ML20246P047

Ack Receipt of 890224 Response to Violations Noted in Insp Rept 50-341/88-31.Part B of Violation 88031-01 Withdrawn Based on Addl Info,Per Agreement That Util Would Document Steps of Potential Conditions Adverse to Quality

ML20246P047
Person / Time
Site:	Fermi
Issue date:	03/21/1989
From:	Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Sylvia B DETROIT EDISON CO.
References
NUDOCS 8903280097
Download: ML20246P047 (1)

See also: IR 05000341/1988031

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UlAR 211939 '

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. Docket No. 50-341

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The Detroit Edison Company

' ATTN:

B. Ralph Sylvia'..

Senior Vice President

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Nuclear' Operations

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6400 North Dixie flighway

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Newport, MI 48166

Gentlemen:

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Thank you for your letter dated February 24, 1989, informing us'of-the. steps

you have taken to ' correct the violations at the Fermi 2 facility,.which we,

brought'.to your attention in 'our letter dated January 24', 1989..

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7

After_ reviewing you~r response, we noted that you denied Part B of Violation

88031-01. During a telephone conversation on March 16,1989, between

Mr. N. Choules of our staff, and Mr. -T. Riley and Ms. P. Anthony of'your staff,

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we learned that the QC inspector had, obtained approval. from your' engineering-

staff prior to ' accepting the installed fuses. Based on the additional

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information, we withdraw Part B of Violation.88031-01.

However, since the basis for accepting the fuses was not. documented on the work-

request, as. discussed in.our report, and with Mr. T. Riley on March 20, 1989,

it was agreed that you would address the steps you have- taken to assure that ~

potential conditions' adverse to quality and their resolutions would be documented

by QC personnel. Mr. Riley stated that this information would be formally

addressed and a response prepared by April 20,-1989.

We will gladly discuss any questions you have concerning this matter.

Sincerely,

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R. W.

-oper, ~ II,: Chi f

Engineering Branch

cc: Patricia Anthony, Licensing

P. A. Marquardt, Corporate

Legal Department

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Licensing Fee Management Branch

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Resident Inspector, RIII

Ronald Callen, Michigan

Public Service Comission

Harry H. Voight, Esq.

Michigan Department of

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February 24, 1989

NRC-89-0020

U.

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Nuclear Regulatory Commission

Attention:

Document Control Desk

Washington. D.

C.

20555

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References: (1)

Fermi 2

NRC Docket No. 50-341

NRC License No. NPF-43

(2)

Notice of Violation. NRC. Inspection' Report'

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50-341/88031 dated January 24.,

1989-

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(3)

Detroit Edison response to SALP Report.

NRC-88-0198

dated August 17, 1988

Subject:

Response to Notice of Violation

1

Attached is the response to reference 2.

The violation was

act for activities.and conditions found during preventive

-tenance on the 130V battery chargers between November 1987

November 1988.

In response to violation 88031-01B.

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-;;;Jir.g a QA inspectors' identification that fuses installed

in 130 Volt battery charger 2B-2 were not as specified in

As-Built Notice 5848-1

DECO has determined that appropriate

information had been previously prepared by engineering which

indicated a non-conforming condition.

i.e..

one requiring the

issuance of a Deviation Event Report, did not exist.

As a

result. DECO denies this portion of the violation.

If there are any questions relating to this response, please

contact Patricia Anthony at (313) 586-1617. M r ,., R . Knop, NRC

RIII, authorized a one day extention for this response in a

telecon with Ms.

L.

Goodman on February 23, 1989.

Sincerely,

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B. Davis

R.

C. Knop

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G.

Rogers

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RESPONSE TO NOTICE OF VIOLATION 50-341/88031

Statement of Violation 50-341/88031-01A:

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In the Notice of Violation it stated:

The preventive maintenance instructions for the 130 Volt-

battery chargers, including WRs P026307

P026308 and several

other WRs for battery chargers work performed in-November

1987, May 1988, and November 1988 did not contain acceptance

criteria for determining the proper size and type fuses

installed in the 130 volt battery chargers.

Discussion:

Originally, the 130 volt battery chargers were supplied and

qualified by the vendor with Brush SF 13x150 internal fuses.

In March 1988

Detroit Edison Engineering Research Department

tested a sample size of 4 from a' lot of 50 fuses for upgrade

to QA-1 applications.

One of the four sampled failed the

let-through current test only.

Comparison of test results to

vendor curves indicated that the one fuse allowed a let-

through current that exceeded the manufactures' value by more

than 30%.

This and the fact that the vendor recommended a

Shawmut replacement fuse led engineering to determine that it

was preferable to stock Gould Shawmut A13x150-4 AMP Trap Form

101 fuses.

The vendor replacement parts list specified Shawmut, Form

101, 150 Amp fuses.

The Vendor Manual, prior to November

1987, did not contain this list of replacement parts.

However, As-Built Notice (ABN) 5848-1 was then issued in

November 1987 to attach this spare parts list to the Vendor

Manual.

The intent was to continue using the installed Brush

fuses unless they failed and required replacement.

Replacements would then be from Gould Shawmut.

The field

configuration was in accordance with that originally supplied

by the vendor.

It should be noted that the vendor had installed and

qualified both types of fuses.

Therefore, no condition

adverse to quality existed in that at no time were

non-qualified fuses installed in the 130V D.C. QA-1 Batti-r

Chargers.

Corrective Actions Taken and Results Achieved:

To eliminate confusion as to the proper fuse to be utilized

in the battery chargers, in November of 1988 the fuses were

replaced with the Shawmut design.

Corrective Actions to Be Taken to Prevent Recurrence:

For tasks that are completed by using procedures, the Fermi 2

Writers Guide requires that occeptance criteria be designated

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RESPONSE TO NOTICE OF VIOLATION 50-341/88031

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Corrective Actions to Be Taken to Prevent Recurrence (cont'):

where necessary.

Additionally, NPP-PS1-01, " Planning of

Maintenance Activities", which was prepared during the recent

Procedures Upgrade Effort, requires that acceptance criteria

be included in the work instruction for those tasks not being

accomplished by a procedure.

As a followup action to strengthen the program. NPP-MA1-02,

" Preventive Maintenance Program" will be revised to

ext iicitly require that acceptance criteria be specified,

where appropriate, for preventive maintenance activities not

being performed using a procedure.

Also, a memorandum will be issued by March 31, 1989 as

required reading for all maintenance planning and support

personnel reiterating the necessity for providing acceptance

criteria in maintenance work instructions.

Date When Full Compliance Will Be Achieved:

The revision to NPP-HAl-02 will be completed by April 30,

1989.

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RESPONSE TO NOTICE OF VIOLATION 50-341/88031

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Statement of Violation 50-341/88031-01B:

In the Notice of Violation, it stated:

When a Production Quality Assurance (PQA) inspector

identified on November 16, 1987, that fuses installed in 130

volt battery charger 2B-2 were not as specified in As-Built

Notice ABN 5848-1, a Deviation Event Report (DER) was not

issued as required by procedure'POM 12.000.52, " Deviation and

Corrective Action Reporting," Revision 3.

As a result, no

action was taken to resolve the fuse size and type

discrepancy.

Discussion:

The subject of the fuses in the safety-related Battery

Chargers was first brought up to Nuclear Engineering (NE) in

June 1986.

Following an evaluation. Preliminary Design

~~

Change (PDC), PDC-5848, Rev.

O,

was issued by NE in December

1986.

The PDC stated that the fuses installed

(i.e.,

the

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Brush SF 13x150 internal fuses) were supplied by the vendor.

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Also, the PDC noted that replacement fuses should be

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classified QA-1 and that since these fuses are not

distributional type fuses normally pulled by plant operations

(i.e.,

they are internal or " instrument" type fuses), they

need not be listed in engineering' specification 3071-128-EJ.

3"

As such, the proper source document for replacements is the

vendor manual.

As noted above in the rerponse to part A of

this violation, the vendor manual, at that time, did not

contain a list of vendor recommended replacement parts.

Therefore. ABN 5848-1 was issued to include the veador

recommended replacement fuses in t he v e nd o r manu a'.

(Shawmui.

Form 101, 150 Amp fuses were the vendor specified replacement

part).

Several important factors should be noted regarding the

nature of the work packages and the str?ts of equipment

involved in this potential violation.

The work packages did

not involve replacement of the battery charger internal

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fuses.

Only a check to verify proper size and type of fuse

installed wrs specified.

When the QC inspector went to

verify the correct fuse was installed, it was noted that the

fuses installed were not the same as the replacement fuses

specified by ABN 5848-1.

In resolving this question before

the inspector could sign-off on the QC hold point, several

factors were considered.

In relation to correct fuse " size",

both the Shawmut and the Brush fuses are rated at 150 Amp;

i.e.,

either is dimensionally correct.

To verify the correct

" type" of fuses, it should be noted that both are identical,

i.e.,

semi-conductor fusest only the manufacturer differed.

Therefore, these fuses are considered like-for-like fuses.

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In addition as was previously documented in PDC-5848, the

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RESPONSE TO NOTICE OF VIOLATION 50-341/88031

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Discussion (cont'):

installed fuses were supplied by the battery charger vendor

as original equipment.

Based on this information and

considering the fact that replacement of these fuses was not

required, the QC inspector signed-off on the QC hold point

involved.

Based on the above considerations, a DER was not

needed since a non-conforming condition did not exist on

these fuses;

i.e.,

there was no condition adverse to quality

for the safety-related battery chtrgers.

When the same question of proper fuse type and size arose

again in the performance of later work packages

(i.e.,

in

November 1988), Production Quality Assurance wrote DER

88-1977 to eliminate the question permanently.

Again, it

should be noted that the work package did not require

replacement of these fuses.

However, as a result of this

recurring question. Nuclear Engineering recommended in the

resolution of this DER that the Brush fuses be removed and

replaced per ABN 5848-1.

This action was completed on

November 18, 1988.

Accordingly, DECO denies Part B of Violation 88-031-01.

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