NRC-97-0067, Forwards Response to Violations Noted in Insp Rept 50-341/97-05.Corrective Actions:Deviation Event Rept (DER) Written to Identify Concern & to Track Corrective Actions

Forwards Response to Violations Noted in Insp Rept 50-341/97-05.Corrective Actions:Deviation Event Rept (DER) Written to Identify Concern & to Track Corrective Actions

ML20149J508
Person / Time
Site:	Fermi
Issue date:	07/21/1997
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-97-0067, CON-NRC-97-67 50-341-97-05, 50-341-97-5, NUDOCS 9707280245
Download: ML20149J508 (10)

Text

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l 0 Dougl.u R Gipson Senior Vice I* resident. Nuclear Generation Fermi 2

, . 64% North Dixie liwy., Newpert. Michigan 4S166

, Tel:3115863201 Far 313M.4172 Detroit Edison 10 CFR 2.201 - -

l July 21,1997 -

NRC-97-0067 U. S. Nuclear Regulatory Commission Attn: Document Control Desk l Washington, D. C. 20555 l

References:

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

2) NRC Maintenance Inspection Report 50-341/97005

, Dated June 19,1997 l

Subject:

Reply to Notices of Violation (97005-01. 97005-02, and 97005-04)

Enclosed is Detroit Edison's response to the Notices of Violation (NOVs) contained in Reference 2.

The following commitments are being made in this letter:

1. Procedure 28.504.03 " Fire Suppression Water System Simulated Automatic Actuation Test" will be revised to clarify that the 2100 to 2300 rpm range is J

not a limit. This will be completed by August 31,1997.

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2. A Maintenance Department Instruction will be issued to reemphasize work control expectations and will address work outside the scope of the work package. This will be completed by September 30,1997. O

3. Desk Top Instruction," Inspection and Surveillance (I&S) WIO7" will be revised to require a QC hold point whenever a Quality Control Inspection Report identifies an unsatisfactory step in a work request.

3. Maintenance Conduct Manual MMAl1," Post-Maintenance Testing Guidelines," will be revised to include guidance on performing a flow test whenever any work performed on the engine affects engine speed. This will

[ be completed by October 31,1997.

,D $ $.$!.!!.blll$$

OhI,!

A DTE Energy company

NRC-97-0067 ,

Page 2 Should you have any questions regarding this response, please contact Ronald C.

Wittschen,~' Compliance Engineer at (313) 586-1267.

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J Sincerely, Attachment cc: A. B. Beach

. G. A. Harris

. M. J. Jordan .

A. J. Kugler -

M. V. Yudasz, Jr.

Region ill ~

' Wayne County Emergency Management Division m, .-

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Attachment to NRC-97-0067 Page1 Response to Notice of Violation 50-341/97005-01 Statement of Notice of Violation:

Technical Specification 6.8.1 required, in part, that written procedures shall be established, implemented, and maintained covering, the Fire Protection Program.

The Fire Protection Program required periodic inspection, maintenance, and surveillance testing of the tire detection and protection systems.

Maintenance Conduct Manual, MMAl l " Post-Maintenance Testing (PMT) Guidelines,"

Revision 2, Section 3.2, stated, in part, "The scope of the PMT is one that: (1)

Demonstrates correction of the original deficiency under normal operating conditions and/or plant conditions at the time of the failure, (2) Ensures no new or related I

deficiencies have been created, and (3) Ensures the system or component can perfomt its

. intended function."

Fire Protection Procedure 28.504.003," Fire Suppression Water System Simulated l Automatic Actuation Test," Revision 3, Section 5.2, required verification that the engme l speed met acceptable limits of 2100 to 2300 rpm. l l

Contrary to the above: l

a. On May 11,1997, the licensee failed to perfonn adequate post-maintenance testing (PMT) to ensure that a new deficiency was not created due to maintenance.

Specifically, the completed maintenance on the diesel driven fire pump included reducing the engine speed from 2440 rpm to 2150 rpm. However, the licensee's l PMT did not verify that the resultant pump pressure and flow would still meet requirements such that the pump would still perfonn its intended ftmetion.

b. On May 2,1997, the licensee failed to verify that the engine speed was operating within the acceptable limits of 2100 to 2300 rpm. Specifically, the licensee accepted Section 5.2 of the surveillance as satisfactory with the engine speed documented as 2440 rpm. No technicaljustification for this acceptance was provided.

Attachment to

. NRC-97-0067 Page 2 Reason for the Violation:

PART (a)

As_ discussed in the Notice of Violation, the diesel fire pump engine had been determined to be running at a speed higher than normal, and a work package was initiated to correct the problem. On May 11,1997 the engine governor was adjusted from 2440 to a lower running speed of 2150 rpm. This speed corresponds with the speed recommended in the system operating procedure. The effect of the lower speed on pump flow (vas discussed at the time of the change, but it was decided that a nety post maintenance test (PMT) was not required. The full effect of the rpm change on pump flow was not recognized at that time.

When the effect of the speed change was recognized, the test data from the earlier tests was corrected for the new engine speed. This calculation determined that the pump flow at the lower speed did may meet the acceptance criteria, and a retest was recommended.

1 PART (b) l Prior to the test referenced in Part (b) of the Notice of Violation, the engine mounted tachometer had failed and was inoperable during this test. While the engine mounted tachometer was inoperable, the strobotac normally used for measuring the pump speed was used to measure the engine speed.

Procedure 28.504.03 " Fire Suppression Water System Simulated Automatic Actuation Test" identifies a range of 2100 to 2300 rpm for the engine speed. For the example in Part (b) of the Notice of Violation, ajustification addressing the higher engine speed would have been appropriate, but would not have affected the acceptability of the test.

Neither pump speed nor engine speed is an acceptance criteria for this test, but both are recorded for documentation and trending purposes. l Actual measured flow is used to determine test acceptance and is corrected for rated pump speed to trend degradation of the pump. The measured flow is directly related to the pump speed which is related to the diesel engine speed and the angle drive ratio. Both engine speed and pump speed are recorded by test procedure 28.504.03. Since flow is

'directly related to both and the acceptance criteria includes flow, there is no need for either pump speed or engine speed to be identified as an acceptance criteria.

. The Corrective Steps That Have Been Taken and the Results Achieved:

A Deviation Event Report (DER) was written to identify the concern and to track corrective actions. A new PMT was performed on May 28 which verified that the lower engine speed of 2150 rpm was acceptable and met required pump performance criteria.

An operability determination was made and concluded that the fire pump was operable.

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' Attachment to

, NRC-97-0067 Page 3

' On May 29 engine speed was raised from 2150 to the range of 2250 to 2300 rpm. This is consistent with the SOP and provides additional flow margin.

I The Corrective Steps That Will Be Taken to Avoid FurtheE Violations:

Procedure 28.504.03 " Fire Suppression Water System Simulated Automatic Actuation Test" will be revised to clarify that the 2100 to 2300 rpm range is not an acceptance criteria. This will be completed by August 31,1997, 1

~ Maintenance Conduct Manual MMAl1," Post-Maintenance Testing Guidelines," will be revised to include guidance on performing a flow test whenever any work performed on the engine affects engine speed. This will be completed by October 31,1997.

- Date When Full ComDliance Will be Achieved:

Full compliance was achieved upon completion of the diesel fire pump flow test on May 28,1997.

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Attachment to

. NRC-97-0067 Page 4 i '

Response to Notice of Violation 50-341/97005-02 4

i Statement of Notice of Violation:

4 10 CFR Part 50, Appendix B, Criterion V," Instruction Procedures, and Drawings,"

required, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type cppropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, on April 28,1997, electrical maintenance personnel put defective 4

parts back in, cleaned, lubricated, and exercised the fused disconnect switch in motor l

control center (MCC) 72E-5A, Position SC, without work instructions appropriate to the circumstances. Specifically, while troubleshooting and replacing switching mechanisms on MCC 72E-5 A Position 3C under Work Request No. 000Z974256, personnel went l

beyond the scope of the work request to perform maintenance on the switch at position 'l SC. l l

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Reason for the Violation:

A work request information form (WRIF) package had been initiated to rework the fused disconnect switch at MCC 72E-SA Position 3C. Quality Controlinspectors monitored the rework. The package required that if spare parts were not available from the warehouse, personnel were to remove needed parts from MCC 72E-5A Position SC, a spare position on the MCC. The rework included replacing parts in the switch at Position 3C with parts from Position 5C. At the conclusion of the initial rework, however, the

'7 switch at Position 3C again failed to operate properly. Parts were swapped between Position 3C and Position 5C and both switches recleaned, relubricated, and exercised.

Both switches were then determined to be working acceptably. The rework on Position 5C was not specifically included in the work package, and should have been documented by a WRIF.

The Corrective Steps That Have Heen Taken and the Results . Achieved:

A Deviation Event Report (DER) was written to document corrective actions initiated to resolve this concern. MWC02 " Work Control," applies to maintenance and modification activities and controls the initiation and documentation of a WRIF including the scope of work. This procedure was reviewed and determined to be adequate. The expectation is that work activities are not to exceed the scope delineated in the work package. The individuals involved including Quality Control inspectors, were coached on these expectations.

l' Attachment to NRC-97-0067 l Page 5 The Corrective Steps That Will Be Taken to Avoid Further Violations:

Work package expectations will be reemphasized by the maintenance first line supervisors during work package briefings. A Maintenance Department Instruction (MDI) is being prepared to provide additional fbcus on work package documentation.

Additionally,- the causes, results and corrective actions for the violation will be discussed in third quarter Electrical Continuing Training.

i The Desk Top Instruction, " Inspection and Surveillance (I&S) WIO7" will be revised to require a QC hold point whenever a Quality Control Inspection Report (QCIR) identifies an unsatisfactory step in a work request.  !

Date When Full Compliance Will be Achieved: ,

Full compliance will be achieved when the Maintenance and Quality Control Instructions I are issued. This will be accomplished by September 30,1997.

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f Attachment to

. NRC-97 0067 Page 6 Respense to Notice of Violation 50-341/97005-04 Statement of Notice of Violation:

10 CFR 50, Appendix B, Criterion III " Design Control" required, in part, that measures be established for the selection and review for suitability of application of materials, parts, equipment and processes that are essential to the safety-related functions of structures, systems and components.

Contrary to the above:

a. On May 13,1997, a nonsafety-related turbo charger blower cover gasket was installed on safety-related emergency diesel generator (EDG) 12 without performing an adequate engineering evaluation which addressed the suitability of application of the part to the safety-related functions of the EDG and EDG components.

b. On May 20 and 27,1997, the licensee continued to install the same type turbo

, charger gasket identified as inadequate on May 13,1997,in EDGs 13 and 14 without revising the engineering evaluation to support the use of the gasket. As a result, inadequately evaluated nonsafety-related parts continued to be used in i safety-related equipment until May 27,1997.

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Reason for the Violation: l Plant procedures require an engineering evaluation of parts used for the repair or moditication of safety-related equipment. This evaluation is documented on an Engineering Evaluation Checklist (EEC). The preparer must document whether the item being evaluated performs a critical function in a safety related component. When the function of the item is determined not to be safety-related, the checklist allows concise documentation of that determination. The EEC for the inspection cever gasket on the EDG cover concludes that the gasket does not perform a critical fun:: tion.

During the inspection and as summarized in the inspection report, t! e inspectors disagreed with this conclusion and indicated that the possibility of r ausing significant operational problems appeared to exist if the gasket failed.

• The Detroit Edison evaluation does not support the above stated NRC conclusion that gasket failure may cause possible significant operational concerns. On the EDG Scavenge Air Blower, the manufacturer has placed a cover which houses the blower

Attachment to

. NRC-97-0067 Page 7 bearings and supporting components. The purpose of the cover is to protect the rotor bearing seals, the small oil lines, and other associated components from inadvertent damage by personnel in the area. The bearings themselves are integral to the blower, are sealed and form part of the pressure boundary between the super charged air inside the blower and the area enclosed by the cover. The gasket in question is a vegetable liber gasket located on this cover for a hand hold inspection cover. When the diesel engine is operating, the inspection cover and gasket do not come in contact with the air entering or leaving the air blower. Should the oil seals on the rotor bearing leak, the air blower pressure on the internal side of the seal could cause an increase in oil leakage and some spray which would be contained by the cover. Failure of the hand hold inspection cover gasket will have no effect on the operation of the diesel. This was the determination documented in the 1989 EEC which concluded the following:

"Since the gasket is always under compression, it will not fail in such a way that leakage would cause the EDG to become inoperative. The gasket will perform its function ifit is installed correctly."

Although the evaluation may be brief, it is commensurate with the level of detai! required to document the determination. The vegetable fiber gasket used in this application has no safety-related function and its failure will not impact proper operation of the EDG. ]

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The Corrective Steps That Have Heen Taken and the Results Achieved:

The following corrective steps had all been initiated prior to the inspection as a result of a self-initiated review. The brief nature of the older evaluations had been identified as a concern in 1996 and a review initiated. Deviation Event Report (DER) 96-0903 dated August 7,1996 was written to self-identify a weakness found in the safety classifications of parts documented by EECs, especially in older packages. Corrective actions initiated as a rest. vf this 1996 DER included reviewing all EECs which previously approved nonsafety-related gaskets for use on safety-related components. These were identified by sorting nonsafety-related stock codes approved for use in safety-related components. Of primary concern was that a nonsafety-related part may have inadvertently been approved for use in a safety-related application. The review focused on identifying non-Q stock codes issued for use on safety-related components. This review was completed prior to the start of the NRC inspection, and concluded that none of the brief EECs had approved a nonsafety-related part for a safety related application.

Prior to the inspection period, in conjunction with DER 96-0903 and in order to ensure that future safety classifications include a stronger documented basis, the following procedural enhancements were made:

I Attachment to

', NRC-97-0067

,Page 8

• A new procedure, MMM16," Parts Quality Classification Evaluation" was written to provide detailed guidance for the Materials Engineering Group (MEG) to perform safety classifications of parts.

• Procedure MMM03," Technical Evaluation of Procurement Documents," was revised to include additional guidance for MEG engineers when providing documentation of the classification of parts as nonsafety-related.

. In accordance with MMM17, " Bill of Material Evaluation," parts to be classified nonsafety-related for QA-1 and select QA-1M plant components must be evaluated by completion of a Parts Quality Classification Evaluation (MMM16) or an approved design document, prior to including it in the Bill of Material.

This ongoing Bill of Material project will result in all of the older evaluations being reviewed and will ensure that a more detailed basis is provided for all parts assigned a nonsafety-related classification.

1 Part b of this Notice of Violation indicates that the gasket identified as inadequate by l

NRC continued to be installed in EDGs 13 and 14 without revising the evaluations.

Upgrading the format and content of the older EECs to reflect current procedures was not considered to be safety significant and was not given a high priority. The decision was made not to dedicate resources at the time of the inspection to that effort. The review in accordance with MMM17 discussed above was planned to address these older evaluations. The EEC for the gasket has now been revised; hotvever the revision did not change the conclusion that the application of the gasket is not safety-related.  !

s Date When Full Compliance Will be Achieved: l l

i Full compliance was achieved when the EEC for the EDO gasket was reviewed and determined to be correct during the self-initiated review of older evaluations. j