NRC-90-0010, Responds to NRC 900102 Ltr Re Violations Noted in Insp Rept 50-341/89-30.Corrective Actions:Storage Area in Machine Shop closed-out & QA1 Matl Returned to Warehouse Where Positive Controls in Effect & Shift Turnover Procedure Revised

Responds to NRC 900102 Ltr Re Violations Noted in Insp Rept 50-341/89-30.Corrective Actions:Storage Area in Machine Shop closed-out & QA1 Matl Returned to Warehouse Where Positive Controls in Effect & Shift Turnover Procedure Revised

ML20006D269
Person / Time
Site:	Fermi
Issue date:	02/01/1990
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-90-0010, CON-NRC-90-10 NUDOCS 9002120307
Download: ML20006D269 (7)

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8. Ralph Syivia

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' Senior vice Pendent -

' I k-- - 6400 North Duse Highway ,

p Ne.wi. u.cni9aa aico February 1, 1990  ;

noi 6aS4 s NRC-90-0010 t

? 7 U. S.' Nuclear Regulatory Commission -

. Attention:: Docuacnt Control Desk Nashington,- D. C. 20555 -i s

Reference:

(1). Fermi 2 .

NRC. Docket No. 50-341 .l NRC License No. NPF-43 l (2) NRC Inspection Report No.- 50-341/89030, Notice of Violation, dated January 2,1990.

Subject:

Response to Notice of Violations from Inspection Report'89030-Attached is the response to Notice of Violations 89-030-01, for lack of a root cause and adequate corrective action as it '

relates' to the control of a QA1 aaterialt storage area; 89-030-02, inadequate independent verification or systea as-left lineups; and-89-030-0s, failure to perform isolation testing for. dampers T41-F009 and T41-F011.

Included in the response are:. (1) The corrective-actions taken and results achieved; (2) the corrective actions.that will be taken to avoid further violations; and (3);the date when full compliance will be achieved.

If there'are any questions relating to this response, please contact Joseph Pendergast, Compliance Engineer, at (313) 586-1682.-

Sincere y, f

B. R. Sylvia Senior Vice President cc: A. B. Davis R. W. Defayette/W. L. Axelson N. G. Rogers J. F. Stang Region III g2120307900201 0 1

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RESPONSE TO NOTICE OF VIOLATION 89-030-01.

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Stqtement of Violation 89-030-01 ]

"10 CPR 50, Appendix B, criterion XVI, . " Corrective Action" states

+ in part, " Measures shall be established to assure that conditions j

-adverse to quality ... are promptly identified and corrected. In -

the case of significant conditions adverse to quality, the 1 measures shall assure that the cause of the condition is- l determined and corrective action taken to preclude repetition." i Contrary to the above, a quality surveillance conducted on January 12'- 20, 1989 identified numerous examples of a condition adverse s to quality relating to inadequate control of a QA1 material l storage area. Root cause was not determined and actions were not taken to preclude repetition. Consequently, other similar-deficiencies in existence at the time of the surveillance were not identified. Additionally, inadequate control of materials in the

-storage area continued' until the time of inspector review on October-10, 1989."

Corrective Actions Taken and Results Achieved:

On October 16-17, 1989, Production Quality Assurance (PQA)-

performed a follow-up surveillance (report no. 89-0326) to the observations noted in the January surveillance. Deficiencies were again observed and Deviation Event Report (DER) 89-1220 was written.

The root cause of this violation war. failure to respond to quality surveillance reports by the Maintenance organization. The Maintenance organization took remedial actions from the January surveillance to place the QA1 storage area in compliance-with FIP-PM3-01, " Material Storage". However, this area was not

• maintained in compliance with the procedure. A contributing factor was that the Quality Report did not specify a response due date on its cover letter and this response was not adequately tracked.

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The remedial action for DER 89-1220 was to close out the storage area in the machine shop and return the QA1 material to the warehouse where positive control is in affect.

l L As corrective action, the Quality Surveillance Report cover letter l' form, used by PQA surveillance personnel has been revised. This l- report is sent to responsible department heads to summarize surveillance results. Now, if the surveillance observations merit l

l a response from the responsible department, it is required to be stated upfront on the report cover letter, along with a response due date.- If this response is not received by PQA within the required time frame and cannot be resolved with the responsible department, the observation may be escalated to a DER. If further action is necessary a Corrective Action Report may be issued. PQA surveillance report responses are now being tracked in the PQA surveillance log. This will ensure a more timely resolution of these surveillance observations.

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In addition, as of the end of 1989, personnel responsible for- root-  ;

cause analysis have received training (DER training) on how to

• determine the root 1cause of events / conditions. This training  ;

included the various methodologies used to evaluate causal factors

.so that comprehensive ~ corrective actions'can be identified. This is expected to minimize root cause determination problems in the future. ,

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L Corrective Actions To Be Taken to Avoid Further Violations:

Asia result of other actions required to followup to the latest i PQA surveillance on this matter, Maintenance will conduct a  :

walkdown and review of other areas in the plant to ensure compliance with FIP-PM3-01. -This action will be completed by  :

February 28, 1990.

In addition, procedure FIP-PM3-01, will be included in required reading for Maintenance supervisory personnel. This will enhance personnel caderstanding of QA1 material storage and control requirements. This required reading will be completed by February 28, 1990.

PQA is also developing a desk-top surveillance instruction. The purpose of this instruction is to describe the methods to be used '

for planning, scheduling, performing, and reporting curveillances conducted by the PQA department. These' instructions are expected to help preclude future instances of untimely followups to. ,

surveillance findings. This procedure is in the comment incorporation stage and will be completed by February. 28, 1990.

The Date When Full Compliance Will Be Achieved: -

Detroit Edison will be in full compliance by February 28, 1990, 3 when the PQA surveillance 1:4structions are to be approved and issued, and the maintenance required reading and walkdown of other storage areas is to be done. i e

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RESPONSE TO NOTICE OF VIOLATION 89-030 Statement of Violation 89-030-02:

"10 CFR 50, Appendix B, Criterion V, " Instructions, ' Procedures, l and Drawings," states in part " Activities affecting quality shall i be prescribed by documented instructions, procedures, or drawings,  !

of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or "

j drawings..."

FMD CT1, which in part establishes requirements for Technical Specification and-10 CFR 50, Appendix J surveillance activities, in Step 4.5.4.17 requires independent verification of the return of systems important to safety to normal configuration following  :

calibration or test.

Contrary.to the above, independent verification of system as-left lineups was not properly performed following completion of ,

surveillances procedures NPP-43 401.510,'" Local Leakage Rate Test, Purge and Vent Valves" conducted on June 13, 1989, NPP-43.401.206,

" Local Leakage Rate Testing for Airlock X-2" conducted on June 3, ,

1989, and NPP-43.404.01 " Standby Gas Treatment Filter Performance  ;

-Test-Division I" conducted on August 16, 1989." >

Corrective Actions Taken and Results Achieved:

The root cause of this event was a failure to review / verify that the independent verification steps of these surveillances were adequately performed before returning the affected equipment to service.- The responsibility for completing the surveillancas was assumed at different times by different groups. Inadequate communications between these groups as to activity status prior to <

accepting the work was a contributing factor.

The responsibility for independent verification of field hardware

. has now been assigned to Operations and Maintenance personnel only. This' assures that only personnel who are properly trained and authorized can perform independent verification activities.

Corrective Actions Taken To Avoid Further Violations:

A critique of the August 16, 1989, event was developed and included in the Operations, Maintenance and Technical Group required reading programs. This critique discussed the sequence of events, developed conclusions and offered lessons learned from this event. The lessons learned and recommendations from this critique are applicable to all three instances. This required reading will be completed by March 13, 1990.

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' RESPONSE TO NOTICE OF VIOLATION 89-030-02 ,

The appropriate administrative procedures were reviewed and evaluated for revision. Procedure NPP-CTI-01,

" Surveillance / Performance Package Control", will be revised. The revision will include clarifying notes and/or steps regarding i

_ responsibilities for completion of any required independent'  ;

l. verification for surveillance packages. This revision will be ,

completed by. February 15, 1990.  !

y The Date When Full Compliance Will Be Achieved:

4 Detroit Edison will be in full compliance upon completion of the changes to NPP-CT1-01 by February 15, 1990 and completion of the required reading noted above by March 13, 1990.

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s g. i RESPONSE TO NOTICE OF VIOLATION 89-030-05 Statement of Violation 89-G30-05:

L " Technical Specification 3 6.5.2 requires secondary containment ventilation system automatic isolation dampers (T41-F008, .

I T41-F009,- T41-F010, T41-F011) to be operable when irradiated fuel is being handled in the secondary containment and during CORE ALTERATIONS. ,

Technical Specification 4.6.5.2.c. requires secondary containment ventilation system ' automatic isolation damper operability .by -

isolation within 5 seconds pursuant to Technical Specification , 4.0.5.

Technical Specification 4.0.5 requires inservice inspection and testing of ASME Code Class 1, 2 and 3 components in accordance with Section XI.  ;

Relief request VR-23 of the licensee's submittal on ASME Section XI testing requires the stroking closed of air operated isolation dampers quarterly. ,

Contrary to the above, by October 17, 1989 plant operators failed i to perform isolation testing for dampers T41-F009 and T41-F011 within the quarterly time frame with CORE ALTERATIONS in progress." ,

Corrective Actions Taken and Results Achieved:

As described in DECO letter NRC-89-0244, dated November 20, 1989, I (i.e., Licensee Event heport 89-024-00) the affected Secondary ,

L Containment dampers were successfully tested per Technical r Specification 3.6.5 2 on October 19, 1989 The root cause of this event was personnel error. Operations personnel had not closely reviewed the Situational Surveillance List for Core Alterations and the Handling of Irradiated Fuel in the Secondary Containment.

! a A critique of this event was included in the required reading program for Operations and Surveillance Group personnel. This required reading increased the awareness of these personnel to the circumstances leading to the missed surveillance. The required reading will be completed by February 15, 1990.

The Licensed Operator Requalification Training Program included a discussion of this event. The importance of a questioning attitude towards staying on top of plant conditions and requirements as.it relates to this event were stressed. It was also designed to reinforce theJr understanding and aware. ness of the Situational Surveillance Tracking program. This training also l involved ~a discussion of the recently develorad desk instruction NP-SG-D1-04, " Operations Information System (OPSI) Users Guide",

for the' computer support system.

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p RESPONSE TO NOTICE OF VIOLATION 89-030-05 f'

The surveillance engineer has been spending additional time with operations personnel reviewing daily schedules and special condition reports. In addition, Operations personnel have been L - instructed by. operations management to focus attention on the ,

" schedule" due dates for completing surveillances to reduce the i i need to rely on the " critical" due dates.

Corrective Actions Taken To Avoid Further Violations:

Procedure NPP-OP1-05, " Shift Turnover", will be revised. This revision will include the requirement to review the list of

- non-triggered Situational Surveillance requirements during shift turnover. . This revision will be completed by February 15, 1990. 4 The licensed Operators will receive additional,' subject matter-specific training regarding the Situational Surveillance Tracking program. The Operators will receive on-line training using the plant computer network for the identification of situational t surveillances. This training is expected to take place by April ,

1, 1990.

In order-to prevent similar events from occurring, Detroit Edison has developed an action plan which is described in NRC-89-0300, dated December 26, 1989 This plan addresses personnel

' performance weaknesses discovered during the first refueling-outage and during the return to power operation.

- The DP's :' hen Full Compliance Will Be Achieved:

Detr :t 8 ' son will be in full' compliance following completion of the aio aal training for licensed operators on the Situational Surveitlance Tracking program by April 1, 1990.

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