-28, an apparent violation was identified in the area _of control of vendor technical information.
The Notice of Violation states:
"10 CFR 50, Appendix B, Criterion 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 location where the activity is performed.
The Fermi 2 Updated Safety Analysis Report, Chapter 17.2.6 requires that documents defining the performance of quality related activities are controlled to ensure that only current and correct information is used at the work location.
Contrary to the above, procedures established to control vendor equipment technical information were not adequate to ensure that only reviewed, approved, and current vendor technical information is used at the work location."
This violation addressed two concerns:
1)
Procedures FMD DC1, Revision 0,
" Document Control", and NE 2.5.10, Revision 3
" Vendor Manuals", have no requirement to collect, review, and control existing vendor technical information pertaining to plant safety-related structures, systems, and components that are in possession of individuals, shops, or departments onsite.
The inspector observed vendor information in eacn building visited but there was no indication that the information had been reviewed to determine its applicability to plant components.
2)
One of the manuals the inspector selected for review was the vendor manual for the core spray pump discharge check valve, a safety-related code valve that was included in the licensee's inservice inspection program.
The inspection report states that the inspector was informed by personnel in the Production Information Center (PIC) that the manual was in use and had not been reviewed and approved.
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Response
l After an ex t e n s iv e review of the facts and interviews with I
all personnel involved, Detroit Edison does not agree that a violation exists on this matter.
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e REVISED RESPONSE TO NRC VIOLATION 88-024-01 In FMD DC1, step 4.6.4 states:
" Uncontrolled copies may be provided 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".
During his inspection, the NRC inspector did not identify any instances where this was not adhered to.
The requested vendor manual for the core spray pump discharge check valve was classified for 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 in Nuclear Engineering.
Although the individual manuals are reviewed'on a pre-established schedule, the ptiority of a specific manual review can be increased on 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 this manua2 for safety-related activities was not yet required.
It is noted that this manual has now been approved by Nuclear Engineering.
10CFR50, Appendix B, Criterion VI, requires tuat controlled documents be used for performance of safety-related a c t iv i t i e s.
By procedure FMD DC1, step 4.11.6, Detroit Edison's program requires the following:
"Only CONTROLLED or VASD [ CONTROLLED - VOID AFTER STAMPED DATE] copies of vendor instructions and manuals that have been approved by Nuclear Engineering shall be used to perform safety-related work or to develop safety-related procedures".
Therefore, DECO's current procedures fulfill the requirements of Appendix B, Criterion VI.
The Quality Assurance organization reviews work packages and other documents, as well as performs per' odic audits, to l
ensure these requirements are met.
During the Maintenance Procedure upgrade, a review was performed to check that all vendor manuals referenced in safety-related procedures have been reviewed.
However, after further discussions with NRC Region III
{
personnel on this matter, DECO management has re-reviewed the
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circumstances surrounding this potential violation.
Although j
DECO still considers the basic elements of a proper vendor j
manual control program are already in place, enhancements j
will be made to ensure safety-related work is performed using only approved vendor manual information.
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REVISED RESPONSE TO NRC VIOLATION 88-024-01 Additional training and information dissemination will be conducted on the Fermi. program and the procedural requirements associated with the use of controlled vendor information in the performance of safety-related work.
Maintenance personnel will receive specific training on the requirements of FMD DC1 and FIP-DC1-02 associated with the control, review and approval of vendor manual information.
This training will be completed by June 30, 1989.
(Note that procedure FIP-DC1-02, Rev.
O, entitled " Vendor Manuals", has superseded NE-2.5.10 cited in the NRC Violation).
Step 5.2 of FIP-DCl-02 states " Vendor Manuals received by Nuclear Generation organizations
- c. r personnel shall be directed to Engineering Support Nuclear Engineering for processing and control".
FIP-DC1-02, which was approved December 16, 1988, prescribes the methods for review, approval and control of vendor manuals, and changes to vendor manuals.
An article on the use of vendor manual information will be issued in the site newsletter, the Fermi 2 Moderator, which receives sitewide distribution.
This article will focus on DECO's program requirements as they relate to all personnel and will be published by June 30, 1989.
Finally, as committed in our discussions with Region III perconnel, DECO will stamp uncontrolled vendor manuals "Do Not Use for Safety Related Work".
This action will be done to the extent practicable since DECO considers this an enhancement to the existing program controls.
In addition, this a departura from the existing progra.a for control of all documents on site.
Uncontrolled copies of documents other than vendor manuals will not be so stamped.
Stamping of uncontrolled copies of vendor manuals will be completed by June 30, 1989.
FMD DC1 and FIP-DC1-02 will be revised by June 30, 1989, to reflect the new stamping requirements for vendor manuals.
Based on our discussions with Region III personnel, we trust that the above enhancements wi] 1 be sufficient to allow the HRC to complete their review of DECO's denial of Violation 88-024-01.
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