IR 05000341/1993002

Insp Rept 50-341/93-02 on 930123-0211.No Violations Noted. Major Areas Inspected:Previous Insp Finding,Audit Program, Auditor Qualifications,Audit Repts & Audit Exit Meetings

ML20128M292
Person / Time
Site:	Fermi
Issue date:	02/11/1993
From:	Kropp W, Phillips M, Twigg R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20128M282	List: IR 05000341/1993002 ML20128M277
References
50-341-93-02, 50-341-93-2, NUDOCS 9302220130
Download: ML20128M292 (5)

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U.S. NUCLEAR REGULATORY CONilSSION REGION 111

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Report No. 50-341/93002(DRP)

Docket No. 50-341 License Nos. NPf-43 Licensee: Detroit [dison Company 2000 Second Avenue Detroit, MI 40226 ,

facility Name: fermt 2 Inspection At: fermi Site, Newport, Michigan Inspection Conducted: January 23 through February 11, 1993 Inspectors: W. J. Kropp gA C Approved By , hief 'A / 7 Reactor Projects Section 28 Date

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-Jnspection Summary:

Insnection from January 23 throuah February 11. 1993

,(Report No. 50-341/92002(DRP1)

Areas Insnectad: Routine, unannounced safety inspection by the resident inspectors of action on a previous inspection finding; the audit program; ,

auditor qualifications; audit reports; and audit exit meetings (Inspection Procedure (IP) 40702).

Results: No violations or deviations were identified. One previous inspection finding concerning the Service Information Letter (SIL) process was closed. The inspectors determined through sampling of auditor qualifications, audit reports, and audit exit meetings that the. licensee has developed a quality assurance program that is in conformance with Technical Specifications, regulatory requirements, commitments in the Updated Final Safety Analysis Report, and industry codes and standards. The inspectors concluded that the overall effectiveness of the audit program was good. The qualifications _of the auditors were good, and the auditors application-of performance based techniques was excellent. Overall the audit reports were thorough and adequate in reporting the results documented in the checklist One Inspector followup Item was identified that pertained to documentation:and followup of audit observations. The communication of. audit results during

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exit meetings'was good, l

9302220130-930211-PDR ADOCK 05000341 0 PDR -

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VGAILS En igns Contacted: ,

Detroit Fdison Company

• W. Orser Senior Vice President, Nuclear Operations

• R. McKeon, Plant Manager, Nuclear Production

• W. Miller, Superintendent, Technical Engineer

• R. Newkirk, General Director, Regulatory Affairs -

• J. Plona, Superintendent, Operations

• J. Tibai, Supervisor, Compliance

• J. Bragg, Principal, Quality Engineer Audits

• T. Braddith, Supervisor, Quality Program Assurance

• L. Goodman, Director, Nuclear Quality Assurance

• Denotes those attending the exit interview conducted on February 11, ,

199 > Action on Previous 1.ospection findinas (92701)

Klpied) Unresolved item (341/92017-05 (DRP1): In September 1988, the licensee had received General Electric (GE) Service Information Letter (SIL) 470 which identified concerns with reactor water level mismatche Two of the recommendations provided by the SIL for reducing the chances of unexpected water level mismatches were backfill the process ,

instrument piping after surveillance testing, and train plant operations personnel in appropriate methods for responding to mismatches between water level instrument . indications. The licensee evaluated the Sll under Deviation Event Report (DER) 88-1833 and decided not to implement the two recommendations mentioned above. After a subsequent reactor water level scram, documented in LER 90011, the licensee determined that the recommendation for backfilling the reference legs should have been implemented and issued DER 90-625 to reevaluate GE SIL 470. Pending a review of DER 90-625, the Sil process was considered an Unresolved item *

in inspection report 9201 The inspectors selected.four GE SILs, reviewed the disposition of DER 90-625 and evaluated the licensee's resolution of the GE ..

recommendations. The inspectors did not identify any concerns wi(b the GE Sils, the DER, or the resolution of the GE recommendations. Based on these reviews, the inspectors consider this item close . Audit Proaram (40702)

The effectiveness of the Fermi audit program was assessed by the inspectors in the areas of auditor qualifications, audit reports, anu audit exit meetings. The inspectors verified that the scope of the audit pogram was defined and .that the responsibilities for overall management of the program were assigne Overall assessment of the program was goo .

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a. tmdilpr Qualificationi Based on interviews with auditors and reviews of personnel records, the inspectors determined that the qualifications of the audit personnel were good. The auditors' backgrounds included maintenance, Senior Reactor Operator and Reactor Operator qualifications, engineering degrees, and specialized industry training in several disciplines. When needed for specific audits, the licensee obtained special expertise from other fermi or industry employees. Through discussions with the licensee, the inspectors verified that no auditor was allowed to participate in an audit of an area in which he had any artor direct responsibilities. Any indirect responsi)ilities were reviewed on a case by case basis to ensure the independence of the audito The inspectors reviewed a sample of audit checklists and found the checklists to be comprehensive and relevant to the scope of the audit. The issues identified by the auditors and documented in the sample check'.ists demonstrated that performance based audits were conducte The auditors' application of performance based audit techniques was excellen b. Audit Reports The inspectors reviewed the following audit reports to assess their effectiveness in reporting audit results to management as documented in the audit checklist:

• Audit Report 91-0105 " Evaluation and Corrective Actions"

• Audit Report 91-0130 " Operations"

• Audit Report 91-0193 " Preventive Maintenance"

• Audit Report 91-0215 " Selected Electrical I&C Design Calculations"

• Audit Report 92-0070 " Evaluation and Corrective Actions"

• Audit Report 92-0084 " Operations"

• Audit Report 92-0097 * Corrective Maintenance"

• Audit Report 92-0109 " Tech Spec Surveillance"

• Audit Report 92-0129 " Evaluation and Corrective Actions"

• Audit Report 92-0146 " Maintenance-PM Program"

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overall, the audit reports were thorough and adequate in reporting the results documented in the checklists. The audit process consisted of observations categorized by three levels of required actions. The most significant observations were classified as

" findings" and required formal reviews through the Deviation Event Report (DER) process. Other observations were divided into those requiring written responses from the audited organization and those that required only a review in the next audit. Those observations that were classified as findings or that required written response were adequately documented and followed u However, the inspectors were concerned with the ability of the audit program to document and followup on the audit observations not requiring written respons An example is Observation #6 of Audit Report 91-0193, Preventive Maintenance. The observation noted the increased savings and greater efficiency in the maintenance department that could result if predictive data on oil sampling was used more effectivel The observation identified only one component f ailure (EDG air compressor) where oil sample information was not ef fectively utilized. However, the audit checklist covered the period from November 18 through December 6, 1991 and identified three significant examples where components failed. The failures involved an air compressor for an emergency diesel generator (EDG); the South Heater Drains Pump (SilDP); and the North Off-Gas Ring Water Pump (NOGRWP). Two of the failures were related to the effectiveness of the licen.ce's oil sampling program (EDG and SHDP), while the other pertained to not finding enough oil in the reservoir to take an oil sample (NOGRWP). Also, during the audit, the High Pressure Coolant injection (llPSI) pump failed a surveillance that was subsequently determined to be attributed to water in the oil. The audit checklist also identified other older examples of components that had water ingress into the oil which were not handled administratively in an effective manner. Even though the audit checklist documented an issue with the licensee's '

predictive maintenance program in the area of oil sampling, the observation written for the audit report did not identif) the problem and required no written response. The inspectors were concerned that the significance of the oroblem with administering the oil sampling program was not adequately identified for senior management not present at the audit exit meeting. An additional concern was adequate followup. The inspectors determined that the licensee initiated actions to improve the oil sampling program soon af ter the audit, but the audit of the preventive maintenance program conducted in late 1992 ( Audit Report 92-0146 ) did not include assessment of the effectiveness of those actions. No surveillance has been performed on the oil sampling program since the performance of Audit 91-0193. The documenting and followup of audit observations is considered an Inspector followup Item pending further NRC review (341/93002-01 (DRp)).

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i Audit Exit Heeting1 By observing an audit pre-tait and an audit exit, the inspectors determined that verbal cornunicaticn of the audit results was good. in discussions with :ne licensee, the inspectors found that the audit organization vier! the esits as a means to communicate details not included in the audit reports. Both the exit and pre-exit were well delivered an: focad to be a good exchange between the auditors and those prerin .

4. Inspection Followun items Inspection followup items are mat:ars wh'ch have been discussed with the licensee, which will be reviewed :y the inspector and which involve some action on the part of the NRC or 'icenset or both. An Inspection Followup Item disclosed ducing tbt inspe: tion is discussed in paragraph . Exit interview (30703)

The inspectors met with the licensae representatives denoted in :

paragraph I during the inspection seriod and at the conclusion of the inspection on February 11, 1993. The inspectors summarized the scope and results of the inspection and fiscussed the likely content of this inspection report. The licensee teknowledged the information and did not indicate that any of the info mation disclosed during the inspection could be considered proprietary it natur .

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