ML20079R130
| ML20079R130 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/09/1983 |
| From: | Wells D DETROIT EDISON CO. |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20079R119 | List: |
| References | |
| EF2-64303, NUDOCS 8306220030 | |
| Download: ML20079R130 (3) | |
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' i Donald A. Wvis 2
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Manager Guam ssurance I
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(313) 237 W57 f
2000 Second Avenue i
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s June 9, 1983 EF2-64303 4
r, e f r. R.L. Spessarc,. Director M
. ' Division of Engineering U.S.' Nuclear Regulatory Ccmnission Region'III
? b Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Noncompliance at Enrico Fermi Unit 2 - IE Report 50-341/83-04..
Dear.Mr. Spessard:
This letter serves to correct two (2) pages of our response to two (2)
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itms of noncmpliance described in your IE Report No. 50-341/83-04, which was issued as a result of the inspection of Enrico Fermi Unit 2 construc-tion site activities performed by Mr. F.W. Reimann on February 4 through March 17, 1983.
Our responses to itms number 83-04-04 and 83-04-07 are correct, however, the " Statements of honempliance" for these two (2) itms were inadver-tently interchanged.
Attacbed are h corrected pages for the two (2) Items of Nonccupliance.
Please remove the corresponding two (2) pages from your copy, and re-insert the corrected pages (attached).
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%p regret this error on our part, and bope this has not caused any undue
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inconvenience.
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sveg truly yours,
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' /2W/h1M/pn Attachment cc: Mr. Richard DeYoung,, Director
. Office of Inspection'and Enforcement U.S. Nuclear Regulatory Ccmnission
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Vashington, D.C.
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Mr. Bruce Little, Senior Resident' Inspector i
4 U.S. Nuclear Regulatory Ccmnission 6450 North Dixie Highway Newport, Michigan 48166
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PDR.ADOCK C5000341 G
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Response to NRC Irspection Rejort No. 50-341/83-04 (83-04-04)
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-i Staterrent of Noncanpliance, 83-04-04 s
'iOCFR50, Appen11x B, Criterion XVI states in part " Measures be established to' assure that conditior.s adverceh quality, such as failures, malfunc-
' tions, deficipacies, deviations, defective material and equignent, and non-coriformances are prmptly identified and corrected". This requirement is reficcted in the Quality Assurance Manual, Startup Manual, and in the NOTE preceeding the test procedure steps of Preoperational Test Procedure PRET.
33000.001, Section 6.0, " Procedure", which states "If the diesel generator stocad fail to start for,any reason, a detailed explanation for the failure and corrective action shS11 be given in Energency Diesel Generator 11 -
Data Sheet B".
h Contrary to the above, on March 2,1983, the Dnergency Diesel Generator 11 experienced four ccnsecutive start failures and detailed explanations for the failures and corrective actions m re not given in Emergency Diesel Generator 11 - Data Sheet B.'
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Corrective Action Taken and Results 1chieved a
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10CFR50, Appendix B, Critericn XVI states in part " Measures shall be estab-lished.to assure that conditions adverse to quality, such as failures, mal-
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functicns, deficiencies, deviations, defective material and equignent, and nonconfonnances are prmptly identified and corrected". This requirement is reflected in the Quality Assurance Manual, Startup Manual, and in the NOIE preceeding the test procerlure steps of Preoperational Test Procedure PRET.
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R3000.001, Section 6.0, " Procedure", which states "If the diesel generator
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should fail to start for any reason, a detailed explanation for the failure and corrective action shall be given in Emergency Diesel Generator 11 -
Data Sheet B".
A 2reakdown of administrative controls occurred when the STE failed to make an entry in Data Sheet B (Start Failure Iog) for each of the unsuccessful j
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-starts on March 2, 1983. This is in violation of site procedures during c
the performance of FRET,R3000.001. However, during operation of Emergency
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, Diesel Generator 11, a bird bound record log book was kept to provide a can-
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' plete histor( of engine operation.
t 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.
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evaluaticn was conducted by the Startup Engineer and his designee (Senior Electrical STE). These persons were not directly involved with engine oper-ation on,the date in question, March 2, 1983. The results of the indepen-dont staff s investigation resulted in the corrective actions stated below.
Corrective Actica to be Taken to Avoid Further Noncanpliance All Startup Test Engineers and Startup Teut Technicians have been informed by;1etter, fran W.R. Holland, Vice-President - Fermi 2, dated March 14, 15/d3, to canply with all requirenents of procedures and not to deviate without proper documentation and authorization. Startup ccnsiders this letter as final corrective action, and is in full canpliance with above Criterion.
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Respmse ~ to Mtc Inspection Report No. 50-341/83-04 (83-04-07)
- Statement of Ncn.uw11ance, 83 '4-07
'10TR50, Appendix B, Criterion. XI requires that the test program for-systems
- and -wents be performed in accordance with written test procedures.
This requirement-is reflected in the Startup Manual and Chapter 14 of the FSAR. - Preoperatimal Test Procedure PRET.R3000.001 "Bnergency Diesel Gener-
- ator Systems", requires that prerequisite valve and electrical lineups, 4~
auxiliary system filling and venting, and system operation be acccuplished i;
iin accordance'with Operating Procedure SOP 23.307.
Contrary to the above, prior' to testing cri March 2,1983, the starting air and fuel oil systes 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 The uncapped fuel oil' piping was clearly an oversight on the part of the support crew responsible for the task. As stated in Docket 341, Details,
- Paragraph d.1, when this concern was mentioned.to Startup personnel,-proper covers were placed over the a - ad piping. Subsequently, the Maintenance Department was' contacted to irrplement necessary action (s) to ensure such oversights are properly addressed. Mr. C. Bergren (Edison Maintenance
. Department) stated that the maintenance personnel responsible have been re-instructed in the proper procedures by the Maintenance Department General Foreman.
10GR50, Appendix B,: Criterion XI' requires that the test program for sys-
. tss and-cmponents be performed in accordance with written test proce-dures.- This requirement is reflected in the Startup Manual and Chapter 14
-of the FSAR. Preoperational Test Procedure PRET.R3000.001 "Bnergency Die-1 sel Generator Systems", requires that prerequisite valve and electrical
.line ups, auxiliary system filling and venting, and system operation be accmplished'in accordance with Operation Procedure SOP 23.307.
' The change of the Fuel Oil Pump Discharge Relief / Regulating valve was cczn-pleted in'accordance with site procedures. The NRC Inspector was mis-
.takenly informed that the replacement valve was " identical". It was'in fact, eJ1 equivalent OA-I valve' of similar range and size. This change was f perfonned in ccanpliance with FSAR Chapter 17, which discussed Vendor and Suppliers OA prograns, and provides assurance that a replacement ewwent does not degrade a system.
On the date specified, March 2, 1983, a valve'line up'was witnessed by the NRC inspector. This line up was performed by the'STE'and Operations' per-sonnel,' but they failed to perform Fuel Oil Subsystem venting in accor-dance with the SOP.
Per the STEs log entries, the first two' (2) start attempt of Emergency
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