NRC-89-0139, Responds to Concern Noted in SSOMI Insp During Wks of 890717 & 31 Re Receipt & Review of Vendor Documents.Summary of Actions to Resolve NRC SSOMI Insp Concern W/Vendor Document Review Encl
| ML20246F530 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 08/25/1989 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-89-0139, CON-NRC-89-139 NUDOCS 8908310039 | |
| Download: ML20246F530 (5) | |
Text
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8, Ralph Sylvb e
a senior vice prescent 1)Edf0j,I am sonn o,m mys..,
Q Newport. Mich'Da0 48166 l
%#O (313) 566-415C August 25. 1989 NRC-89-0139 i
U.
S.
Nuclear Regulatory Commission Attention:
Document Control Desk l
Washington, D.
C.
20555 i
i Rererence:
(1)
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 (2)
Detroit Edison letter to the NRC. VF-85-0134 dated July 5 1985
Subject:
Actions to Resolve NRC SSOMI Inspection Concern with Vendor Document Review l
A SSOMI team, which was lead by_Mr. Robert Gramm, was at Fermi 2 the weeks of July 17 and July 31 1989.
They expressed a concern with receipt and review of vendor documents.
Specifically, vendor information relating to the Emergency Diesel Generators was not appropriately reviewed and incorporated into procedures or manuals.
Enclosed is a summary 1
of the actions that Detroit Edison intends to implement in order to resolve this concern.
If there are any questions relating to this information, please contact Jeffrey Dudiets at (313) 586-4827 or Patricia Anthony at (313) 586-1617.
Sincerely.
$$aff,?D cc:
A.
B.
Davis R.
C.
Knop W.
G.
Rogers J.
F.
Stang R.
Gramm n0 (\\
Region III
\\
Ik 8908310039 890825 PDR ADOCK 05000341-G PNU
Attachnent August 25, 1989 10C-89-0139 Page 1 10C SSO4I Concern with Vendor Information At the SSO4I exit meeting on August 4,1989, the 100 reporte$ a concern with Detroit D31 son's Vendor Docunent control system.
The IEC requirements are given in Generic Letter 83-28, Regaired Actions Based on Generic Implications of SALD4 A'1WS Events, section 2.2 Equipnent Classification and Vendor Ir.terfsce (Programs for all Safety-Related Conponents), sub-section 2, which follows:
For vendor interfa::e, licensees and applicants shall establish, inglenent and naintain a continuing program to ensure that venSor information for safety-related conponents is conplete, current and controlled throughout the life of their plants, and appropriately referenced or incorporate 3 in plant instructions and procedures. Vendors of safety-related equipnent should be conta:teS and an interface established.
Where vendors cannot be identified, have gone out of business, or will not supply information, the licensee or applicant shall assure that sufficient attention is paid to equipnent maintenance, replacement, and repair, to conpensate for the lack of vendor backup, to assure reliability commensurate with its cafety function (GDC-1). The program shall be closely couple 3 with action 2.2.1 above (equipnent qualification). The program shall include periodic connunication with vendors to assure that all applicable information has been received. The program should use a system of positive feedback with vendors for mailings containing technical information. This could be accomplished by licensee acknowle3 enent for receipt of technical 9
mailings. It shall also define the interface and division of responsibilities among the licensee and the nuclear and nonnuclear divisions of their vendors that provide service on safety-related equipment to assure that requisite control of an3 applicable instructions for nalntenance work on safety-related equipnent are provided.
In our correspondence to the IUC, VP-85-0134, dated July 5, 1985, Detroit B31 son committed to adopt the INPO developed program, as prepared by the IUI7C committee, INPO 84-010, Verdor Equipment Technical Information Program (VETIP).
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1 p
' Attachment D
h, August 25,:1989-N
'IGC-89-0139' Page 2 p
NRC SSan Concern with Vendor'Information-VETIP was based on the recognition that " Vendors are 'not familiar with the surveillance or maintenance histories, nor g
with the application of the equipnent or its environment. This -
' type of information is nost readily available at the plant level within individual utilities." The intent was to have utilities develop internal administrative controls to properly report and'
- disseminate resalts from the INPO NPRDS, and SEE-IN programs rather than have cach utility establish periodic; contacts with 0
each vendor.
J a doing so the utility would more effectively.
remain current on technical issues affecting the plant's equipment.
During the SSWI audit,' NIC inspector, J. Jacobson, produced a Colt /Fairbanks Morris Service Information Letter, -(SIL), Issue 17 and asked if Detroit Mison had evaluated it.' It was observed that Detroit Mison had only included SIL issues 1 through 10 in the Colt / Fairbanks Morris Vendor Manual
-#VME8-1.0.
During Detroit Mison's subsequent investigation, a nunber of possible enhancements to strengthen the Vendor Manual / Document program were identified. These enhancements,. i.e., program changes, were formulated to address the' concerns identified during the inspection and subsequent Eison investigation. They are as follows:
' s Concern 1 The present administrative controls did not ' assure that seven SILs from Colt were included in the Vendor Manual.
Procram Chanaes FIP-DCl-02, Vendor Manuals, will be revised to establish an internal program to periodically interface with selected QA-1 equipment vendors to assure that the vendor generated SILs, Notices, etc.,' are evaluated and incorporated into the controlled vendor manuals or evaluata3 for physical modification, as applicable.
The program will include vendor selection criteria whicn a.
will preclude unnecessary contact with vendors whose equipnent. typically does not require periodic -
maintenance, and/or they are replaced rather than i
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' Attactment L..
-August-25,L1989 NHC-89-0139 Page 3.
NRC SSO U Concern with Vendor Information-repaired, etc. These types typically. fall into a category of passive equipment for which INPO would issue CERs/SOERs, or. for which 10CFR Part 21 notices would cover their. failures, i.e.,' terminal blocks, connectors, thermocouple, etc.-
b.
The program will require contact be made with selected vendors on a two year. cycle.. This review supplements.
and enhances'the continuously maintained OER/SOER programs.
Concern 2 Fermi 2 did not have a single point of responsibility 'for receipt and control' of vendor technical:information.
Proaram Ehnrnaes
~ 2.1 Fermi Management Directive, FMD AD3, Correspond'ence Control,.will be ~ revised to indicate that Nuclear Engineering is rmponsible for' the receipt and
.. disposition or vendor technical information, ' including 10CFR21~ notices.:
2.2 FMD cal-and FIP-cal-01 will be revised to identify 'that melear Engineering is responsible for preparing Deviation Events Reports (DERs) for 10CFR21~ notices as well as other vendor issuances.
2.3 Purchasing will revise the OA-1 Equipment Purchase Order, Standard Attachment to identify that melear Engineering is to be the recipient of 10CFR21 notices and technical information, including subsequent technical notices and service letters.
' Concern 3
. Fermi's administrative controls did not prov2de explicit direction for the recipient of vendor technical information, other 'than vendor manuals or design documents, to send copies to Nuclear Engineering for review and approval.
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' Attachment -
l August 25,?1989 NIC-89-0139.
.Page.4 NIC SSCMI. Concern with Vendor' Information
.Procram Chance
. The change to' FM AD3, noted above, coupled ' with the
. requirement of.section 4.1.4 of FND AD3 for individuals in organizations, other than the primary recipient, who receive official: externally generated correspondence,. to forward the' correspondence to the' primary recipient, in this case,
!bclear Engineering adequately a3 dresses this concern.
Imi enerttatIOn Implementation for the above progrars, including revision of
' appropriate Fermi Managenent Directives (FHDs) and the
- supporting Fermi Interface Procedures (FIPs), will be revised
.by Novenber 30, 1989.
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