NRC-97-0064, Responds to NRC Re Violations Noted in Insp Rept 50-341/97-02.Corrective Actions:Returned Switch TCO/6 & CM & CF Breakers to pre-event Configuration

Responds to NRC Re Violations Noted in Insp Rept 50-341/97-02.Corrective Actions:Returned Switch TCO/6 & CM & CF Breakers to pre-event Configuration

ML20141G567
Person / Time
Site:	Fermi
Issue date:	07/02/1997
From:	Fessler P DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-97-0064, CON-NRC-97-64 50-341-97-02, 50-341-97-2, NUDOCS 9707090361
Download: ML20141G567 (9)

Text

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Pcul Festler

, Plant Manager I

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Edison  ;;re"hDixieHwya' " "

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10 CFR 2.201 i July 2,1997 NRC-97-0064 i

l U. S. Nuclear Regulatory Commission  :

Attn: Document Control Desk Washington, D. C. 20555

References:

1) Fermi 2 i NRC Docket No. 50-341 [

NRC License No. NPF-43 i i

2) NRC Inspection Report 50-341/97002 i dated June 2,1997  !

3) NRC Inspection Report No. 50-341/96201 [

dated November 12,1997 i

Subject:

Renly to Notices of Violation 97002-02. 97002-07. and 97002-08 I Enclosed is Detroit Edison's response to the Notices of Violation (NOVs) contained  !

in Reference 2. There are no commitments made in this letter.  ;

Should you have any questions regarding this response, please contact Andrew V. i Antrassian, Compliance Engineer at (313) 586-1856. i Sincerely, ,  ;

cc: A. B. Beach ,/ cy j '

G. A. Harris l M. J. Jordan A. J. Kugler M. V. Yudasz, Jr. ./

Region 111

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Wayne County Emergency Management Division l

! 9707090361 970702

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NkC-97-0064 Enclosure .!

Page1 Response to Notice of Violation 50-341/97002-02 l

Statement Of Notice Of Violation

Technical Specification 6.8.1 requires that procedures shall be established, implemented, and maintained covering applicable activities listed in Appendix A of Regulatory Guide 1.33,  !

Revision 2.

Regulatory Guide 1.33, Revision 2, Appendix A, Section 4.w states that instructions for energizing, startup, shutdown, and changing modes of operation should be prepared for Offsite

Electrical Systems (access circuits).

Contrary to the above, on February 3,1997, the inspectors identified that the licensee did not have prepared instructions for energizing and startup of Bus 302 in the Offsite Electrical System. '

Reason For The Violation On February 3,1997, Operations personnel were performing an evolution to reenergize 345kV Switchyard Bus 302 in accordance with Switching Order 74349. During this evolution, the CM

and CF breakers which are associated with the Main Generator Output were caused to trip open due to a personnel error, A Nuclear Power Plant Operator (NPPO) mistakenly closed a knife l switch associated with Trip Cutoff #6 (TCO/6), " Automatic Voltage Regulator (AVR) Trip  ;

Cutoff To PA String," which caused the CM and CF breakers to trip open. No adverse system .I consequences resulted from this event. i 4

l Evolutions of this type are controlled at Fermi using switching orders executed through the

] Central System Supervisor (CSS). Prior to this event, Fermi specific procedures governing '

120kV and 345kV operations did not exist.

1 Corrective Steps That Have Been Taken And The Results Achieved j Immediate actions included returning switch TCO/6 and the CM and CF breakers to their pre- j event configuration, and hanging a caution tag on switch TCO/6. l i

The NPPO involved was coached the night of the event and subsequently received training regarding proper questioning attitude and self checking techniques. In addition, shift training l

} and Operations Continuing Training were conducted related to this event.

l Corrective Steps That Will Be Taken To Avoid Further Violations 4

In order to better control these switching operations, procedures have been developed and approved for use governing the shutdown and restoration of 120kV Buses 101 and 102, and

345kV Buses 301 and 302. Procedure 23.300.01,"120kV Bus Operation," was approved on March 31,1997. Procedure 23.300.02,"345kV Bus Operation," was approved on April 14, 1997.

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NRC-97-0064  !

Enclosure  ;

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Corrective Steps That Will Be Taken To Avoid Further Violations (Continued)  ;

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Training material was revised to incorporate information related to this event including the new procedures governing 120kV and 345kV operations. Operator tasks were also developed based  ;

on these new procedures.  ;

t Date When Full Compliance Will Be Achieved 5

i i Full compliance was achieved on April 14,1997, when both the procedures governing operation i of the 120kV and 345kV Buses were approved. I i

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NRC-97-0064 Enclosure Page 3 Response to Notice of Violation 50-341/97002-07 j l

1 Statement Of Notice Of Violation I 10 CFR Part 50, Appendix B, CriterionV, requires, in part, that instructions, procedures, or  !

drawings shall include appropriate quantitative or qualitative acceptance criteria for deteimining that important activities have been satisfactorily accomplished. ,

l Contrary to the above, as of September 11,1996, the inspectors identified the following  !

examples ofinappropriate quantitative acceptance criteria: ,

a. An inappropriate quantitative acceptance criteria of 0.033 standard cubic feet per minute (scfm) air leakage for the accumulators on the automatic depressurization system (ADS) ,

was used in Surveillance Procedure 43.137.002, Revision 21,"SRV Accumulator Check i Valve Test." The designed calculated acceptance leakage rate was 0.002 scfm. Thus the i accumulators could have been depressurized such that they would not have allowed for 5 l actuations of the ADS in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in accordance with the original design. l l

j b. An inappropriate quantitative acceptance criteria of 25 standard cubic feet per minute (sefm) air leakage rate for air operated valve P50-F440, and 20 scfm air leakage rate for  !

air operated valve P50-F441 were used in Surveillance Procedure 24.129.04, Revision 26, t

" Control Air Isolation Integrity." This leakage rate would have made the non- ,

interruptible Control Air System inoperable due to not being able to provide sufficient air l supply during accident conditions. i

c. An inappropriate quantitative acceptance criteria for open coil contactor pickup voltage .

j (104v) was used in Maintenance Procedure 35.306.008, " Motor Control Load l Compartment," for High Pressure Core Injection Valve E4150-F059. The correct  ;

calculated available voltage was 102.9v. Thus the available voltage could have been such  ;

that the valve would not have opened under accident conditions. j Reason For The Violation Regarding the first example, during the initial development of Surveillance Procedure t 43.137.002, Design Calculation DC-0469," Essential Accumulators For Class I Valves (SRVs),"

was not reviewed to identify the proper acceptance criteria.

l Regarding the second example, Design Calculation DC-4931,"Non-Interruptible Control Air (NIAS) Calculations," was not revised to address leakage past valves P5000F440 and F441 when

. leakage acceptance criteria for these valves was incorporated into Procedure 24.129.04.

Regarding the third example, it was determined that the design calculation for valve E4150F059 ,

inappropriately utilized the founh hour battery voltage as the source voltage rather than the first .

minute battery voltage.

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- NkC-97-0064-Enclosure l Page 4 l

Corrective Steps That Have Been Taken And The Results Achieved .

Regarding the first example, the actual system requirements for the accumulators were reviewed against Calculation DC-0469. It was determined that the calculation did not properly account for all leakage boundary components. Consequently, although the accumulators were found to have  !

adequate reserve to perform their intended safety function, the accumulators had less reserve j time than was previously calculated. Calculation DC-0469 was revised on October 9,1996, to j properly address accumulator boundaries, potential leakage paths, and design conditions. The j revised calculation identifies acceptable leakage rates to assure adequate accumulator reserve. i Procedure 43.137.002, was revised on October 15,1996, to incorporate acceptance criteria j consistent with Calculation DC-0469. Testing was performed during the Fifth Refueling Outage  :

which verified past and present accumulator operability. Updated Final Safety Analysis Report  !

(UFSAR) Revision 8 incorporated clarifications related to this example consistent with )

Calculation DC-0469. '

Regarding the second example, previous as-found test data was reviewed and it was determined that NIAS compressor capacity had not previously been exceeded. Because NIAS usage /

leakage had not been tested since start-up testing was performed, Infrequently Performed Test or Evolution (IPTE) packages were developed to test system usage / leakage and compressor capacity for Division I and Division 11 Control Air which assumed a more reasonable leakage rate for valves P5000F440 and F441. Procedure 24.129.04 was revised on November 6,1996, based on assumptions used in the IPTE packages. Testing under the IPTEs was completed for Division I and Division II on November 13,1996,' and November 27,1996, respectively, which verified system operability. Calculation DC-4931 was revised on December 2,1996, to incorporate the results of the IPTEs. In addition, Procedures 27.129.04," Division I NIAS Leakage / Usage - Compressor Performance Test," and 27.129.05, " Division II NIAS Leakage / Usage - Compressor Performance Test," were developed based on the IPTE packages  ;

and approved on June 10,1997, to monitor system performance on a periodic basis. j l

Regarding the third example, Calculations DC-5351, "DC Control Cable Voltage Drop For QA-1 Div.1," and DC-5352,"DC Control Cable Voltage Drop For QA-1 Div. 2," were reviewed to identify any other components with control circuit pick up voltages based on other than first minute source voltage, which were in fact required to operate in the first minute of the battery l load cycle. Eight additional components meeting this criteria were identified. The control circuits for all nine components were re-calculated using the first minute source voltage and it was determined that in all cases sufficient voltage was available to pick up the component starters. Calculations DC-5351 and DC-5352 weie revised on January 10,1997, to incorporate the appropriate source voltage revisions for the affected components.

Corrective Steps That Will Be Taken To Avoid Further Violations The discrepancies identified in the three examples have been corrected. As was appropriate, reviews of associated procedures were conducted to identify similar discrepancies. With the exception of those discrepancies associated with the above examples, no additional discreppncies were identified. Based on this information, it is Detroit Edison's position that no further corrective actions are necessary at this time.

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• - Enclosure Page 5 Date When Full Comoliance Will Be Achieved I

Full compliance was achieved on January 10,1997, when the design calculation revisions associated with third example were completed.

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N'RC-97-0064 l Enclosure Page 6 j Response to Notice of Violation 50-341/97002-08 Statement Of Notice Of Violation 10 CFR Part 50, Appendix B, CriterionV, requires, in part, that activities affecting quality shall be prescribed by documented instructions of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions.

Quality Assurance Manual, MQA02, Revision 3, Section 4.8, " Internal Audits and Surveillances," requires that Deviation Event Reports (DER) be issued for findings identified in quality assurance audits and surveillances.  ;

i Quality Assurance Manual, MQA02, Revision 3, Section 3.6.5, requires that repetitive problems  !

identified through the audits / surveillance be escalated to management attention through the l Management Action Request (MAR) process.

i Contrary to the above, as of September 11,1996, the inspector identified the following examples i of failure to accomplish an activity in accordance with instructions: j i

a. A Quality Assurance (QA) inspector failed to issue a DER for three findings identified in j Audit NQA 96-0106 in accordance with MQA02, Section 4.8.

b. A QA inspector failed to escalate to management a repetitive problem with inappropriate transfer of corrective actions from old DERs to new DERs in accordance with MQA02, Section 3.6.5. The problem was originally identified in Audit NQA 95-0133 and was again noted in Audit NQA 96-0106.

Reason For The Violation Regarding the first example, the three findings involved issues related to programmatic weaknesses in the Fermi corrective action program which were originally discussed in a Nuclear Quality Assurance (NQA) Audit (Report 96-0106) conducted in February / March 1996. The discussion of these programmatic issues was contained in the executive summary section of Report 96-0106 and the issues were not specifically identified as findings in the report. The issues involved lack of guidance for DER evaluators on the relative depth of review for each of the three DER significance levels, weaknesses in the DER root cause evaluation process, and weaknesses in establishing DER corrective actions.

The intent of the executive summary discussion was to summarize common weaknesses which were drawn from an analysis ofidentified findings in order to provide focus areas for increased management attention. In this particular case, the executive summary discussion of the three programmatic issues was not drawn from findings identified in the body of the report.

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N'RC-97-0064 Enclosure l

• Page 7 Reason For The Violation kontinued) l l Regarding the second example, the intent of the guidance provided in MQA.02 was to elevate significant, repetitive safety or programmatic issues to management attention using the Management Action Request (MAR) process. At the time this repetitive issue was identified, it

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[ was not considered to meet the significance threshold and a MAR was not initiated. This intent -  !

of escalating significant repetitive issues using the MAR process was not clearly expressed in  !

l MQA02 at the time this issue was identified.

i Detroit Edison acknowledges the failure to follow procedures identified in both the referenced l examples. The cause'of the failure to follow these procedures is attributed to inconsistent i understanding of management expectations and procedure ambiguities, j l

Corrective Steps That Have Been Taken And The Results Achieved Regarding the first example, a Joint Utility Management Association (JUMA) Audit (Report 96-0121) conducted in June 1996, identified that DERs were not initiated for the issues related to weaknesses in the root cause ' evaluation process and in establishing corrective actions discussed in the executive summary of Audit 96-0106. In response to this finding, DER 96-0684 was ,

initiated on June 14,1996. Nineteen audit reports that were not reviewed during the JUMA Audit were reviewed during resolution of DER 96-0684 to identify any other instances where ,

executive summary focus areas were not drawn from identified audit findings. No other j deficiencies of this kind were identified.  !

In addition, subsequent to the JUMA Audit, two NQA Audits of the Evaluation And Corrective Action Program were conducted in July / August 1996 (Report 96-0129) and in March 1997 (Report 97-0110). These follow-up audits did not identify programmatic deficiencies of the kind described in Report 96-0106.

A rnemorandum was issued to the NQA Audit Staff on September 18,1996, which clarified the expectation that the focus areas identified in the executive summary of audit reports are not to  ;

describe issues which are not identified in the body of the audit report and documented in DERs.

Should additional findings be identified during the development of the executive summary focus areas, then a DER is to be initiated to document the issues.

Regarding both examples, the issues identified in this violation were discussed in Audit Team i Leader refresher training conducted on December 4,1996.

l Inspection Report 96201 documented the issues identified in this violation as a Deficiency. In response, DER 96-1823 was initiated on December 12,1996, to document and evaluate these issues.

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NRC-97-0064

. Enclosure Page 8 Corrective Stens That Will Be Taken To Avoid Further Violations Regarding the first example, Detroit Edison is currently in the process of a complete redesign of the corrective action program at Fermi. The new corrective action program will provide for simplified initiation of conditions and improved guidance regarding the relative depth of resolution for conditions with different levels of significance. Implementation of the new corrective action program is expected to be completed during Fall 1997.

Regarding the second example, Procedure MQA02 was revised on February 12,1997, to eliminate the MAR process. The procedure now identifies that any condition resulting from ineffective implementation of QA program requirements will be reported to management through the Audit Assessment reporting process and will be addressed separate from, and in addition to, the corrective action process. This Audit Assessment reporting process includes designation of a Task Manager by the line organization; development, implementation, and effectiveness review of corrective actions; self-assessment by the responsible organization; and follow-up surveillance by NQA to verify the effectiveness of the corrective actions. The revision to MQA02 also clarified that conditions adverse to quality are trended, regardless of their significance, in the corrective action program to identify emerging adverse trends.

Date When Full Compliance Will Be Achieved Full compliance was achieved on February 12,1997, when the revision to MQA02 was implemented.

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