NRC-90-0050, Responds to Violations Noted in Insp Rept 50-341/89-34. Corrective Actions:Surveillance Performance Form Revised to Clearly Indicate When Surveillance Partially Completed & Tagging Procedure Revised Re Component Alignment
| ML20034A997 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/16/1990 |
| From: | Orser W DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-90-0050, CON-NRC-90-50 NUDOCS 9004250197 | |
| Download: ML20034A997 (7) | |
Text
. -
. ~....
u X,
j cuum s. or.., -
1 Nucle O hons-O
.hh* 8 oNe'r*'uon.
April:16, 1990' NRC-90-0050
- 3 U. S. Nucid,ar Regulatory Commission Attention: -Document Control Desk
- i Nashington, D.C. _20555-
_l
-Referencess. '1) Ferai' 2 '
NRC Docket No. 50-341 NRC License No. NPF-43 1
- 2) NRC Inspection Report No. 50-341/89034 i '-
+
Subject:
.Re g nse to a Notice of Violations 89-034-03/04/05 i
5 Attached'is Dt.LNit Edison's response to the notice of violation for:
4 (1) the Off Gas System being placed into service without performing l
the Technical Specification surveillance to verify the Hydrogen-
. Monitor opeable; and-that compensatory measures for four hour grab l
samples per Technical Specifications were not initiated; and (2) the violations associated with the B31-F020 valve not being stroke time tested when,itsL surveillance was due.
'these violations were reported;by. Detroit Edison by Licensee' Event Report (LER)89-035, "Off Gas Hydrogen Monitoring Surveillance was not Completed as Required by Technical Specification" and'LERs89-037 and.-
89-037-01,." Testing Required by Technical Specifications for thel t
Reactor Water Sample Line Isolation Valve had,not been Completed due i
to Personnel Error". Detroit Edison has initiated. corrective actions-to resolve these problems.. Included in the response'is a' discussion l
of:
( 1) corrective action taken and the results achieved;--(2)-
. corrective action to be taken to avoid further violations; and-(3) the-
~;
date when full compliance will be achieved.-
r Our respbnse date was extended to-April.16, 1990, due to a' mail ic delay. This extension was discussed with and' authorized by your staff l
on March 16, 1990.
l If there are any questions-relating to this response, please contact-l Joseph Pendergast, Compliance Engineer, at (313) 586-1682.
Sincerely, Enclosure cc:
A. B. Davis R. W. DeFayette t
W..G. Rogers I
l.
9004250197 900416
~
J. F. Stang i
-i PDR ADOCK 05000341 i
i lj Q
PDC L
i
I r
Enc 1ccura to NRC-90-0050 April 16, 1990 Page 1 of 6 Statement of Violstion 89-034-03 l
l Technical Specification-3 3 7.12 and associated Table 3 3 7.12-1, l-Iten 2.a requires the offgas system hydrogen monitor'.to be i
operable when the offgas systes.is in operation or to take Action 124 in the Table. Technical Specificatica Table 3 3 7 12-1, Action 124 allows four hour grab samples in. lieu of having the hydrogen monitor operable.
Technical Specification 4 3 7 12 and associated Table 4 3 7.12-1 Iten 2.a requires periodic channel calibration and functional tests be performed for the offgas system hydrogen monitor.when the offgas system is in operation, t
Contrary to the above, the offgas systes was placed into service.
on December 10, 1989 without performing surveillance 44.080.501 to verify the hydrogen monitor operable nor were the compensatory four hour grab samples initiated. This condition existed until discovery on December 12, 1989 Corrective Actions That Have Been Taken and Results Achieved:
i Upon discovery, the Hydrogen Monitors were declared inoperable. Grab sampling was then initiated and' hydrogen concentration within offgas was found to be well within specification.. The Hydrogen Monitor surveillance was successfully completed on December 13, 1989, at 1600-hours.
Procedures 22.000.02, 23 712,~ 23 125 and 44.080.501 had precautions or' prerequisites placed in them as appropriate to flag personnel for the need to perform the surveillance or verify its current status before placing the Off Gas System in service.
The Chemistry Departaent incorporated verification of the mode change l
surveillance requirements into the'Shiftly Situational Surveillance I
Checklist. This requires that the lead chemistry technician review chemistry surveillances with the Nuclear Shift Supervisor or hist delegate shiftly.
Required reading describing this event was given to Operations, Surveillance Tracking, Instrument'and Controls, and Chemistry Personnel. This increased their awareness of the sequence of events.
~
Corrective Action That Will Be Taken to Avoid Further Violations.
The potential generic ramifications of this event were considered in the accountability action plan developed by Detroit Edison as l
described in Detroit Edison letter NRC-89-0300. Included in this action plan was verification that there were no other unidentified problems with the return to service of safety-related equipment from 1
I
i EnclosurO te a
NRC-90-0050-
=
April 16, 1990 l
. Page 2 of 6 the outage or startup following the outage. 'Ihis plan has' focused on i
professionalism, accountability, followup and simplification' of work activities.
It will serve to improve performance of personne1'in all-activities throughout the plant.
.. All personnel in Operations, Surveillance Tracking, Instrument and '
Controls, and Chemistry have viewed'the Fermi 2 professionalism-video:
presented by management'which included a presentation of the facts 1
conoerning this event. This video emphasized the level of
. (
-professionalism that is needed from nuclear personnel.
j i
Nuclear Quality Assurance (NQA) has provided an oversight review.
(
function for the Accountability Action Plan. The WQA oversight team 4
found that the specific reviews identified-in this action plan has raised the confidence level such that no additional problems similar-to those identified-in December 1989 had-occurred. Additionally, the
[
actions to improve existing programs such as the LCO Program, Abnormal-r Lineup Sheet Program and the Surveillance Scheduling and Tracking-Program should be effective in minimizing recurrence of these.
problems. The NQA assessment team will continue to follow through on' the remaining action items.
Date When Full Compliance Will Be Achieved:
Detroit Edison is in full compliance.
.i t
' I o
...----m,.
Enclo:urs to-1 NRC-90-0050 E
April 16,.1990 Page 3 of 6 1
Statement of Violation 89-034-04
?
Technical Specification 3 0.4 states in part " Entry into an l
OPERATIONAL CONDITION shall not be made unless the conditions for the Limiting Condition for Operation are met.without reliance on-i provisions contained-in the ACTION requirements."
Technical Specification 3 6 3 requires all primary containment isolation valves to be operable in OPERATIONAL CONDITIONS 1, 2 and 3 Table 3.6 3-1 Item A.2 of this specification identifies valve B31-F020 as a primary containment isolation valve.
Contrary to the above, plant operators entered into OPERATIONAL CONDITION 2 on December 6, 1989, with valve B31-F020 inoperable in that.the quarterly ASME Section XI'atroke time test had not been performed.
Corrective' Actions That Have Been Taken and Results Achievedt' 1
A critique of this event-was developed and issued to_ Operations j
personnel as required reading. This critique included a description-
- t of the sequence of events, consequences of the event, conclusions, i
lessons learned, and recommendations.
The administrative procedure governing LCOs, NPP-OF1-11, was revised.-
Revisions included prohibiting the combining of LCOs and requiring identification of components that'are out of service to enhance tracking of equipment status. This procedure revision was approved and has been implemented following training of the operating crews.
l-The Surveillance Performance Form has been revised to clearly indicate' when a surveillance is partially completed. This will assure; surveillance groop personnel are aware of-the work that needs to be i
done before the surveillance is completed.
Corrective Action That Will Be */aken to Avoid Further' Violations.
[
Procedure NPP-CT1-01, " Surveillance-Performance Package Control", will be revised. This revision will ensure that credit for an entire surveillance cannot be taken unless the entire procedure has been -
completed satisfactorily.
J The potential generic ramifications of this event were considered in 4
the accountability action plan developed by Detroit Edison as described in Detroit Edison letter NRC-89-0300.
Included-in this action plan was verification that were no.other unidentified problems 1
with the return to service of. safety-related equipment from the outage or startup following the outage. This plan has focused on professionalism, accountability, followup and simplification of work 0
activities.
It will serve to improve performance of personnel in all activities throughout the plant.
w
--me
.c e
n.ey v
=
-,-.-..w
-- =--
--ew
-w w.
+
v
- Enc 1ccuro to.
' April 16, 1990:
Page 4 of'6 j
i i
All personne1'in Operations have viewed the Fermi 2'professionalisa i
video presented by management which included a presentation of the l
J' facts concerning this event. This video emphasized the level of.
?
- professionalism-that is needed from nuclear personnel._
Nuclear. Quality Assurance (NQA) has provided an oversight review function-for the Accountability Action Plan; The NQA oversight team-found that the specific reviews identified in-this action plan has' raised the confidence level such that no additional problems similar to those identified in December 1989.had occurred. Additionally, the
- actions to improve existing programs such as the LCO Program, Abnormal Lineup Sheet Program and.the Surveillance Scheduling and Tracking Program'should be effective in minimizing recurrence of these.
problems.: The NQA assessment team will continue.to follow through on the remaining action _ items.
Date When Full Compliance Will Be Achieved:
\\
The change to NPP-CT1-01 will be completed by the end of June 1990.
Fermi 2 is presently in compliance with the requirements of Technical Specifications 3 0.4 and 3 6.3 i
F f
EncleIura to 1,
' April 16,1990 Page 5 of 6 q
j Statement of Violation 89-034-05 10 CFR 50, Appendix B, Criterion V, requires in part " Activities affecting quality shall be prescribed by... procedures...and shall q
be accomplished in accordance with these... procedures..."1 Administrative' Procedure NPP-OP1-12, " Tagging and Protective.
j Barrier System," provides the implementing instructions for tagging = valves and switches to prevent inadvertent operation of
^
. structures, systems and components as required by 10 CFR 50,
(
Appendix B,-Criterion XIV, " Inspection, Test, and Operation Status.". Section 6 -of NPP-OP1-12 requires documentation of.
independent verifications, reactor operator authorization to-t.
L
. establish a selected tagging boundary, senior reactor operator.
acknowledgement of tagging boundary being implemented / removed, and notification to maintenance personnel of a modification to
. l the tagging boundary.
4 Contrary to the above:
a.
The tagging measures associated with valve B31-F020 allowed the valve to be opened on December 18-19,- 1989, without.any-reasonable tagging measure present to prohibit such an action even though the tagging records required the. valve to be closed.
b.
Operators failed to comply with the administrative tagging procedure when establishing and modifying the tagging boundary under Abnormal Lineup Sheet 89-1478 in that an independent' valve position verification was not present, a.
reactor operator' authorization signature for a tagging boundary modification was not present, a senior reactor l
operator signature was not present.for. acknowledgement ~of a-tagging boundary modification, and some notification stamps to maintenance personnel.that the tagging boundary.had been modified were not present.
~
Detroit Edison considers these violations to be attributable to i.
procedural inadequacies and personnel errors.
l Corrective Action That Have Been Taken and Results Achieved:
The Operations Department developed a critique of.this' event in order to capture the lessons learned. This-critique was included in the Operations Required Reading program in order to disseminate the lessons learned.
In this critique, several corrective actions were recommended; including revising NPP-OP1-11 and NPP-OP1-12 to prevent similar occurrences in the future.-
l f
f
,,l.~
-k,
^
Endlo:uroto:
... April 16, 1990 Page 6 of 6-Corrective Action That Will Be Taken'to Avoid Further Violations:
)
~
Revisions were-made-to both NPP-OP1-11 and NPP-OP1-12 based upon the conclusions of the critique of'this event. The revision to NPP-OP1-11 included prohibiting combining entries.in the Limiting Condition for Operation (LOO) system and' identification of the specific component or.
system.Q fac6S as part of the LOO entry. Also, if an LCO entry is q
rewritten, tne procedure requires a complete review of the rewrite be performed. This will verify that pertinent information is correctly.
t transferred.
l NPP-OP1-12 was' revised to require components' aligned outside their normal status be tagged and those being worked be listed in the Red Tag Record.
~
i A video tape _ covering the revisions to NPP-OP1-11 and NPP-OP1-12 was presented to the operators in early April.
All the major. elements of the corrective action program have been
-(
completed. The final steps of transferring the existing control room red-line annotation to the new tagging center nylars is being completed on a priority basis.
3 Operations personnel have viewed the Fermi 2 professionalism video presented by Management. This video emphasized the need for attention to detail and the level of. professionalism necessary for nuclear-personnel.
Nuclear Quality Assurance (NQA) has provided an oversight review function for the Accountability Action Plan. The NQA oversight team found that the specific reviews identified in this action plan has raised the confidence level such'that no additional problems.similar
.to those identified in December 1989 had occurred. Additionally, the-1 actions to improve existing programs such as-the LCO Program,-Abnormal' Lineup Sheet Program and the Surveillance Scheduling and Tracking.
Program should be effective in minimizing recurrence-of these problems. The NQA assessment team will continue to follow through on the remaining action items.
Date When Full Compliance Will Be Achieved:
Fermi 2 is presently in full compliance with the requirements of NPP-OP1-12.
Y i
,.-.