ML20246P047
| 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..
1
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
)
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,
. Og Q
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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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DCD/DCB(RIDS)
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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
U.
S.
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.
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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A.
B. Davis
R.
C. Knop
W.
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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