IR 05000341/1989015

Insp Rept 50-341/89-15 on 890515-19.Violation Noted.Major Areas Inspected:Allegation Re Operation of Facility

ML20247N302
Person / Time
Site:	Fermi
Issue date:	05/31/1989
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247N291	List: IR 05000341/1989015 ML20247N285 ML20247N296
References
50-341-89-15, NUDOCS 8906050309
Download: ML20247N302 (9)

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U.S. NUCLEAR REGULATORY COMMISSION-REGION III-Report No,' 50-341/89015(DRP) License No. NPF-43 Docket No. 50-341-Licensee: The Detroit Edison Compan North-Dixie Highway-Newport,.MI 48156

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Facility Name: ' Enrico Fermi Nuclear Power Plant, Unit 2

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Inspection At: Fermi 2 Site, Newport, Michigan Inspection Conducted: May 15-19, 1989 Inspector: J. McCormick-Barger

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Approved By:

Sc4 R. C. Knop, Chief g 3g/

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I Reactor Projects Branch 3 Date Inspection Summary Inspection on May 15-19, 1989, (Report No. 50-341/89015(DRP))

.Kreas Inspected: Special, unannounced safety inspection with regard to an allegation related to the operation of the Fermi Facilit Results: One violation was identified in Paragraph .

8906050309 890531 PDR ADOCK 05000341 Q PDC r

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DETAILS 1. Persons Contacted Detroit Edison Company

• S. Catola, Vice President, Nuclear Engineering and Services

• S. Orser, Vice President, Nuclear Operations

• V. Cranston, General Director, Nuclear Engineering

• Goodman, Director, Nuclear Licensing

• G. Walker, General Supervisor, Plant Engineering

• J. Wald, Supervisor, Quality Engineering

• A. Bryer, Supervisor, Material Engineering Group

• E. Kremer, Supervisor, Nuclear Procurement

• C. Settles, Supervisor, Technical Engineering

• P. Anthony, Compliance Engineer NRC Staff

• Rogers, Senior Resident Inspector, Fermi

• S. Stasek, Resident Inspector, Fermi

• J. McConnick-Barger, Reactor Engineer RIII Other Fermi staff members were contacted during the inspectio * Denotes those attending the May 19, 1989 exi . AllegationReviews(92701],

Allegation No. RIII-88-A-0001 . Allegation No. RIII-88-A-0001 was initially reviewed from March 8 through September 20, 1988. This review was reported in Inspection Report No. 50-341/88008(DRP), dated November 23, 1988. The following is an additional concern associated with this allegation and the results of the NRC inspector's revie Concern The former Material Engineering Group (MEG) supervisor refused to approve some Deviation Event Reports (DERs) prepared by his subordinates or allow them to go to the Fermi Safeteam (a group set up to review employee concerns) or the NRC with plant concern These activities occurred prior to 1988. The alleger provided three examples of DERs that the former MEG supervisor would not approve l and an Engineering Evaluation Disposition Fonn written by MEG instead of a DE NRC Review The inspector received information from the alleger and information provided by another individual in Safeteam file number 6374 that included copies of three DERs that were allegedly prepared by MEG l 2

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employees but no't signed and processed by the fomer MEG superviso The Safeteam file documented concerns similar to what was alleged above. The Safeteam organization was not able to substantiate that MEG employees were not allowed to go to the Safeteam or NRC. The Safeteam report stated that the complainant had not suffered discrimination as a result of the generation of this Safeteam concern and subsequently voluntarily discontinued employment at Fe mi . However, the Safeteam did confirm that the supervisor would not sign some DERs. The Safeteam file indicated that the supervisor stated that he would refuse to sign DERs that addressed programmatic problems already identified in other DER The following is a general description of each of the three specific examples of MEG employee concerns that were not approved as DERs by the former MEG supervisor: " Failure to Follow Material Issue and Return Procedure 12.000.029" - IRM detector high voltage power supply GE part No. 112C2220G3 stocked as Non-Quality (NQ) stock No. 654-6561, was issued for use in safety-related application PIS N C51K601D per Request on Stores (ROS) No. 117170, dated December 1,1986, without material engineering technical review and upgrading to QA Level I. The material was issued by the warehouse without MEG concurrence for its intended applicatio This DER was signed and dated by the initiator on December 7, 198 " Failure to follow procedure on QA1 Equipment Modification including documentation of rework effort" - The instrument shop modified a QA1 stock item E41K615, "HPCI Pump Flow Rate Controller," without providing the source and QA level of the replacement C401 Capacitor (or resistor) on the manual amp board, including identifying the applicable procedure and solder certification of the technician that performed the installation, and the results of pcst maintenance testin This DER was signed and dated by the initiator on June 19, 198 " Failure to Maintain Accuracy of SPRS" - The spare parts reference system (SPRS) should be maintained in accordance to the MEG supervisor's memorandum dated April 8, 1986, and in

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accordance with procedure 12.00029, Revision 17 dated July 1987. The DER listed several errors in the SPRS and stated that many others existed. The author of the DER recommended that either the SPRS be corrected or the procedure changed to not allow plant staff to rely on the SPRS as a sole reference to determine acceptable spare parts. This DER was signed and dated by the initiator on July 24, 198 The three authors of the above DERs stated that the supervisor would not sign them because he felt the issues had already been identified by numerous other DERs and that issuing more DERs would not be useful. The inspector contacted the former MEG supervisor a informed him of the unsigned DERs. The supervisor stated that he

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didnotrecall'thefirstorthirdDERs(itemsaandcabove)and

> stated he did not believe the third DER had ever been provided to !

him for his si The supervisor did recall the second DER

'(itembabove)gnature.and stated that he did not sign it because other DERs had identified similar problems and the plant was in the

. process.of revising procedures and had conduced significant amounts of training to correct the programmatic concern. Note: The specific concern identified in the DER (item b above) was resolved by the DER initiator prior to writing the DE The Safeteam file documented many of the activities that the )

licensee performed to resolve each of the three programmatic l concerns documented in the three DERs described above. In addition, Inspection Report No. 50-341/88008(DRP) also discussed  ;

the licensee's activities, mostly performed after the DERs were written, to address the problems identified. Although the programmatic concerns identified by the DERs had been identified by other DERs and corrective actions were or had been taken to attempt to resolve the programmatic aspects of the deficiencies, the DERs still appeared to be valid and should have been processed to aid the plant in assessing both the immediate actions that had been taken and the effectiveness of any of the long term corrective actions that were planned and/or may have been taken to address the earlier DERs. Fermi Procedures 11.000.52 and later 12.000.052,

" Deviation and Corrective Action Reporting," was established during

.the timeframe the DERs were written to control the processing of DER In these procedures, Section 2.0, " SCOPE " states that DERs shall be implemented for conditions adverse to quality of safety-related activities, items, and services. Section 7.1 in POM 11.000.52 and 8.1.4 in P0M-12.000.052 states that the supervisor shall review the DER and if he agrees that a Condition Adverse to .

Quality (CAQ) exicts, shall' sign the DER. If the supervisor feels no CAQ exists, he shall return the DER to the initiator with a written explanation. Failure of the supervisor to either sign the ;

DERs and process them or provide the initiators with a written explanation adequately justifying the reasons why a CAQ did not exist is considered a violation of NRC requirements (341/89015-01).

The inspector interviewed available members of the MEG staff that had worked for the former supervisor and/or the current superviso The inspector also interviewed selected staff members that currently work for the former MEG supervisor in a different engineering  !

organization. No additional examples of DERs not being processed were identified. With the exception of the alleger and the individual who made the Safeteam compliant, no staff members stated that they were ever told they could not go to the NRC or Safeteam and felt tha't their former and/or current supervisors follow Fermi procedures and NRC regulations. In addition, significant changes to the DER procedure have occurred which should help to prevent recurrence. For example, the DER procedure no longer requires supervisors to sign DERs and the initiator may remain anonymou The inspector reviewed Engineering Evaluation Disposition form (EEDF)

No. 4024, dated March 18, 1987, alleged to have been used instead

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of a DER. This EEDF identified an installed lube oil circulating pump motor that was purchased and installed as a non-safety-related component but should have been purchased and installed as a' Quality Assurance Level 1 (QA1) safety-related component because it was fed from a QA1 power supply. The actual motor application was considered non-safety-related non-QA1. Engineering performed a material upgrade review and dispositioned the EEDF by stating that the installed motor met the safety-related QA1 requirement Failure of the MEG to also write a DER to evaluate the root cause of the installation error, and to trend the deviation was a violation of the licensee's DER procedure-(P0M-12.000.052) which requires a DER for items identified as conditions adverse to quality of safety-related activities, items, and services. However, after MEG completed its disposition of the EEDF, the Project Quality Assurance Organization rejected it during its final EEDF concurrence review and wrote the required DER which was subsequently dispositione Conclusion This concern was partially substantiated. The inspector reviewed the concerns identified in the three DERs and one EEDF (that the former MEG supervisor allegedly did not process deficient conditions in accordance with the DER procedure) and determined that DERs should have been written. Not processing the concerns identified in the -

three DERs is a violation of NRC requirements. The inspector was unable to substantiate that the supervisor did not allow employees to go to the NRC or Safeteam. However, the alleger and one other MEG staff member did submit formal complaints that they were told by their former MEG supervisor not to go the NRC or Safeteam. Since the alleger provided only one example where MEG used an EEDF to j disposition a condition that should have required a DER but was not written by MEG, and this example resulted in PQA rejecting it  ;

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and writing a DER, indicating that in at least this case the Fermi QA program worked, the inspector had no further concern in that  :

area. This concern is considered close B. The inspector met with the alleger on May 15, 1989, to obtain specific examples of DERs that were not allowed to be processe During that meeting, the alleger provided the following new concerns: ,

Concern No. 1 The MEG uses Potential Design Change (PDC) forms to document and resolve lead design document discrepancies rather than required DER NRC Review During the inspector's interviews with MEG staff members and current MEG supervision, the inspector was told that when lead design document  ;

discrepancies are identified and MEG verifies that installed hardware is not affected and the discrepancy is not a significant condition adverse to quality, a PDC is generated to request engineering to

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correct the lead design document. The inspector was informed that this was in accordance with the licensee's PDC procedure and its Lead Design Document Index procedure. The inspector reviewed copies of Fermi Management Directive FMD-CMI, " Design Control," Revision 1, dated January 13, 1989, and Fenni Implementing Procedures FIP-CMI-04,

" Lead Design Document Index," Revision 1, dated March 28, 1989, and FIP-CMI-01, " Potential Design Changes," Revision 2, dated April 12, 1989. FIP-CMI-04, Section 5.5, states that discrepancies between the as-built condition in the plant and the lead design document are to be addressed by initiation and disposition of a DER, if appropriate, or other formal processes, such as a PDC. FIP-CMI-01, Section 5.5, states that MEG can disposition vendor part number change PDCs that do not result in a plant modification. Although the above imple-menting procedures imply that a PDC is appropriate to resolve lead dcsign document discrepancies, the Fermi Management Directive appears to indicate otherwise. FMD-CM1, Section 4.11.1, states that a DER shall be initiated for deficiencies in approved desig The inspector reviewed a list of MEG initiated PDCs issued in the past year and picked 18 for closer review. From this sample, the inspector identified one PDC that represented an example of a PDC that identified a discrepancy between the lead design document, in this case, the Central Component Data Base (CECO), and the as-built condition of the plant. PDC-10153 stated that CEC 0 listed Aschroft gauge for component No. PIS D11RA07 as Model No.1009ALXVC-02B when the catalog ordering information and a telecon with the vendor stated that the number should be 251009AWLXUC-028. The PDC also stated that the installed gauge (as-built condition of the plant)

was the same model number as identified by the vendor and catalo Since the CEC 0 data base is the lead design document and was in disagreement with the actual as-built condition of the plant, this example of a MEG initiated PDC substantiates the allegatio Although the licensee's management contends that issuing PDCs for minor lead design document discrepancies, that do not involve a condition adverse to quality, is in accordance with its administrative control program, the NRC has several concerns. By bypassing the DER program, the licensee does not appear to have a clearly defined program for determining the root cause of the deficiencies or for trending the deficiencies to determine if additional corrective actions are needed, such as identifying and correcting other lead design deficiencies and/or taking actions to prevent recurrenc Not writing a DER when identifying design document discrepancies appears to conflict with the Fermi Management Directive discussed above. Also, the NRC is concerned that the PDC process, rather than the DER program, may not assure that these design document discrepancies are receiving adequate engineering and QA reviews for considerations such as seismic and environmental qualification, and other design related analyses that may be necessary when components originally thought to be installed are later found not to be. Resolution of the above concerns will be tracked as unresolved item 50-341/89015-02. The licensee was asked in the i

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cover letter to this inspection report to provide a written response to these concerns, f 6

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Conclusion i

This allegation was substantiated. It is the licensee's standard i practice to use PDCs to document and resolve minor lead design- J document errors. Several NRC concerns were identified as a result 1 of the licensee's- practice of not writing DERs to address some  !

design document deficiencies. NRC followup of these concerns will be addressed in the resolution of unresolved item 50-341/89015-0 This allegation concern is close i

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Concern No. 2 The alleger provided a memorandum dated January 15, 1988, from the new MEG supervisor to MEG personnel informing them to discontinue the practice of placing'a note on Inspection Report Fonns (IRFs)

requiring material to be placed on OC hold pending the issue of ,

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a PDC or Engineering Design Package (EDP). The alleger stated that this memorandum was directing the MEG personnel to not perform a task that is required by procedure NE 6.11 PCN No. NRC Review The inspector obtained a copy of Nuclear Engineering procedure NE 6.11 " Technical Review of Procurement Documents," Revision 0, dated March 6, 1986. Procedure Change Notice No. 2 directed the MEG reviewer to reference on the IRFs, the applicable design document and required Quality Control to verify that the design

' document was approve The inspector discussed this issue with the MEG supervisor and was told the memorandum was issued prematurely in anticipation of a

' future procedure change. This concern was previously transmitted to the licensee. The licensee responded to the issue on April 19, 1988. On Page 2 of the attachment to its response, the licensee concurred that the memorandum was in error and stated that DER 88-0088 was issued to address the use of memorandums by MEG to control safety-related activitie Although the use of a memorandum to change requirements specified in an approved procedure is not in accordance with Fermi procedures, the issue of placing or not placing material on hold until the applicable design document is approved has little or no safety significance. This is because the material could not be issued or used until the applicable design documents are approved. The inspector has determined that the licensee's corrective actions to address this. concern, which included incorporating all applicable memorandum guidance into approved procedures and discontinuing i the memo practice, are adequat Conclusion The concern was substantiated. The action taken by the licensee to correct the deficiency appears to have adequately resolved the concern. This issue is considered close . -- . _ _ _ _ - - _ _ _ _ - _

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l Concern No. 3 The plant is ordering material as non-quality items with the intent i

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l of having HEG upgrace the material to quality related after arrival onsite to expedite procurement time. No examples of this activity were provided by the allege NRC Review The inspector interviewed a large portion of the MEG staff and was unable to find a staff member that had any knowledge of the alleged j activity. During the NRC's previous review of this albgation, I reported in Inspection Report No. 50-3t.1/88008(DRP), the NRC L reviewed several examples of MEG's material review and upgrade activities and found them to be acceptable (section 3.: of the inspection report). Since MEG material upgrade activities appear to be acceptable, there should not be a sigificant safety issue if material is ordered as non-safety-related and subsequently reviewed and appropriately upgraded for a safey-related applicatio Conclusion Due to lack of specific examples, or corroboration frc:n MEG staff members, this concern was not substantiate If the activity alleged did occur, it should not result in a significant safety concern since MEG would still be required to perform upgrade analyses. This concern is considered close Concern No. 4 The alleger provided two material stock numbers for filters that were manufactured by different vendors but intended for the same application. The alleger stated that the inspector should review the licensee's material program and determine if the licensee has adequate engineering approval for the use of the filters in their intended safety-related application. This review would substantiate that the licensee's material program is still not working correctl NRC Review The inspector had the licensee access its Spare Parts Reference System (SPRS) and enter the s.tock numbers provided. The SPRS indicated that both filters were intended for the same plant component. However, the SPRS also stated that a MEG review would be required prior to the material being used to assure that it conforms to the design requirements. This SPRS notation is part of the licensee's commitment to validate the SPRS before it can be used. This commitment was documented in the licensee's attachment to a letter to the NRC dated April 19, 1988. Determining that the filters require MEG review prior to use indicates that the licensee's commitment is being implemete _ _ _ _ _ - - - - - - . - - - - - - .

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Conclusion This concern was not substantiated. The SPRS listed the filters'

stock numbers as having the same inte d use but did not allow the filters to be used until the filt were reviewed and approved by MEG. This concern is considered close . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. An unresolved item disclosed during the inspection is discussed in Paragraph . Exit Interview (30703)

The inspector met with licensee representatives (denoted in Paragraph 1)

on May 19, 1989, and sumarized the purpose, scope, and findings of the inspection. The inspector discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents or processes as proprietar , 1

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