ML20079R126
| ML20079R126 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/27/1983 |
| From: | Wells D DETROIT EDISON CO. |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20079R119 | List: |
| References | |
| EF2-64300, NUDOCS 8306220024 | |
| Download: ML20079R126 (11) | |
Text
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c Donald A. Wells Manager Ouafy Assur nce a
(3131 237M57 Edison sis'EF52e May 27, 1983 EF2-64300 Mr. R.L. Spessard, Director Division of Engineering U.S. Nuclear Regulatory Cmmission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Noncmpliance at Enrico Fermi Unit 2 - IE Report 50-341/83-04.
Dear Mr. Spessard:
This letter responds to the itms of nonempliance described in your IE Report No. 50-341/83-04. This inspection of Enrico Fermi Unit 2 construc-tion site activities was performed by Mr. F.W. Reimann on February 14 through March 17, 1983.
The itms of noncmplj.me are discussed in this reply as required by Sec-tion 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
The enclosed response is arranged to correspond to the sequence of items cited in the body of your repcrt. The number for the items of nonexpli-ance and the applicable criterion are referenced.
We trust this letter satisfactorily answers the concerns raised in your report. If you have questions, please contact Mr. G.M. Trahey, Assistant Director - Project Quality A.ssurance.
Very truly yours, 9
(S
)
J' DAW /NEM/pn cc: Mr. Richard DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Cmmission Washington, D.C.
20555 Mr. Bruce Little, Senior Resident Inspector U.S. Nuclear Regulatory Ca mission 6450 North Dixie Highway Newport, Michigan 48166 111 8306220024 830615 VuN 0 W 1
PDR ADOCK 05000341 G
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a THE DEIROIT EDISON CXNPANY PROJECT QUALITY ASSURANCE 4
ENRICO FmMI 2 PROJECT 1
Response to NRC Report No. 50-341/83-04 Docket No. 50-341 License No. CPPR-87 Inspection at: Fermi 2 Site, Newport, Michigan Inspection Conducted: February 14 - March 17, 1983 i
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Response to NRC Inspection-Report No. 50-341/83-04 (83-04-01)
Statement'of Noncmpliance, 83-04-01 10CFR50, Appendix B,-Criterion XV,' states in part " Measures shall be estab-lished to control materials, parts, or emponents which do not conform to requirements.in order to prevent thejr inadvertent use or installation.
'1hese measures shall include, as appropriate, procedures for identifica-
' tion, doctanentation, segregation, disposition, and notification to affected organizations". Paragraph 2.5.9 of the Quality Assurance Manual requires 4
that nonconforming items be tagged or labeled.
Contrary.to the aDove, on February 1, 1983, several nonconforming DC power 4
cables renoved frcan the High Pressure Cooling Injection (HPCI) and Reactor L
Core Isolation Coolant.(RCIC). systans were stored in the HPCI and RCIC rooms along with conforming cables and the nonconforming cables were not
--tagged,: labeled, or segregated fran conforming cables.
j i-Corrective Action Taken and Results Achieved h conditions identified in the referenced noncompliance occurred while a contractor was performing work on the R32-01 system under the jurisdiction of the System'Ctznpletion Organization (SCO).
SCO is responsible for the. management of maintenance and modification acti-vities on systems turned over to Detroit Edison frcan construction, which 4
are.in either the Checkout and Initial Operations (CAIO) or Preoperationa1 test phase. The Nuclear Production Maintenance Section also performs
' maintenance activities on CAIO or Preoperational systems per SCO's request.
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JAll power cables are now properly tagged. The work per Nonconformance Report (NCR)82-043 has been cmpleted'for the cable identified on this rarau v11ance. Operational Assurance shall review NCR 82-043, and verify thatanyLothercablepulledperthisNCRisproperlytagged.
f corrective Action to be Taken to Avoid Further Nonccznpliance h cable requiring removal was originally identified as potentially non-conforming on NCR 82-043, issued March 15, 1982. The cable identified on.
the NCR was noted as not requiring Quality Control' (OC) hold or Limited l
' Work Authorization (IMA) tags. This wasLan error. The cable should have
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been tagged, either at the cable or breaker, stating that the wrong sized -
t cable had possibly been installed.
. Detroit Edison ~has since issued P.O.M. 12.000.52T,.which is the procedure t
' currently being used the report and document nonconformances detected dur-ing the CAIO and Preoperational test phase. Detroit Edison will review 12.000.52T to verify that the procedure provides for an adequate review by:
Project-Quality Assurance (PDA) to assure that nonconforming material has been properly identified and controlled prior to evaluation and disposi-
. tion. Any necessary procedure revisions will.be processed.
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, PQA personnel' reviewing part-II of N3s will be innediately instructed to i
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Response to NRC-Inspection Report No. 50-341/83-04 (83-04-01)
Corrective' Action to be Taken to Avoid Further Nonemplianc3 (cont'd) review part I of the NCR to assure i: hat xmconforming material has been satisfactorily identified and controlled.
P m will review open NCRs and verify that nonconforming material, or poss-ible nonconforming material, is properly identified and controlled.
'Ihe Date When Full Carreliance will be Achieved Full ccInpliance will be achieved August 1,1983.
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Response to NRC Lnspection Report No. 50-341/83-04 (83-04-03)
Stat m ent of Noncompliance, 83-04-03 10CFR50, Appendix B, Criterion V, states in part " Activities affecting qual-ity shall be prescribed by bwnted instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accmplished in accordance with these instructions, procedures, and drawings." The licen-see's Tmporary bbdification Procedure 4.7.2.01 contains instructions for controlling tmporary changes to equignent design, including jumpers and lifted leads. Additionally, the Startup Manual requires that electrical jumpers and lifted leads be controlled by appropriate steps in applicable preoperational test procedures, and that the control rom maintain a log or record of the installation and removal of jumpers and lifted leads.
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Contrary to the above, on March 1, 1983, six (6) instrumentation leads relating to Dnergency Diesel Generator 11 were found disconnected for testing purposes without:
(1) being tagged as required by Procedure 4.7.2.01, (2) being controlled by the applicable preoperational test procedure (PRET.R3000.001 which controlled the testing in progress), and (3) the control rom maintaining a log or record of the disconnection of the leads, b.
Contrary to the above, Temporary Modification Procedure 4.7.2.01 con-tained two (2) different instructions for the control of jumpers and lifted leads, allowing the use of two different types of control tags, and the option of not controlling jumpers and lifted leads through con-trol rom logs or records.
Corrective Action Taken and Results Achieved During the preoperational testing of Dnergency Diesel Generator 11, a work authorization form (PN-21) was issued to the Instrumentation and Control (I&C) Shop to perform work on the H50-00 portion of tic Dnergency Diesel Generator Stator Tmperature Indicators (H50-00: Bearing Temperature and Motor Winding T mperature System). The I&C repairmen were performing ini-l tial CAIO calibration on the H50-00 indicators for the Dnergency Diesel l
Generator rmote indication, the procedure being utilized was 46.000.11.
Site procedures allow CAIO calibration's to be performed coincident with preoperations and allows leads to be lifted without Temporary Modification tags under the following conditions; hanging yellow notice tags, or hav-ing personnel nonitor the lifted leads. The Control Rom would not be aware of an active Temporary Modification since one would not exist. Since the H50-00 system was not operational at that time, and it was not a requirement of the diesel preoperation, the R30-00 configuration was not cmprmised by CAIO work. As previously stated, CAIO calibration (procedure 46.000.11) was being performed on the six (6) leads. Since these leads were for Generator Stator Temperature Indication, a Fluke Digital Multimeter was being utilized to read RTD resistance instead of the H50-00 indicators which were not available at the time of the preoperation. Use of the Fluke was documented in Section 5.0 (Test Equipnent) and in Appendix A, "Special Test Equignent",
of PREI'.R3000.001.
Noncmpliance with procedures did occur when the I&C repaimon failed to
Response to NRC Inspection Report No. 50-341/83-04 (83-04-03)
Corrective Action Taken and Results Achieved (cont'dl.
re-terminate the leads at the end of their shift. As corrective action, the IaC Shop was notified and the appropriate tags were attached during the preoperational testing on Energency Diesel Generator 11. The Startup Test Engineer (STE) contacted the I&C Shop Supervisor to clarify and delineate the required procedure for tagging T eporary Modifications and this infor-mation was dissminated to the individual repainnen. The STE performing diesel 11 preoperational testing was fully aware of this situation, and it did not irrpact the performance nor data collection of PREF.R3000.001.
Corrective Action to be Taken to Avoid Further Noncompliance The T eporary Modification procedure currently in use is Startup Instruction 4.7.2.01, Revision 8.
This procedure will be superceded by Plant Admini-strative Procedure 12.000.25T, currently in draft form with an expected approval date of mid, June. Procedure 12.000.25T will clarify the tagging procedure and control of lifted leads and jumpers along with other Temporary Modifications. 'Ihe record keeping function of Temporary Modifications will be the responsibility of the Nuclear Shift Supervisor or designee.
The Date When Full Compliance will be Achieved Full cmpliance will be achieved within 90 days of approval of 12.000.25T (Septaber 16, 1983). This time will be required to transfer existing Tmporary Modifications to the new procedure, provide training, and phase out S.I. 4.7.2.01.
Response'to NRC Inspection Report No. 50-341/83-04 (83-04-04)
Statenent of Noncanpliance, 83-04-04
'10CER50, Appendix B, Criterion XI requires that the test program for systems and ccuponents be-performed in accordance with written test procedures.
This requirenent is~ reflected in the Startup Manual and Chapter 14 of the FSAR.- Preoperational Test Procedure PREF.R3000.001 "Bnergency Diesel Gener-ator Systems", requires;thatiprerequisite valve.and electrical lineups, auxiliary system filling and venting, and systen operation be acccmplished
- in'accordance with Operating Procedure SOP 23.307.
Contirary to the above, prior to testing on March 2,1983, the starting hir
~ and fuel oil systems for Bnergency Diesel Generator-11 were not properly lined up and filled / vented as per required by SOP 23.307. As a result, the engine experienced three repetitive start failures.
Corrective Action Taken and Results Achieved 10CFR50, Appendix B,'. Criterion XVI states in part " Measures shall be estab-lished to assure that conditions adverse to quality, such as failures, mal-functions, deficiencies, deviations, defective material and equipnent, and nonconformances are prmptly identified and corrected". This requirement is reflected in the Quality Assurance Manual, Startup Manual, and in the NOTE pre - ling the test procedure steps of Preoperational Test Procedure PRUI.
R3000.001, Section 6.0, " Procedure", which states "If the diesel generator should fail to start for any reason, a detailed. explanation for the failure and corrective action shall.be given in Bnergency Diesel Generator 11 -
Data Sheet B".
A breakdown of adninistrative controls occurred when the STE failed to make an entry.in Data Sheet B-(Start Failure Iog) for each of the unsuccessful starts on March 2, 1983. This is in violation of site procedures during the performance of PREF.R3000.001. However, during operation of Energency Diesel Generator 11, a hard bound record log book was kept to provide a can-plete history of engine operation.
Startup personnel conducted an evaluation and analysis of the Start Failures as addressed in Docket No. 50-341, Details, d.2, Paragraph 3 and 4.
This evaluation was conducted by the Startup Engineer and his designee (Senior Electrical STE). 'lhese persons were not directly involved with engine oper-ation on the date in question, March 2, 1983. The results of tne indepen-dent staff's investigation resulted in the corrective actions stated below.
Corrective Action to be Taken to Avoid Further Nonccupliance
'All Startup Test Engineers and Startup Test Tecnnicians have been informed by letter, frun W.R. Holland, Vice-President - Fermi 2, dated March 14, 1983, to conply with all requirements of procedures and not to deviate
. without properhv-ntation and authorization. Startup considers this
~1etter as final' corrective action,- and is in full cmpliance with above Criterion.
Response to NRC Inspection Report No. 50-341/83-04 (83-04-04) 3 b
N Date When Full Otanp11ance will be Achieved Full empliance has been achieved.
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r Response to NRC Inspection-Report No.-50-341/83-04 (83-04-07)
Statement of Nonocupliance, 83-04-07 10CFR50, Appendix B, Criterion.XVI states in part " Measures be established
-to assure that conditions adverse to quality, such as failures, malfunc-tions,' deficiencies, deviations, defective material and equignent, and non-
'conformances are praptly identified and corrected".: This requirement is reflected in the Quality Assurance Manual, Startup Manual, and.in the NDPE pra - ding the test procedure steps of Preoperational Test Procedure PRET.
R3000.001, Section 6.0, " Procedure",-which states "If the diesel generator
-should fail to start for any reason, a detailed explanation for the failure and corrective action shall be given in Energency Diesel Generator 11 -
Data Sheet B".
Contrary to the above, on March.2,1983, the anergency Diesel Generator 11 experienced four consecutive start failures and detailed explanations for the failures and corrective actions were not given in anergency Diesel Generator 11 - Data' Sheet B.
. Corrective Action Taken and Results Achieved The uncapped fuel oil piping was clearly an oversight on the part of.the 4
support crew responsible for the t:ask. As stated in Docket 341, Details, Paragraph d.1, when this concern was mentioned to Startup personnel, proper covers were placed over the exposed piping. SuhaaTJently, the Maintenance Department.was contacted to inplanent necessary action (s) ~to ensure such -
oversights are properly addressed. Mr. C. Bergren (Edison Maintenance e
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-Department)- stated that the maintenance personne1' responsible have been
're-instructed in the proper procedures by the: Maintenance Department j,
General Foreman..
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10CFR50, Appendix.B, Criterion XI rec'uhes that the' test progra.L for sys--
tems and emponents be performed in accordance with written test proce-dures. This requirenent is reflected in the Startup Manual and Chaptar 14 4
of the FSAR. Preoperational Test Procedure PREF.R3000.001 "Snergency Die-l sel Generator Systems", requires that prerequisite valve and electrical i.
line ups, auxiliary system filling and venting, and system operation be accanplished in accordance with Operation Procedule SOP 23.307.
~ The change of the Fuel Oil Purrp Direharge Relief / Regulating valve was com-
,pleted in accordance with site procedures. The NRC Inspector was mis-U
.takenly informed that the replacemnt valve was " identical". It was in fact, an equivalent OA-I valve of similar range and size. This change was performed in compliar.ce with FSAR Chapter 17, which discussed Vendor and Suppliers OA programs, and provides assurance that a replacanent cmponent does not degrade a system.
lOn the date specified, March 2, 1983, a valve line up was witnessed by the NRC inspector. '1his line up was performed by the STE and Ooerations' per-sonnel, but they failed to perform Fuel Oil Subsysten venting in accor-dance with'the SOP.
Por the STEs log entries, the first two (2) start atteupt of Bnergency
- s.,1 Response to ISC Inspection Report No. 50-341/83-04 (83-04-07)
_ Corrective Action Taken and Resulta Achieved (cont'd) s Dietal Generator 11 were attributable to not venting the Fuel Oil Systm.
'lhe first. attempt was a failure due to excessive time to reach rated speed.
The. investigation performed by the STE at the time of the failure consisted of discussions with the verdor who agreed that the prob 1m was air pockets in the Fuel Oil Systm. Operation of the engine (i.e.
the first attempt) should have vented the system; frm these discussions, the STE felt no physical adjustznents to the engine were required, and a second start
_ attempt was warranted; this was noted by an entry in the STE's log. On the second attarpt the engine received a " Start Failure" signal which was traced to the " Cranking Time Relay" (7 + 1 sec). After the second failure, the vendor agreed with the Test Engineer that the air bubbles were still present and the STE directed the Standby Fuel Oil Punp.to be operated to vent the Fuel Oil Systs; this also was noted in the log.. On.the third attempt, diesel 11 achieved rated speed and voltage within time, but
' tripped when synchronization was attempted. 'Ihe alarm received was " Field Failure". This condition, similar to a Reverse Power Trip,. occurs due to a Generator. Voltage to Grid Voltage mismatch. With diesel 11 generator vol-tage equal to the grid voltage upon breaker closure, the syste attempted to control the diesel generator and as a result, the DC Field collapsed causing the DC Relay to pickup and trip the unit (this trip is bypa==ad on anergency Operation). 'Ihis differs slightly frm a Reverse Power Trip since the generator voltage was equal to the grid, not less, however, on this third trip the Reverso Power Relay target was verified as not being picked up. The operator was informed of his errors and it was pointed out that the SOP for Dnergency Diesel; Generators covered synchronization proce-dures in detail and that a greater familiarity with the SOP was warranted
.(a separate meeting was held with the Nuclear Shift Supervisor and the Operations Engineer regarding operator familiarity with SOPS). Emergency Diesel Generator 11 was reset and started again; this time the STE deli-berately aborted the run when he was mistakenly informed that the Fuel Oil Relief Valves had lifted and that the system pressure (PI-RA08) was exceeding 45 psig.. Although the vendor stated that the engine could oper-ate without damage at this pressure, the F.O. Punp Discharge Relief /Regu-lating valve was adjusted to reduce the-systen pressure.to the specified range (25-30 psig) in accordance with the anergcncy Diesel Generator Tech-nical Manual.
Corrective Action to be Taken to Avoid Further Noncc1rpliance
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A meeting was. held on March 2,-1983, to discuss the noncampliance and the corrective action taken, as stated above.. Startup also took the initiative to suspend engine operation until SOP 23.307 was reviewed by both Startup and Operations' personnel with enphasis placed on utilizing SOPS during -
- equipnent operation.' Full cmpliance was achieved on March 2,1983.
- 'Ihe Date When Full Compliance will' be Achieved Full empliance has been achieved.
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L Response to NRC Inspection Report No. 50-341/83-04 (83-04-08)
Statment of Nocccm1pliance,~ 83-04-08 (Supplement II,- Detail #4.0) 10CER50, Appendix B, Criterion II states in part' " Activities affecting qual-ity_ shall be aoocuplished under suitable controlled conditions...such as.
adequate cleanliness..."Section I of the Quality Ascurance Manual requires that activities affecting quality be performed under suitable controlled conditions.
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~ Contrary to the above, on March 15, 1983, cable trays containing safety related cables in' a cable. tray rocan adjacent to the auxiliary electrical room (relay room)z were:found to have rags,. ropes,'an electric ~ fan, concrete expansion anchors, food waste, various lengths of conduit.and small bore' pipe,. tools, wood debris, and other. construction debris in then. This itera of nonocupliance is repetitive in that a violation-for debris in cable trays '
was' identified in Inspection Report No.\\50-341/82-10.
. Corrective Action Taken and Results Achieved The area identified by the NRC Inspection was inmediately cleaned to an acceptable level.
Corrective Action to be Taken to Avoid Further Noncmpliance Detroit Edison has issued a project procedure on Housekeeping,' PPM 7.27, Revision 0, on May 9, 1983. ! Itis procedure establishes the policy and prac-tioes to. control housekeeping at the Enrico Fermi 2. site for all areas under jurisdiction of the project management organization. This procedure assigns the overall responsibility for control of housekeeping to the site manager.
Due to this procedure, the System empletion Organizi. tion (SCO) Director and.
<the Project Superintendent are required to perform a walkdown every month of i
each area under their jurisdiction, and complete a project h - aka m ing c.hecklist.
Project Quality Assurance has developed a program to monitor the effective-ness of' corrective action by Project Management. The objective is to pro-vide continuing analysis of the effectiveness of the Housekeeping program, to identify trends in housekeeping activities, and provide detailed infor-mation to. Project Management.
L The Date When Full Ompliance-will be Achieved Due to the' nature of this item of.nonccupliance, it will be an on-going activity although full compliance ie. considered to have been achieved.
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