IR 05000341/1985035

Insp Rept 50-341/85-35 on 850617-21.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Licensee as-built Program & Independent Insp

ML20129H459
Person / Time
Site:	Fermi
Issue date:	07/12/1985
From:	Falerits Z, Mendez R, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20129H455	List: IR 05000341/1985035 ML20129H451
References
50-341-85-35, NUDOCS 8507190116
Download: ML20129H459 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/85035(DRS)

Docket No. 50-341 License No. NPF-33 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48224 Facility Name: Enrico Fermi Nuclear Power Plant, Unit 2 Inspection At: Enrico Fermi 2 Site, Monroe, MI Inspection Conducted: June 17-21, 1985 I. $ 2 Inspectors: Z. Falevits 7//2/Ff Date '

R. V.andez-

'W -I!!Ll d'"

Date F

Approved By: C. C. Williams, Chief ~lbt[t[

Plant Systems Section Date Inspection Suninary Inspection on June 17-2L 1985_ _(R_eport N DRSJ)

341/85035_(Ticenseeactionon Areas Inspected: Routine, unannounced inspection of previous inspection findings, review of licensee as-built program ("B" software items), and independent inspection. The inspection involved a total of 89 inspector-hours onsite by two NRC inspectors including 27 inspector-hours onsite during off shift Results: Of the areas' inspected, no violations or deviations were identifie ~'

8507190116 850712 PDR 0 ADOCK 05000341 PDR

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DETAILS Persons Contacted W. H. Jens, Vice President, Nuclear Operations F. Agosti, Manager, Nuclear Operations R. S. Lenart, Superintendent Nuclear Operations W. F. Colbert, Director Nuclear Engineering G. M. Trahey, Director N. K. Earle, Supervisor Licensing B. E. Wickman, Supervisor M&M. L. Bregni, Engineer Licensing S. P. Zoma, Principa! Resident Engineer C. J. Morrison, I&C E ngineer G. W. Richards, I&C Engineer

! L. B. Collins, System Engineer L. F. Wooden, System Engineer Those identified above attended the exit meeting on June 21, 1985. In addition to the,above persons other licensee and contractor personnel were contacted during this inspectio . Licensee Ac_ tion o On Previous _ Inspection. Items

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- (Closed) Unresolved Item (341/85028-01(DRS)); During a recent inspection the inspector noted that 1E cables utilized in the control circuits for the primary containment isolation valves E11-F079A&B and E11-F080A&B, located in.the RHR sample lines, were downgraded to non-1E. Ger eral Electric Master Parts List (MPL)

classified these valves as "A" (Active) whose active performance is important to safety. Subsequently, the licensee in letter NE-85-0901 dated June 24, 1985, noted operational considerations, as well as the design basis characteristics of the valves control circuits as the basis for downgrading the control cables to non-1E status. The system is designed to denergize-to-operate. The two normally closed primary containment isolation valves are connected in series for each sample line, and are fail-safe to close on loss of air or electrical power, (ASME class II). The control cables are routed in separate division cable tray systems, minimizing the possibility of single failure causing inadvertent opening of a sample line. Based on the above, this item is resolve (Closed) Unresolved Item (341/85028-02(DRS)); This item addressed an electrical separation requirement violation in the internal wiring to the redundant divisional trip coils of the Anticipated Transient Without Scram (ATWS) mitigation system of the Recirculation Pump Trip (RPT) circuitry. One of the internal wiring divisions was required to be installed in flexible conduit all the way to the ;

final element; e.g., the field breaker triping coil, since it is

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the final device whose failure can compromise the trip functio In subsequent discussions between Region III, NRR, and members of the licensee's staff, the licensee has conmitted to install the required flexible conduit and will submit a scheduled date for installation in October 1985. The NRC plans to conduct inspections on this issue in the future when the corrective action is complete, (0 pen) Unresolved Item (341/85009-01(DRS)); This item relates to the various cases identified where Balance Of Plant (B0P) cables are electrically interfaced with divisional cables in safety and non-safety related circuits. The licensee has subsequently performed a comprehensive review and analysis (Reference DEC0 letter VP-85-0132, dated June 10,'1985) of approximately 550 schematic diagrams where 1E and non-1E circuits interface without the intrinsic. separation provided by isolation devices. As a result of this review, a total of 656 cases where IE and non-1E circuits interfacing electrically were identified. These cases were categori.:ed into 13 representative samples. The analysis addressed the impact of electrical faults in the non IE circuits on the function of the 1E circuits for each of the 13 samples. This analysis was transmitted by the licensee to NRR for revie Subsequently on June 20, 1985, during a telecommunicatoin between Region III, NRR and the licensee's staff, it was concluded that the licensee will be required to take appropriate corrective action to resolve NRR concents regarding representative samples numbers 2, 3, 6, 7, 8, 11, 12 and 13. Representative samples numbers 1, 4, 5, 9 and 10 were found to be acceptable as analyzed by the licensee (Reference DEC0 letter NE-85-0900). Licensee corrective action will be reviewed in future inspections, this item remains ope . Review of Licensee As-Built Program During this inspection the inspectors expanded the review of the

"B" software items which are defined as items which require revisions to the design drawings to make them conform to the actual field hardware configuration. The following as-built walkdown packages were reviewed:

(1) Diesel Generator No.-11 panels R30-P311 and R30-S00 (2) RHR Mechanical Draft Cooling Tower Fan "B" E11560001 (3) Reactor Protection panels H11-P609 and H11-P61 (4) 480V switchgear 72ED (RHR complex R145039).

(5)' Process Radiation Panel D11-P29 (6) _ Reactor Core Isolation Cooling Panel E51-C00 (7) Diesel Generator Panel R30-P32 .

(8) Standby Gas Treatment Panels T46-P401A and H21-P295 (9) Process Radiation Panel D11-P29 (10) Primary Containment Monitoring System Panel H11-P91 The review consisted of examining the following related documents:

Deviation Event Reports .(DER), As Built Notices (ABN), Engineering Design Packages (EDP), CR7 termination cards, walkdown prints, and test report In addition, the inspectors conducted field inspections of selected installed components and panels to ascertain the effectiveness of the as-built program in identifying and correcting nonconforming condition The inspectors reviewed the following "B" software items including their associated corrective action documents:

Device N DER N Item No. Corrective Action Document R30-P311 85-190A 6 ABN-2410-1 R30-P311 85-190A 7 ABN-2410-1 R30-P311 85-190A 8 ABN-2410-1 R30-P311 85-190A 9 ABN-2410-1 R30-P311 85-190A 12 ABN-2410-1 R30-P311 85-190A 13 ABN-2410-1 R30-S008 85-190A 5 ABN-2742-1 R30-5008 85-190A 13 ABN-2739-1 R30-S008 85-190A 18 ABN-2739-1 R30-5008 85-190A 30 ABN-2741-1 R30-S008 85-190A 31 ABN-2741-1 R30-5008 85-190A 36 ABN-2741-1 E1156C0010 85-402 1 ABN-2395-1 H11-P609 85-130 17 ABN-2551-1 H11-P609 85-130 20 ABN-2551-1 H11-P611 85-119 3 ABN-2747-1 H11-P611 85-119 3C ABN-2747-1 R14-S039 85-0328 1 ABE-1446A R14-5039 85-032B 8 ABE-1446A R14-5039 85-032B 10 ABE-1446A D11-P297 85-349 2 ABN-2453-1 D11-P297 85-349 3 ABN-2453-1 D11-P297 85-349 7 ABN-2453-1 D11-P290 85-336 1 ABN-2470-1 D11-P290 85-336 1 ABN-2453-1 D11-P290 85-336 2 ABN-2453-1 D11-P290 85-336 3 ABN-2453-1 D11-P290 85-336 7 ABN-2453-1 E51-C002 85-322 1 ABN-2610-1 E51-C002 85-322 3 ABN-2610-1 E51-C002 85-322 SA ABN-2510-1

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Device N DER No_ Item N _C or_ rec c _tiye_Ac_ tion, Document -

E51-C002 85-322 5B ABN-2510-1 H11-P014 85-378A 1 ABh-ELLL-1 H11-P014 85-378A 12 ABN-2528-1 H11-P014 85-378A 18 ABN-2528-1 H11-P014 85-378A 25 ABN-2528-1 H11-P014 85-378A 30 ABN-2528-1 H11-P014 85-378A 31 ABN-2528-1 H11-P014 85-378A 33 ABN-2528-1 H21-P295A 85-249 7A ABN-2757-1 H21-P295A 85-249 78 ABN-2757-1 H21-P295A 85-249 7C ABN-2757-1 H21-P295A 85-249 1 ABN-2756-1 H21-P295A 85-249 1 ABN-2756-1 H21-P295A 85-249 1 ABN-2756-1 H21-P295A 85-249 1 ABN-2756-1 H21-P295A 85-249 1 ABN-2756-1 T46-P401A 85-163 2 ABN-2618-1 T46-P401A 85-163 3 ABN-2618-1 R30-?321 85-181A 5 ABN-2414-1 R30-P321 85-181A 7 ABN-2414-1 R30-P321 85-181A 8 ABN-2414-1 R30-P321 85-181A 10 ABN-2414-1 R30-P321 85-181A 12 ABN-2414-1 R30-P321 85-181A 15 ABN-2414-1 R30-P321 85-181A 16 ABN-2414-1 R30-P321 85-181A 18 ABN-2414-1 R30-P321 85-181A 19 ABN-2414-1 R30-P321 85-181A 20 ABN-2414-1 The inspectors also examined various design drawings for ABN posting requirements and their incorporation in the drawing No violations or deviations were identifiec in the "B" software  ;

items progra During the field inspection of installed components the following

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deficiencies were noted by the inspector: i (1) Diesel Generator panel R30-P311 (a) Licensee walkdown print 61721N-2712-40 had not been completely yellow lined which indicated that not all devices on panel requiring -inspection have been inspected by the license (b) Licensee walkdown print 61721N-2712-40 identified two ,

incorrect wire designations on termination points B29-3 and l B29-4. This was erroneously omitted from DER-85-19 j

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(c) Two loose strands of wire, in very close proximity to the adjacent termination points, were identified on TB-B28-03 '.

l and TB-B16-7.

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(d) The cable designated as 228807-1C on drawing  ;

61721N-2712-40 was observed in field as 228807X-1C.

l The inspector informed the licensee that an additional, more comprehensive walkdown will be required on panel R30-P311 since it has not been completed during the walkdow (2) Reactor Protection panels H11-P609 and H11-P611. Note: Scram contactors K14A thru H, and KISA thru D were not in the licensee's as built scope of inspection due to the fact that they are enclosed inside metal covered boxes within panel ,

The inspector examined above contactors and noted the following concerns:

(a) Compression type terminals T1, T2 and T3 contained three conductors on each compression lu (b) Even though all 14 scram contractors are identical in their construction, connecticns to termination points T1,.

T2 and T3 were observad to be nonunifor (c) Contactor K150 point T3 did not contain the plate placed against the terminated lugs as require (d) Point 10 of contactor K14F contained two conductors while design drawing indicated one conductor. Point 10 of contactor K14H contained one conductor while design drawing indicated two conductors. Further review

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disclosed that C&IO test No. CCTH11P609-004 which was performed in September 1982, implemented FMR-2538 revision A. During this test the engineer modified the configuration of the installed wiring causing the design drawings to be in conflict with the installed wirin This modification was documented on the test report, a design change however, was not initiated to revise the design drawings. C&IO test form TR.000063.01 revision 1, dated October 1981, requires that: " Wiring, connection and schematic diagrams agree." Signature of test engineer indicated this was accomplished, although, as installed field connections were found to be in conflict with the applicable design drawin ,

(e) Three control switches on RPS panel H11-P609 were observed in the field to contain more stages than the design drawing indicate Items b.(1) and b.(2) are considered open pending further review and evaluation of licensee corrective action and NRC revie (341/85035-01(DRS)).

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. The inspectors also discussed other "as-built" issues with the licensee who indicated that they would followup or resolve the following issues:

(1) Field conductors terminated at a pressure type connection-(Weidmuller type block) were observed to be either not fully inserted or the insulation of the conductors were stripped too far back. Four field conductors were observed with Lare conductors extending a 1/4-1/2 inch beyond the Weidmuller termination block inside a junction box associated with system No. T46-P401A (Standby Gas Treatment System). Licensee specifications and instructions require that the insulation be stripped back so that approximately a 1/16 of an inch is beyond the terminal block. The licensee is continuing to review this issu (2) A connection point inside a control panel associated with system H21-P295N was observed to be connected with three termination lugs. The PN21 disposition for this item required that the termination point be reworked to comply with the licensee's specification, 2 lugs per termination. The licensee agreed to investigate this matter furthe (3) Discrepancies were noted in the designation of normally open/ closed air operated limit switch contacts between schematics and their associated wiring diagrams. Several instances were noted where a schematic diagram would show a contact in the normally closed position while the contact development in the wiring diagram show this contact in the normally open position or vice-versa. The inspector discussed this issue and the licensee stated that in the future, the air operated valve limit switch contacts should be shown on the schemes based on the valve closed status. The licensee stated it would take about a year to consolidate the question of the limit switch representation on their drawing The inspection disclosed that these actions are part of the licensee's ongoing "As-Built" consolidation program and actions taken and those planned to be taken were found acceptable to the NR . Review of Licensee Conmitment_ _to_ Verifylaggintof q Instrument Li_nes During a previous inspection followup on Unresolved Item 84068-01, sensing lines appeared to violate the separation requirements for redundant sensing lines. The licensee determined based on their review, no evidence of a separation or routing problem existed. The licensee did determine that the observed deficiencies involved incorrect tagging of the instrument lines rather than a divisional or routing proble Surveillances were performed to ascertain the extent of the proble Twenty-six sensing lines were walked down from their originating point in the drywell to the instrument transmitter connections by the site

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QA group. The results of the walkdown identified six instrument sensing lines that had the incorrect divisional designations in addition to incorrect information. On March 15, 1985, the licensee issued memo No. EF2-102, 520 that committed to verify correct tagging of the 118 instrument sensing lines in the drywel Documented information was available regarding the results of the walkdown initiated by the licensee's letter of March 15, 198 The identification (tagging) on instrument sensing lines, that originate in the drywell, were changed as a result of a walkdown initiated by the licensee's letter of March 15, 1985. Documentation regarding the walkdown results was not available during this inspection. On May 10, 1985, the licensee issued Engineering Change Notice ECR-3234-1 which developed appropriate tagging criteria to correct inconsistencies on the instrument tags. During this inspection period, the inspectors accompanied licensee personnel to verify the information on the sensing line. The tagging of ten instrument lines which penetrate the drywell and connect to instruments outside the drywell were checked against the applicable drawing, no problems or deficiencies were identifie No violations or deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Paragraph . Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on June 21, 1985. The inspectors sumarized the scope and findings of the inspection, which were acknowledged by the licensee. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents / processes as proprietar