NRC-95-0068, Provides Rev to Response to NOV 94-11 Re Violations Noted in Rept 50-341/94-11.Corrective Actions:Corrected Locking Discrepancy on E11-F018D

Provides Rev to Response to NOV 94-11 Re Violations Noted in Rept 50-341/94-11.Corrective Actions:Corrected Locking Discrepancy on E11-F018D

ML20087F473
Person / Time
Site:	Fermi
Issue date:	08/11/1995
From:	Mckeon R DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-95-0068, CON-NRC-95-68 NUDOCS 9508150296
Download: ML20087F473 (3)

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14 ' Robert McKeon

' Assist;.nt Vce Presn33rit i and Manager, operauoris

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Edison = r""y" August 11,1995 1r' ==_

NRC-95-0068 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) NRC Inspection Repon 50-341/94011 dated September 16,1994

3) Detroit Edison Letter NRC-94-0083, dated October 17,1994

Subject:

Revised Response to Notice of Violation 94011-01 Enclosed is a revision to Detroit Edison's response (Reference 3) to the Notice of Violation contained in Reference 2. This revision is being submitted to clarify the information previously provided in the " Reason for the Violation" ponion of Detroit Edison's response. No new commitments are being made in this letter.

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If there are any questions related to this response, please contact Ken Riches, )

Compliance Engineer, at (313) 586-5529. j l

Sincerely, 'l h[ A Enclosure cc: T. G. Colburn  !

H. Miller M. P. Phillips A. Vegel Region III i i

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i Enclosure to NRC-95-0068

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Egply to Notice of Violation 50-341/94011-01 Statement of Notice of Violation 94011-01

" Technical Specification 6.8.1.d. requires that written procedures shall be established,

, implemented, and maintained covering the surveillance and test activities of safety-related equipment. Attachment 2 of Surveillance Procedure NPP-43.401.404," Local Leakage Rate Testing for Penetration X-201 A", requires in part, that Valve El1-F018D be restored to a

" Locked Open" position.

Contrary to the above, on August 22,1992 ' he NRC inspector determined that Residual Heat f Removal (R11R) pump "D" recirculation - .ation valve El1-F018D had not been locked in the

! open position in accordance with the restmation specified in Surveillance Procedure NPP-43.401.404."

Reason for the Violatio_a This violation occurred because training with respect to locked valve verification was not effective. Several operators performed separate checks of this valve between July 23 and August 8,1994, none of the them identifying that the valve was improperly locked. El1-F018D is a rising stem gate valve. The locking chain was threaded through the handwheel and was locked, but the free end of the chain was not secured to the valve. Operators believed that verifying valve position by visual observation of the valve stem in the "up" position with the chain and the lock installed was acceptable. This method of verification did not meet requirements regarding l the need to perform " hands-on" verification of valve position and locked condition of locked 2

} valves as described in the procedures for Independent Verification, Locked Valve Guidelines and I

} Locked Valve Lineup Verification. This event is believed to be a training issue rather than a series of individual performance problems because of the number of operators involved in using the inappropriate visual locked valve verification method.

Corrective Actions Taken and the Results Achieved 1

i The locking discrepancy on El1-F018D was immediately corrected when identified on August )

l 22,1994. In order to provide e.ssurance that this was an isolated problem, locked valve i verifications were performed on the following systems (outside containment); Standby Liquid Control (C41), Residual 11 eat Removal (El 1), Core Spray (E21), High Pressure Coolant Injection j (E41), Emergency Equipment Cooling Water (P44), Emergency Equipment Service Water (P45),

Compressed Air (P50), Standby Emergency Diesel Generator (R30), Standby Gas Treatment (T46) and Hydrogen Recombiners (T4804). The personnel performing these verifications were

( instructed to perform a " hands-on" positive check to ensure that locking devices were installed and secure. No additional problems were identified.

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4' Enclosure to NRC-95-0068

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Corre*ctive Actions To Be Taken To Prevent Recurrence i

Procedural requirements for Independent Verification and Locked Valve Verification, along with a clear statement of management's expectations with regard to these activities, has been presented - l in Cycle 7 Licensed Operator Requalification training for both licensed and non-licensed operators. ' Itis training included a " hands-on" demonstration of locked valve positioning and verification techniques. In the interim, operators performing locked valve verifications were briefed by shift supervision on this event and on the proper method for performing locked valve verifications. These briefings were completed prior to plant startup. l..

Date When Full Complir;)ce Will Be Achieved Full compliance was achieved on August 22,1994 when the locking chain on El1-F018D was secured to the valve and the valve was properly verified to be in the locked open position.

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