ML20093B511

Responds to NRC 840829 Ltr Re Violations Noted in Insp Rept 50-341/84-29.Corrective Actions:Personnel Instructed on Cause & Significance of Error & on Importance of Procedural Compliance.Personnel Responsible for Work Orders Cautioned

ML20093B511
Person / Time
Site:	Fermi
Issue date:	09/27/1984
From:	Jens W DETROIT EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20093B497	List: ML20093B511
References
EF2-69717, NUDOCS 8410100103
Download: ML20093B511 (6)

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1 eo t" syne H. Jens -

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Delloll s $ September 27, 1984 EF2-69717 Mr. James G. Keppler Regional Administrator Region III.

U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137-

Reference:

Fermi 2 NRC Docket No. 50-341

Subject:

Detroit Edison Response Inspection Report 50-341/84-29

.This letter responds to the items of noncompliance described in your Inspection Report No.-50-341/84-29. This inspection was performed by Messrs. R. C. Martin, S. G. DuPont and G. O'Dwyer, and Ms. P. L. Eng on July 16 through August 17, 1984.

The items of noncompliance are discussed in this reply as required by Section 2.201 of the NRC's " Rules of Practice",

Part 2, Title 10, Code of' Federal Regulations.

The enclosed response is arranged to correspond to the sequence of items cited in the body of your report. The number for the items of noncompliance and the applicable criterion is referenced.

We trust this letter will satisfactorily respond to the noncompliances cited in your report. If you have questions regarding this matter, please contact Mr. Lewis Bregni, (313) 586-5083.

Sincerely, J

cc: Mr. P. M. Byron jt[

hgd Mr. S. G. DuPont /

Mr. R. C. Knop D 8410100103 841005 I '

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l 33 THE' DETROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATIONS ORGANIZATION

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RESPONSE TO NRC REPORT NO. 50-341/84-29 DOCKET NO. 50-341 LICENSE NO. CPPR-87

-; s INSPECTION AT: FERMI 2, NEWPORT, MICHIGAN

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INSPECTION. CONDUCTED

JULY 16 THROUGH AUGUST 17, 1984 L

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' RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-29

~ Statement'of Noncompliance 84-29-01, Criterion V 10 CFR 50,. Appendix B, Criterion V as implemented by DECO

c _ z Quality Assurance Manual, Section 9.0.1 requires that

< activities affecting ' quality shall be accomplished in-accordance.with procedures.

ContraryLto the above, during preoperational testing certain

. activities were not-accomplished in accordance with proce-

'dures. This.is evidenced by the following occurrences:

a. While establishing initial conditions for R3000.003, Emergency Diesel Generator Load Profile Test and Load

-Sequencing, test equipment needed to obtain acceptance

- criteria data was not electrically connected as required by the procedure.

b. During performance of R3000.003, test personnel did not operate switches:in the manner specified in the proce-dure causing the "C" core spray pump to be delayed in starting during the test.

c. While establishing' initial conditions for R1102.001 Emergency Safeguards System Auxiliary Electrical System an electrical breaker was not placec in the open posi-tion as required by the procedure.

Each of -these occurrences required retesting to be performed for the affected sections of the respective preoperational tests.

Corrective Action'Taken and Results Achieved-

.This item involves three examples of failure to follow approved procedures due to personnel error.

Two of these examples occurred during R3000.003, EDG Load Profile and ' Load Sequencing Preoperational lre:st.- The other example occurred during R1102.001, ESF Auxiliary Electrical System Preoperation Test.

In each instance, the personnel involved in the error were instructed on the specific cause and significance of their error. The importance of exact procedural compliance and attention to detail were emphasized.

Additionally, the initial conditions for each test were re-established in accordance with the appropriate test procedure and the tests were repeated successfully.

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RESPONSE TO NRC INSPECTION REPORT l NO. .50-341/84-29 Corrective Action Taken to Avoid Further Noncompliance Each of these- examples was discussed at the Startup Group weekly staff meeting. This discussion included the details of the event.and the possible causes for each type of personnel error.- Strict. compliance with procedures and attention to detail were identified as essential to personnel and-equipment safety and to assure the validity of the test results.

Date-When' Full Compliance Will Be Achieved Full. compliance has been achieved.

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w 50-341/84-29 1 RESPONSE TO NRC . INSPECTION REPORT NO.-

')f , LS tatementLof' Noncompliance 84-29-02, Criterion V.

l10 CFR;50,' Appendix B, Criterion V and ANSI N18.7-1976~,

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E-Section 5.3,:as implemented by-DECO Quality Assurance ~

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-Manual, Section19.0.1, requires that activities ~affecting (qualityf shallJbe prescribed by _ appropriate written instruc-I', -

- tions,; procedures,for drawings, and accomplished in accord-

., ance with .these documents.-

. Contrary to the above, preventative maintenance activities

.to. clean Lthe Emergency Diesel Generator 14 Lube Oil Filter 9, ' Land _ corrective maintenance activities on a Residual Heat

! Removal System Valve were'not performed by appropriate,

' approved, --_ written procedures.

Corrective Action Taken and Results Achieved Personnel. responsible:for the preparation and approval of'

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theser work orders had' assumed that these maintenance items

, were within the' capability of the craft. This assumption

. wasibased onftheir knowledge of General Maintenance c p

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Journeyman job descriptions and the existing training 1

. ' programs. . The-individual preparing the' lube oil filter package _did --not _ adequately - review existing procedures . for i- uthis ! maintenance itera. .The individual preparing the package affecting the_ Residual 1 Heat Removal (RHR) system valve did

.not' recognize that the_ electrical disconnection and removal of'.the_Limitorque' operator warranted the use of an-approved procedure. In each case, craftsmen _were provided' l, handwritten instructions on the " Attachment A" to the work ordere m :.

Th'e'immediate corrective action consisted of the following:

, , -o" ' Work Yorders 'were initiated for . EDG .No.13 and -No.14 to n . .verifyLthat the lube oil' cartridges are : installed in accordance with POM .34.000.14, " Emergency Diesel g Generator ~ Inspection."

to - The QC' inspections which were part of the original m#. -work ' order verified that the affected RHR systemi

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Limitorque. valve operator was properly installed.

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. RESPONSE TO NRC-INSPECTION REPORT NO. 50-341/84-29

-Corrective Action Taken to Avoid Further Noncompliance To avoid recurrence of the specific problem with changing

-the EDG lube oil filters, the computerized preventative maintenance program sheet _will be revised to reference Maintenance Instruction M-136 " Emergency Diesel Generator-Preventive Maintenance". This instruction was revised to incorporate the' requirements of POM 34.000.14.

To-: avoid recurrence of the specific problem with the removal of Limitorque valve operators, a new Maintenance Instruction MI-M328, "Limitorque Installation and Removal," has been written for the removal and' installation of Limitorque valve

-operators. This instruction will be included in the appropriate' future work orders. Personnel responsible for the preparation of work orders have been instructed to include Maintenance Instruction M-047, " Motor and Generator Terminators," as part of work orders which' involve motor and generator determinations or reterminations.

Administrative Procedure 12.000.15, provides guidance for the use of procedures for routine and non-routine maintenance. Personnel-involved in the preparation of-maintenance work orders have been advised of the details of

'this noncompliance and cautioned against writing maintenance instructions without. first thoroughly reviewing existing -

instructions and procedures. -Additionally, these individuals' have been alerted to the need to identify tasks where OSRO approved procedures may be appropriate.

Date then Full Compliance Will be Achieved Full compliance will be achieved by October 1,1984.

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