NRC-87-0081, Responds to 870514 Notice of Violation & Proposed Imposition of Civil Penalty from Insp Repts 50-341/87-02,50-341/87-06 & 50-341/87-08.Corrective Actions:Control & Instrumentation Surveillance Procedures Improvement Program Instituted
| ML20215B518 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/12/1987 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| CON-NRC-87-0081, CON-NRC-87-81 NUDOCS 8706170353 | |
| Download: ML20215B518 (23) | |
Text
DCI ]
Detroit-r-a Edison EEE **
c=_
I June 12,1987 NIC-87-0081 l
Director, Office of Enforcement U. S. Ibclear Regulatory Comission Attn: Document Control Desk Washington, D. C.
20555
References:
- 1) Fermi 2 IEC Docket No. 50-341 NIC License Ib. tPF-43 3
2) tbtice of Violation aM Proposed Inposition of Civil Penalty (FEC Inspection Report tbs. 50-341/87002' (DRP); 50-341/87006 (DRP).and 50-341/87008 (DIP)),
dated May 14, 1987.
Subject:
Response to tbtice of Violation and Proposed Inposition of Civil Penalty Detroit B31 son's response to Reference 2 entitled " Reply to a Notice of Violation" is attached. This response Maresses uech of the five areas required by Reference 2.
As notal in the response, Detroit B31 son concurs that the items identified were violations of the applicable Technical Specifications and that certain problems have existed for too long. Therefore, Detroit E31 son is not contesting the basis for the civil penalty. However, based upon the corrective action programs now in place and the timeliness with which more recently identified problens are acted upon, Detroit Mison believes that escalation of the base penalty was excessive, The violations wre, for the most part, identified by Detroit B31 son s
and were pronptly processed pursuant to 10CFR50.73 dnd Detroit s
B31 son's Licensee Event Report (LER) program. Full conpliance has been achieved with respect to the a:tions required to resolve each of the specific violations. The specific corrective actions taken for.
each violation have been thorough and effective as outlinM in the -
attached responses.
^
Generic actions to prevent occurrence of related proolems are also being taken. These generic actions are identified in the responses j[
and include:
8706170353 870612
^
gDR ADOCK 05000341 PDR
,o ru
USMC June 12, 1987
- MC-87-0081 Page 2 An overall procedures inprovement program as discussed with Region III aM other menbers of your staff on March 13,1987, An I&C surveil! n:e W L a'tres inprovement program, A Technical Specif wn surveillance procedure verification effort, A conprehensive review of surveillance procedures to ensure that Situational as well a i Periodic test regairements are adequately separated ard identified, An IMeperdent Safety Engineering Group (ISEG) assessment of eight essential systems to identify test conditions that potentially are at variance with conditions required for the systems to perform their intended functions, ard An irdeperdent assessment of Technical Specification surveillance procedures by a menber of the Irdependent Overview Committee (IOC).
These actions irdit Me that management has been directly involved in the resolution of t ese problems anS that there is a strong concern for any item affecting the quality of operation at Fermi 2.
A recent event, not identified in Reference 2, involving inproper scheduling of an 18-month surveillance of the CO,, Fire Suppression System for the Standby Gas Treatment charcoal fiIters was the result of an ircorrect data entry into the Surveillance Scheduling and Tracking (SST) conputer program. This problem was immediately reclved in a conprehensive manner and will be described in Licensee Evant Report (LER)87-019. The short-term corrective actions to correct this specific item have been coupleted, including satisfactory perfor nance of the missed surveillance. The long-term corrective actions to verify the entire SST conputer program for all Technical Soccification surveillances are underway. The immediate attention given to this event and the conprehensive program to correct any other possible deficiencies in the SST couputer program are further indications that management is taking pronpt ard thorough a: tion to resolve' problems affecting the surveillance program at Formi.2.
Detroit B31 son believes that while a substantial amount of work remains to be done, the overall trend for Fermi 2 as reflected by the LERS analyzed Or the 12 months prior to March,1987, indicates
(
USNBC June 12, 1987 I
NRC-87-0081 Page 3 inprovement. Detroit B31 son respectfully. suggests ~that as set forth
'in its LERs, ISEG surveillance program evaluation,'_and the Fermi Business' Plan, management is providing an aggressive program to address problems as they arise.
Detroit Bilson agrees that these violations of Technical specifications are serious and believes.that the corrective actions identified for each violation will yield the desired results.- We
-intend to continue with a strong management directed. effort toward
. resolving problens as we approach and go beyond Connercial Operation.
The programs identified 'in this response are yielding positive results arsi their continued inplementation -is expected to improve the..
operation of Fermi 2.
A check in the amount of One Ibn$ red Thousand Dollars ($100,000) is enclosed.
If you have any questions,'I will be pleased' to discuss them with you at your convenience..
Very truly yours, h
. Ral h a
Group Vice President Enclosures oca Mr. A. B. Davis Mr. E. G. Greenman Mr. W. G. Rogers Mr. J. J. Stefano I
1 1
.j 1
i
L
. USNFC June 12,1987.
NIC-87-0081 -
Page 4 I, B. RMPH Sn#IA, do hereby affirm that the foregoing statenents are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
kb a
B.- RALF11 SY[ President A
Grmp Vice On this IO N day of OLLM
, 1987, before me personally appeared B. Ralph Sylvie, being first duly sworn and says that he executed the foregoing as his fre<s act'and deed.
ARtL SL Alb Notary Public KAREN M. REED Nottry Public, Monroe County, Mich, 3 Cwmission Expires May 14, 1930 i
f
l Enclosure to I
NRC-87-0081-Page 1 Reply To a Notice'of Violation 1
i STATEMENT OF VIOLATION - A Technical Specification (TS) Limiting Condition of Operation.
(LCO) 3 5.1.c requires that the High Pressure Coolant Injection (HPCI) system be operable when the_ unit is in Operational' Condition 1 or Operational Condition 2 or 3 with reactor steam dome pressure greater than 150 psig. The HPCI system may be inoperable provided that, among other systems, the Reactor Core Isolation Cooling (RCIC) system is operable.-.
TS LCO 3 7.4 requires that the RCIC system be operable when the unit is in Operational Conditions 1, 2-or 3 with reactor steam dome pressure greater than 150 psig. The RCIC system may be inoperable provided that the HPCI system is operable.
l 1
1 TS LCOs 3 5.1.c and 3 7.4 specify an operable flow path to be capable of taking suction from the suppression chamber and transferring the water to the reactor vessel.
When an LCO or its associated action statement cannot be met, TS 3 0 3 requires that action be initisted within one hour to place the unit in an Operational Condition in which the LCO does not~
apply.
Contrary to the above:
i 1.
On October 9, 1986, between the hours of 8:40 and 10:40 a.m.
j and between the hours of 12:55 and 2:55 p.m., while the unit
-)
was in Operational Condition 1 with reactor steam dome f
pressure greater than 150 psig, both the RCIC and HPCI systems were made inoperable during performance of Surveillance Procedure 44.030.154 by closing and
]
de-energizing those systems' suppression chanber suction q
valves. Action was not initiated within one hour to place i
the unit into an Operational Condition in which TS LCOs
]
3 5.1.c and 3 7.4 did not apply.
(LER 86-037-00).
j 2.
On December 24, 1986, between the hours of 12:50 and 5:00 j
p.m., while the unit was in Operational Condition 2 with
)
reactor steam dome pressure greater than 150 psig and the l
1 1
Enclocurs to NRC-87-0081 Page'2-HPCI system inoperable, the'RCIC' system was made inoperable-by valving out the RCIC flow transmitter during performance of Surveillance Procedure 44.110.04. Action was not-initiated within one hour to place the unit into an Operational Condition in which TS LCOs 3 5.1.c and 3 7.4 did not apply.
(LER 86-048-01).
3 On December' 26, 1986, between the hours'of 1:30 and.'3:50' p.m.,~while the unit was in Operational Condition 2.with reactor steam dome pressure greater than 150 psig and the HPCI system inoperable, the RCIC system was rendered inoperable'arter calibration and troubleshooting activities when the system flow controller was set at 505 gpm instead of the required 605 'gpm flow rate. Action'was not initiated within one hour to place the unit into an Operational Condition in which TS LCOs,3 5.1.c and 3 7.4 did not apply.-
(LER 86-048-01).
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Detroit Edison concurs that the three items.specified above are violations of Technical Specifications.
CAUSE OF THE VIOLATION A.1 This violation of Technical Specifications resulted from a failure by I&C and Operations personnel to recognize that prerequisites for surveillance procedur? 44.030.154 "ECCS-HPCI. Condensate Storage Tank Level Calibration" placed the plant'in the condition specified. This failure can be attributed to lack of understanding of plant conditions and lack of an impact statement in the procedure.
A.2 This violation of Technical Specifications'was the result of -
personnel error. The Nuclear Assistant Shift Supervisor (NASS) did not recognize that the calibration procedure for the RCIC flow channel would cause RCIC to become inoperable. As a result, action was not initiated within one hour to place the unit into an Operational Condition'in-
]
which Technical Specification LCOs 3 5.1.c and 3 7.4 did not apply.
Inadequate communications between Operations
Enclocura to NRC-87-0081 Page 3 personnel and the I&C personnel performing this calibration contributed to the problem.
A.3 This violation was the result of personnel error and inadequate verification that'the flow controller had been restored properly.
1 CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED i
A.1 The NASS involved in'this event has been counseled.
Procedure 44.030.154 "ECCS-HPCI Condensate Storage Tank Level Calibration" has been revised to clearly state that it is preferable to perform this procedure during Operational Conditions 4 and 5, and that concurrence to perform it in Operational Conditions 1, 2 or 3 must be obtained from I&C supervision or the Operations Engineer. ' Additionally, methods for performing this surveillance during Operational Conditions 1, 2 or 3 have also been incorporated into the procedure including a specific valve lineup to ensure a J
supply of water from the suppression pool to the HPCI and RCIC pump suctions.
A.2 The Operations and Maintenance personnel involved in this event have been counseled. Licensed operators have received additional training with regard to Technical Specification 3 0 3 requirements and training has been conducted on the
{
RCIC pump flow control circuit effects on system operability.
)
A.3 The Operations personnel involved in this event have been counseled. Required reading associated with performing independent verification has been provided for licensed j
operators.
)
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Detroit Edison realized in early 1986 that the surveillance procedures needed improvement. An I&C surveillance procedures improvement program was developed and discussed with NRC at the second enforcement conference in early 1987 The following activities related to improvement of the I&C surveillance procedures are in progress:
q Enclosure to-
'NRC-87-0081-l Page 4.
1.-
Plant impact statements are being added to ensure that all' responsible personnel are made aware of the plant impact of -
performing the particular surveillance.and to specify the plant Operational Conditions under which the test may be l
performed.
j 2.
Loop sketches are being added to facilitate review and understanding of these procedures by' responsible
' individuals.
3 The procedures are undergoing a human factors review to improve their usability.
J
)
4.
Instrument loops.are.being validated to ensure that all
'I calibration methods and' accuracies are correct.
5.
Procedures are being reviewed t'o ensure that they adequately 1
overlap each other with respect to testing all necessary i
components and functions.
6.
Procedures are being given a high quality review upon W
completion to ensure that all elements of:the improvement.
program have been adequately captured.
7 Independent verification guidelines are being evaluated to determine whether or not revision is required-to ensure that.
equipment is returned to service properly upon completion of
')
'd surveillance testing.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED A.1, A.2, and A.3 Full compliance has been achieved with respect to the specific procedural changes, counseling and training identified under'
" Corrective Steps That Fave Been Taken and Results Achieved,"
above.
i
Encloture to
~NRC-87-0081' Page 5 i
DATE WHEN FULL COMPLIANCE WILL BE-AdHEIVED (CONT.)
l All~seven items comprbing-the'I&C surveillance procedures' improvement prograt described above will be completed by December 31,'1987 Although not all of the items comprising the program
- 4 identified'above specifically apply.to violations A.1, A.2 and-A.3, the entire program has been presented here to place the-program in perspective.
q 3J
-l 4
2 1
1
Enclo;urs to NRC-87-0081 Page 6 i
l
/
STATEMENT OF VIOLATION - B l
TS LCo 3 10.2.b allows, when the unit is in Operational Condition l
1 or 2, the bypassing of the sequence constraints imposed on J
control rod groups by the Rod Sequence Control System (RSCS) i required by TS LCO 3 1.4.2 when performing control rod scram testing provided the Rod Worth Minimizer (RWM) is operable. TS Surveillance Requirement 4.10.2 requires that the following verification be perforned when operation occurs under TS LCO 3 10.2.b:
Within eight hours prior to bypassing any sequence constraint and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while a sequence j
constraint is bypassed, verify the operability of the RWM and verify the movement of control rods between 50% rod density and the RSCS preset power level is blocked or limited to the single notch mode.
Contrary to the above, during the period between 10:00 p.m. on November 3, 1986, and 10:15 p.m. on November 5, 1986, while the t
unit was in Operational Condition 2 and the sequence constraints imposed on control rod groups by the RSCS were bypassed during control rod scram testing, the verifications specified in-TS i
Surveillance Requirement 4.10.2 were not performed at the required frequencies. The RWM was only verified operable on November 4, 1986, at 4:35 a.m. and 5:15 p.m. and on November 5, 1986, at 7:30 p.m.
The movement of control rods between 50% rod density and the RSCS preset power level was only verified to be blocked or limited to the single notch mode on November 4, 1986, l'
at 6:30 p.m. and November 5, 1986, at 7:09 p.m.
(LER 86-043-01).
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION _
Detroit Edison concurs that this event was a violation of Technical Specifications.
j l
l
'l i
i l
1 i
Enclo ure to NRC-87-0081 i
Page 7 l
l CAUSE OF THE VIOLATION This event resulted from personnel error involving a misinterpretation or Technical Specifications. Contributing factors were ambiguity in the wording of the Technical Specification surveillance requirement and an inadequate surve'.llance testing procedure.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED Urgent required reading has been provided to all licensed i
operators regarding their responsibilities for ensuring Technical Specification compliance.
A~ Technical Specification Interpretation has been written to clarify the surveillance requirements associated with bypassing sequence constraints.
Procedure 54.000.03, " Control Rod Scram Insert Time Test," has been revised to include sign-off locations for indicating surveillance testing completion. Finally, procedures 24.608 " Rod Worth Minimizer Functional Test" and 24.609, " Rod Sequence Control System Functional Test" have been revised to include additional guidance regarding performance of the surveillances.
I CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS 1
The corrective actions identified above have resolved this specific problem.
f DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved with respect to this specific violation, i
i 1
l l
l 1
l l
4 i
l a
~
Enclosur@ to NRC-87-0081 Page 8 STATEMENT OF VIOLATION - C i
0 TS LCO 3 6.1 3.b requires that each primary containment air lock' shall be operable with an overall leakage less than or equal-to 0.05 La at 56.5 psig when the unit ~is in Operational Condition 1, 2, or.3 TS Surveillance Requirement 4.6.1 3.c.1 requires that 1
an. air lock leakage test at 56.5 psig be conducted prior to fuel loading and.every six months to verify that the'overall air lock
. leakage rate is within its limit.
TS 4.0.4 requires that entry into an Operational Condition shall l
not be made unless the applicable LCO surveillance requirements-J have been satisfied within the' required surveillance interval.
1 Contrary to the above, the unit entered Operational Conditions 1, a
2 and 3 at various times between 4:35.a.m. on January 24, 1987, and 9:30 a.m. on February 2, 1987, in violation of TS 4.0.4, in that TS Surveillance Requirement 4.6.1 3.c.1 was not satisfied within the required interval. The testing interval expired on 3
January 12, 1987 Testing conducted on February 2, 1987 disclosed that the overall air lock leakage exceeded the allowed leakage rate of 0.05 La at 56.5.psig.
(LER 87-003).
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Detroit Edison concurs that this event is a violation of-Technical Specifications.
CAUSE OF THE VIOLATION l
This event involved a personnel error associated with the incorrect logging of an earlier air lock leak rate test as having been completed when, if fact, only a portion of the entire test had been completed. This error resulted from inadequacies in.
procedure 12.000.018 " Surveillance Program".-for documenting partial test completion. Specifically, the same attachment was used to record both the Situational surveillance test results (Airlock door seal leakage tests) and the Periodic' surveillance test results (Airlock pressurization test).
Enclosure to l
NRC-87-0081 Page 9_
i h
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED I
Upon discovery of the missed surveillance, the air lock e
?
pressurization test was performed and failed. The outer door handwheel shaft seal packing was tightened and the air lock then tested satisfactorily.
No repairs were made to the inner door l
prior to the successful completion of the air lock leak rate j
test. Therefore, it can be concluded that the inner air lock i
door would have adequately sealed the containment against any out-leakage. The air lock surveillance was completed l
successfully on February 2, 1987, less than ten hours after identification of the missed requirement. Procedure 12.000.18,
{
" Surveillance Program" has been revised to provide direction for i
documenting partial surveillance test completion. The generic j
Surveillance Performance Form (SPF) has been revised to include j
provisions for documentation of partial test completion should it be needed for any surveillance, and the surveillance test tracking program has been revised to include separate scheduling events for the door seal and the air lock leak rate tests.
Finally, procedure 43 401.206, " Local Leakage Rate Testing for Air Lock, X-2" has been revised to provide separate attachments for the surveillance test requirements for the doors and the air lock. The individuals identified to perform these tests in the-future are cognizant of these changes.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS i
The corrective actions identified above are expected to prevent any further discrepancies associated with the recording of this surveillance. Since other surveillance procedures were known to satisfy both Periodic surveillance requirements as well as Situational surveillance requirements, such as startup and shutdown requirements, all surveillance procedures were reviewed to determine whether or not any other surveillance tests combine Situational and Periodic requirements on the same procedural attachment.
Eighteen (18) of approximately twenty-five hundred (2500) procedures were identified which do employ the same attachment; however, these tests are such that the Situational requirements are identical to the Periodic requirements and thus, performance of the test satisfies either requirement. Therefore, Detroit Edison has concluded that problems similar to that identified in this violation do not exist elsewhere in the surveillance procedures.
Enclosure to
-NRC-87-0081-
.Page 10 DATE WHEN FULL COMPLIANCE WILL BE~ ACHIEVED Full compliance has been achieved with respect to this specific violation.
i h
'l l
4
Enclosura to NRC-87-0081 1
Page 11
)
STATEMENT OF VIOLATION - D 1
TS LCO 3.6.6.1 requires that two independent drywell and suppression chamber. hydrogen recombiner systems shall be operable when the Unit is in Operational Conditions 1 or 2.
TS Surveillance Requirement 4.6.6.1.a specifies testing to demonstrate hydrogen recombiner system operability be performed every six months to verify that the recombiner system heater outlet gas temperature increases to greater than 1150 F within 75 minutes and is maintained at that temperature for one hour.
i TS 4.0.4 requires that entry into an Operational Condition shall not be made unless the applicable LCO surveillance requirements i
have been satisfied within the required surveillance interval.
Contrary to the above, the unit entered Operational Condition 2 on eleven occasions between August 29, 1985, and December 19, 1986, in violation of TS 4.0.4 in that the test procedure to implement TS Surveillance Requirement 4.6.6.1.a did not verify that the recombiner system heater outlet gas temperature increased to greater than 1150 F within 75 minutes and was maintained at that temperature for one hour under emergency conditions with the Residual Heat Removal system operating.
Testing conducted on January 8 and 9, 1987 disclosed that the Division II hydrogen recombiner system was inoperable and could only reach 761 F within 75 minutes due to an original equipment j
deficiency not disclosed during preoperational testing.
(LER 86-047-01).
i ADMISSION OR DENIAL OF THE ALLEGED VIOLATION l
Detroit Edison concurs that this event is a violation of Technical Specifications.
I i
y c,
i
- EnclosureJto:
NRC-87-0081 Page112; CAUSE OF-THE VIOLATION-A decision-was made_during'the'preoperational test ~ program and.
was' carried over to the surveillance test program to use the'
'i Residual" Heat. Removal (RHR)' keep-fill ~ system (60_psig) rather-
-than the'RHR system (250 psig) to_ test-the design and operation of;the Hydrogen Recombiner System.:; This ultimately led;to thei inability to detect;a' design. error associated with improperly sized orifices and prevented the problem ~from.being' discovered earlier. :The problem was not. identified until December.-26, 1986L when the RHR System was'used to provide cooling water flow during-g the surveillance' test.
J CORRECTIVE STEPS-THAT HAVE BEEN:TAKEN-AND=RESULTS ACHIEVED:
Properly sized orifices have beenlinstalled'and the' system has'
'J been tested satisfactorily with the RHR pumps operating. The surveillance test procedure has-been revised to require that, recombiner functional testing-be performed with the RHR pumps op3 rating.
i CORRECTIVE STEPS THAT WILL BE TAKEN'TO AVOID FURTHER VIOLATIONS The corrective actions identified above have resolved this particular problem. To determine whether_or not:this type of:
problem exists within otherl systems, the! Independent Safety.
j Engineering Group (ISEG)-is assessing.eight essential systems-to.
identify test conditions'.that;potentially are'at; variance with conditions required for the: systems'to perform.their. intended
~
functions. The assessment includes a~ review of selected parts of.
Test Analysis Reports (Preope ational' test), functional surveillance test' procedures and otherLappropriate documents.1 The systems selected for assessment are Core Spray (CS), Residual:
Heat Removal (RHR)', Emergency: Equipment Cooling Water'(EECW),
Automatic Depressurization (ADS), Emergency Diesel Generator.
(EDG), Standby Liquid Control (SLC), Control' Air (CA), and High H
Pressure Core Injection (HPCI).
Enclosure'to 1
NRC-87-0081 Page 13-
' I DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED-Full compliance has been achieved with. respect to this specific j
event.-
The ISEG assessment report will be' issued by. July 1, 1987 Management may identify additional action based upon review of this report.
c 8
l
Enclorurs to l
Page 14 i
STATEMENT OF VIOLATION - E TS LCO 3 3 2 and the associated Table.3 3 2-1, Section 2.c, require that the Reactor Water Cleanup System (RWCU) isolation actuation instrumentation for the heat exchanger / pump area ventilation differential temperature high function be operable when the unit is in Operational Condition 1, 2 or 3
- Further, with the one channel inoperable, the licensee is required to close the affected system isolation valves within one hour and j
declare the affected system inoperable.
TS 3 0.4 requires that entry.into an Operational Condition shall not be made unless the applicable LCOs are met without reliance j
on the provisions of the action requirements.
Contrary to the above, on December 18, 1986 the unit entered Operational Conditions 2 and 3 in violation of TS 3 0.4 and remained in Operational Condition 2 until December 20, 1986 in violation of LCO 3 3 2 with the RWCU isolation actuation instrumentation for the heat exchanger / pump area ventilation differential temperature high function inoperable without satisfying the applicable action requirements. The trip function was made inoperable on December 3, 1986 when the leads for the thermocouples in one of the differential temperature trip systems had been reversed and improperly landed following a surveillance test. (LER 86-046-01).
)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION i
Detroit Edison concurs that this event is a violation of Technical Specifications.
CAUSE OF THE VIOLATION This event was the result of personnel error in the landing of thermocouple leads. Contributing factors included inadequate procedures for functionally demonstrating channel operability following maintenance activity, and unclear thermocouple lead-labeling, j
EnclosurG to NRC-87-0081 Page 15
, CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED
~ *
.The affected leads' were properly installed and the channel tested satisfactorily.
Personnel: involved with this event have been a
counseled. Procedures for calibration (44.020.158/.159) and for I
functional testing (44.020.156/.157) of the channels were revised f
to include provisions for documentat!an of dT indications for.the-RWCU heat exchanger room and post-tes' independent verification of dT switch wiring terminations.
-(1.e., those within cabinet H11-P614/ have been clearly labeled-and are now landed on a switched terminal strip which will allow 1
performance of tests within this cabinet without the lifting of i
j CORRECTIVE TEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS s
The corrective actions identified above have resolved th'is-particular problem. The inclusion of.the switched-terminal strip
)
and the clear. labeling of all leads in cabinet-H11-P614 should prevent any future occurrences of this type of event.
4 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 1
Full compliance has been achieved with respect to this specific j
violation.
i 1
i 4
l
a r
J
.i 4
Enclosure toi 4
NRC-87-0081 Page-16 d
STATEMENT OF VIOLATION'-'F I
TS Surveillance Re'quirement'4.4.3 1.b requires.that-the drywell.
floor drain and the drywell. equipment drain sump pump-run-time-systems receive a channel functional test at least~once per 31:
~
. days and a channel calibration: test at'least onceper 18 months when the unit-is'in Operational:ConditionsL1,.2 or 3 TS 4.0.4
. requires.that entry into an Operational. Condition shall not be made.unless the2 applicable: LCO surveillance requirements have been satisfied within the required-time ~ interval.
j Contrary to the above,.the unit entered Operational Conditions 2-
']
and 3 in: violation of TS 4.0.4-several times between August.1985' and October 1986 without. satisfying TS' Surveillance Requirement-4.4 3 1.b.
The procedure to' implement this requirement'did not
' include channel functional and calibration, testing for the drywell' floor drain and equipment drain sump pump-run-time systems.
(LER 86-008-00).
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Detroit Edison concurs that.this'-is a violation of Technical Specifications.
CAUSE OF THE' VIOLATION
]
Technical Specification surveillance requirement.4.4 3 1.b l
specifies a 31-day channeltfunctional test and an 18-month 1
channel calibration test of.the primary containment ~ sump pump flow and drywell floor drain sump level. monitoring systems'to demonstrate operability of the primary containment sump flow monitoring system. Personnel involved with writing and reviewing the surveillance procedures that-implement the Technical-Specification surveillance requirements interpreted the' requirements for demonstrating operability of.the containment sump flow monitoring system-from these~ Technical Specification surveillance requirements. 'Since the Technical Specification surveillance requirements do not. address all aspects of system' operability, certain necessary'surveillances were not identified and thus, were not written, such as the pump-run-time' surveillances.
t 1
1
.Enclosura to URC-87-0081 Page.17.
'1 CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED The drywell sump pump-run-timers were tested immediately following discovery of this event. Surveillance procedures 44.120.50, "Drywell' Floor Drain. Sump Level Calibration",
44.120.51, "Drywell Floor Drain Sump Level Functional Test",.
44.120.52 "Drywelll Equipment Drain Sump Level Calibration", and 44.120.53 "Drywell Equipment Drain Sump Level Functional Test" have been written and/or revised to include all appropriate
' instrumentation. All four procedures have been successfully performed since occurrence of this event.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION The corrective actions described above have adequately resolved this particular issue.
A Technical Specification line item verification effort is in progress to ensure that all' Technical Specification required surveillances are contained within the Computer Scheduling Program and that the frequencies and operational modes are identified correctly.
i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED I
Full compliance has been achieved with respect to this specific
]
violation.
The Technical Specification surveillance procedure improvement effort associated with the generic aspects of this violation, described above, will be completed by December 31, 1987 j
3
~
Encloture to NRC-87-0081 Page 18
.i STATEMENT OF VIOLATION - G TS Surveillance Requirement 4.3 7.12 and the associated Table 4.3 7 12-1, Section 2.b, require a daily channel check for the' noble gas activity monitor in the offgas system at the 2.2 minute delay piping during main condenser air ejector operation.
l Contrary to the above, from the beginning.of facility' operation to September 16, 1986, the' required daily channel check for'the noble gas activity monitor-in=the offgas system at the 2.2 minute delay piping during main condenser air ejector operation had not-been performed.
(LER 86-039-00).
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Detroit Edison concurs that this event is a violation of Technical Specifications.
CAUSE OF THE VIOLATION This event was the result of personnel error.in preparing and reviewing a surveillance procedure to fulfill Technical Specification surveillance requirements. The instrument identified in the surveillance procedure and, thus, the instrument being tested, was not'the correct' instrument.
j CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED A successful channel check was performed on the correct instrument immediately' upon identifica',lon of the problem.
Procedure 24.000.02", Shiftly,' Daily, Weekly and Situation Required Surveillances" has been revised to specify the correct
~
instrument number.
t
..-i Enclosura;to
- NRC-87-0081.
I Page 19 i
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONSL
-The corrective actions identified above have. resolved this
.s..
particular concern.
The more generic, ongoing effort of ensuring that all. procedures.
are accurate is being satisfied by the latest revision to NOIP j
~11.000.131 " Procedures, Manuals and Orders."-: This procedure requires:the individual' assigned to; write _or revise:a procedure
.to.be a subject matter expert in the area to be addressed and tol
. ensure that the procedure contains all.of the steps necessary to 3
~
1 accomplish the specific activity being addressed. Additionally,
- this procedure requires an independent technical review by.
another subject matter expert.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has.been achieved with respect to this specific; violation.
-j The implementation of the revised NOIP 11.000.131-is' ongoing.
J u
I s
1 i
L L -_