NRC-87-0243, Responds to Violations Noted in Insp Rept 50-341/87-28 Re QA & Preventive Maint Programs.Corrective Actions:Task Force Developed & Review of Preventive Maint Tasks for Safety Significance Conducted
| ML20236P123 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/13/1987 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-87-0243, CON-NRC-87-243 NUDOCS 8711170153 | |
| Download: ML20236P123 (8) | |
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g B. Rilph Sylvl3 Group Wce President I
Detroi.t m
m ums Edison =w-,
i Novenber 13, 1987 NIC-87-0243 i
U. S. Nuclear Pegulatory Commission i
Attn: Document Control Desk j
Washington, D. C.
20555
References:
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Fermi 2
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NIC Docket No. 50-341 NFC License No. NPF-43 i
2)
IE Inspection Report No. 50-341/87028 dated October 16, 1987 3)
Detroit B31 son letter NIC-87-0081, i
dated June 12, 1987 4)
Detroit Ddison letter NIC-87-0176, dated October 1,1987
Subject:
Response to Notice of Violation 50-341/87028 i
Reference 2 identified violations related to the Fermi 2 Quality i
Assurance and Preventive Maintenance programs. Detroit Edison's response is attached.
We trust this letter satisfactorily responds to your concerns. Please contact Mr. Lewis Bregni at (313) 586-4072 if you have any further questions.
Sincerely, c/l y
Enclosure cc: Mr. A. B. Davis i
Mr. E. G. Greenman
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Mr. W. G. Rogers Mr. J. J. Stefano l
USNIC Region III j
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8711170153 871113 8
PDR ADDCK 05000341
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I Enclosure to NIC-87-0243 i
Page 1 RESPONSE 'IO NC71' ICE OF VIOLATION 50-341/87028 I
Statement of Violation i
Fermi 2 Technical Specification, Section 6.8.1, requires that procedures for preventive maintenance, which can affect the performance of safety-related equipment be established, implemented, i
and maintained. Additionally, Fermi 2 Technical Specification, Section 6.8.4, requires that programs including preventive maintenance, be established, implemented, and maintained to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident.
l Contrary to the above, the licensee failed to inplement, or inplement on schedule, the preventive maintenance program for a significant number of couponents (more than 5,000), including those associated with residual heat removal (RRR), high pressure coolant injection (HPCI), remtor core isolation cooling (ICIC), and emergency core cooling water (ECCW) systems.
This is a Severity Level IV violation (87028-01).
Corrective Actions Taken and Results Achieved The cover letter to Reference 2 requested that Detroit Edison evaluate the effect that never-performed and past due Preventive Maintenance items have on the reliability and operability of the affected systems, to reassess the priorities assigned to the PM items an3 to provide plans to inplement a program to reduce the Preventive Maintenance backlog to an acceptable level. In response to these concerns, a task force was developed and a review of the PM tasks for safety significance was conducted. The PM tasks were assigned priorities (A or B) depending on their safety significance. The safety-significant PM ectivities (Priority A) that had not been previously conpleted within the PM Program were identified. A review of equipnent history was next performed to detennine whether the PM activity had been satisfied during the performance of other maintenance activities.
This resulted in the identification of 757 Priority A PM items that had not been previously coupleted either through the PM Program or through other maintenance tasks. These 757 Priority A PM totivities were then evaluated to determine when each activity was required to.be conpleted. Eighty-eight (88)' activities were identified as being required to be conpleted prior to plant restart. These wre issued
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Enclosure to NEC-87-0243 Page 2 l
1 and conpleted during the 87-06~ outage in July / August,1987. An evaluation of the remaining non-coupleted Priority A activities was-then performed to ensure that deferral of each activity would not J
inpact the reliability and operability of the affected system.
206 of the original 757 non-conpleted Priority A activities have now been conpleted. This includes the 88 non-deferrable activities conpleted during the 87-06 outage. The remaining 551 activities will be conpleted as schedule allows, but no later than prior to startup'
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following the LIRI' outage.
1 Corrective Actions to be Taken to Avoid Further Violations 1
To ensure that safety.significant. Preventive Maintenance (PM) activities are conpleted on schedule in the future, the PM Procedure (12.000.17) is being revised to require Priority A PM's not coupleted.
In the month they are scheduled, to be identified and evaluated. If postponement of the PM cannot be justified, then a Deviation Event f
Report (DER) will be written to document the missed PM and to obtain
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formal Engineering evaluation of the situation. A report will be 1
issued monthly to the Superintendent - Maintenance & Modifications
.f identifying the Priority A PM activities that were not conpleted.
-l This report will identify the piece of equipment, a description of the PM task to be performed, the safety significance of not performing the
-j activity, the new. scheduled coupletion date and the justification _ for the schedule.
p_gle_of Fu11 Coneliance q
t Procedure 12.000.17 will be revised by December 1,1987. The remaining 551 Priority A PM activities discussed above will be j
conpleted prior to startup following the LLRT outage, which is presently scheduled for March, 1988.
Enclosure to NIC-87-0243 Page 3 Statement of Violation 10CFR50, Appendix B, Criterion II, as implemented by Detroit Mison Conpany Operational Quality Assurance Policy 2, " Quality Assurance Program," requires that the Quality Assurance Program shall provide control over activities affecting the quality of the identified structures, systems, ard conponents, to the extent consistent with their inportance to safety, and requires that stivities affecting quality shall be accomplished under suitably controlled conditions, including assurance that all prerequisites for the given activity have been satisfied.
Contrary to the above, the licensee failed to identify the IDG 13 fuel oil day tank level indicators as safety-related ard TS related on WR No. 648693, which resulted in work instructions being prepared, work i
being performed and closed out as if the conponents wre non i
safety-related and non TS related and the licensee failed to provide ad~1uate controls consistent with the conponents inportance to safety.
This is a Severity Level V violation (87028-04)
Detroit Edison's Position and Actions Detroit Edison does not necessarily agree with the violation as written. Specifically, Detroit Mison does not agree with the implication that all Technical Specification-related equipment should be classified as safety-related., The "important to safety" issue has a long history and is one that has not yet been resolved. This violation involves a level indicator that is used to verify a level of l
at least 210 gallons of fuel in the Emergency Diesel Generator Day Tank on a daily basis. The indicator serves no active safety-related purpose and its failure would not preclude proper operation of the Emergency Diesel Generator. The level of fuel in the day tank is the inportant element; the level indicator nerely provides a nethod of l
determining this level. Should the level indicator not be operable, alternate rethods of determining level in the day tank would be rceptable. The Technical Specification sinply requires a certain level to be verified on a daily basis with no reference to a level indicator, a level measuring rod or other neasuring device.
Detroit Edison agrees that instrumentation used to fulfill Technical Specification requirements must be accurate and reliable and has been evaluating methods to ensure that this instrumentation is maintaino3 in a satisfactory manner. The tentative plan is to identify the instrumentation used to fulfill Technical Specification requirements, and to classify ard maintain it as Quality level 1M.
Replacement
il Enclosure to NRC-87-0243 Page 4 parts will meet the same criteria as that originally specified and/or.
purchased and installed.
Detroit Edison will couplete its. evaluation of this tentative plan by-1 Decenber 31,1987 and will keep the NBC resident inspector informed as this evaluation progresses. Presently, the I&C Surveillance Procedures Improvement Program described in. Reference 3, and the.
1 detailed technical' review of Technical Specification surveillance-i requirements described in Reference.'4 are underway. and will' provide, a-list of Technical Specification-related instruments as described above. An update.of this response along with specific conpletion j
dates will be provided by Decenber. 31, 1987.
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Enclosure to NFC-87-0243 I
Page 5 Statenent of Violation 10CFR50, Appendix B, Criterion XVIII, as inplenented by Detroit Edison Conpany Operational Quality Assurance Policy 18, " Audits," requires that a comprehensive system of planned and periodic audits shall be carried out to verify conpliance with all aspects of the quality assurance program and to determine the effectiveness of the program, and requires that audits shall be performed in accordance with written procedures or checklists.
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J Contrary to the above, the licensee's auditors and audits failed to l
identify the preventive maintenance issue noted in Violation j
341/87028-01 and failed to conplete checklists, irrluding the j
checklist item on material storage protection level, which resulted in l
failure of the licensee to: verify conpliance with all aspects of the
@ Program; Mequately determine the effectiveness of the @ Program; and identify a significant condition Mverse to quality.
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This is a Severity Level IV violation (87028-08).
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Corrective Actions Taken and Results Achieved i
The Audit Program inplenenting procedure, N@P 1801, was revised during the inspection in July 1987 to require the Audit 'mam Leader (ATL) to assign priorities (high or low) to each checklist item prior to checklist approval. High priority items are required to be l
conpleted during the audit. The ATL is also regulrd to review the i
checklist following the audit to verify that all checklist items have been accounted for and justification has been provided for checklist items not conpleted. NCAP 1801 now also provides guidance concerning acceptable annotation of checklist items.
Training sessions were held with a.L1 ATL's to review the revised j
l procedure. Training was conpleted on August 28, 1967. In Mdition to I
communicating the changes described above, these training sessions l
l were used to reemphasize the inportance of maintaining a global perspective and focusing audits on performance and results of activities being audited.
In addition to the above, the supervisor for the audit function, is reviewing the audit checklist prior to the audit to assure that enphasis is on product and results ard that the checklist identifies high priority items. Periodically, the audit supervisor and @
j management will spend tine in the field monitoring audits in progress l
to assure themselves that their expectations with reference to performance are being met and to provide appropriate fedback to the l
auditors, including coaching where necessary (current @ Program
Enclosure to NBC-87-0243 1
Page 6 requirements stipulate that the supervisor and his manager review,and approve the conpleted audit reports).
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Corrective Actions To Be Taken to Avoid Further Violations The corrective actions described above have been taken to prevent further violations.
D3te cf Full Conoliance l
1 Procedure changes and training identified above have been conp2eted.
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l Actions associated with overview of audits described in the las,t paragraph, above, have been initiated and.will continue until.OA l
managenent is satisfied' that the audits are being performed _ to produce.
a results and product perspective.
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Enclosure to NIC-87-0243 Page 7 Statement of Violation Fermi 2 Technical Specification, Section 6.5.2.8 requires that audits of unit activities be performed within specified frequencies.
Contrary to the above:
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Audits of unit activities, such as operations, corrective action, i
and fire protection were not performed within specified frequencies.- (341/87028-09A)..
l-This is a Severity Level V violation (87028-02).
l QgrrectlyLActions Taken arrl Results Achieved Prior to the inspection several audits originally sche 3uled for 1988 r
had been rescheduled to bring them in line with'their initial frequency (e.g., Fire Protection moved from January.1988, to.Decenber l
1987 and Corrective Action from February and August '1988 to January.
and July 1988.)
C9rrective Actions To Be Taken to Avold Further Viplations Audit schedules are issued' at the beginning of the year and update 3 quarterly. The yearly schedule provides a two year look ahead.
Beginning with the 1988-1989 schedule, Detroit Elison will not only.
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identify the audit conpletion date and required frequency but'will also irdicate when the previous audit was performed. This will enable the Reviewer and Approvers to assure themselves that' Fermi 2 is -
l meeting the spplicable frequency requirements. We believe this level' of management overview will assure Technical Specification Conpliance.
Date of Full Conoliance Full coupliance will be achieved by January 1,1988.
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