ML20082U926

Responds to NRC Re Violations Noted in IE Insp Rept 50-341/83-21.Corrective Actions:Generic Retesting on Charger 2A1-1 Will Be Performed by 831230.Maint Instruction Revised to Include Balancing

ML20082U926
Person / Time
Site:	Fermi
Issue date:	12/01/1983
From:	Wells D DETROIT EDISON CO.
To:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20082U918	List: ML20082U926
References
EF2-66481, NUDOCS 8312190225
Download: ML20082U926 (7)

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- ; Donald A. WeHs c ManagerOuality Assueance-

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2000 Second Avenue M r 1, 1983 ja* i$3YMan 4e22s -

EF2-66481 lMr.' R.L.IRpa*=?rd,' Director m

Division of Engineering

'U.S. Nuclear Regulatory Comission -

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Region III T-z,

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Subject:

. Noncompliance?at Enrico Fermi ~ Unit 2 - IE Report 50-341/83-21 g.

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Dear Mr. Rpaamard:

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(This ' letter. responds:to' the ' items of noncmpliance described in your IE Report'No.:50-341/83-21. -This inspection of Enrico Farmi Unit 2 con-struction site activities was performed by Mr. S.G. DuPont on August 3

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through Septamaar 16, 1983.

l "Ihe items of nonempliance are ' discussed in this reply as required by

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Section:2.201 of the NRC's " Rules of. Practice, Part 2, Title 10, Code of Federal (Regulations..

lTheenclosedresponseis'~arrangedtocorrespondtothesequenceofitems

' cited in the body of your. report. LThe number' for the item of noncompli-

?ance and the applicable criterion is referenced.

'In response. to the NRC request regarding actions taken to improve the

quality of.the' conduct of the preoperational test program at Enrico

' Fermi--2, DetroitjEdison is currently preparing a response..to subnit-to

the NRC.. All organizations associated with the.preoperational test program have:been' directed to review [and report on procedural changes that have been implemented in the program ~since January,1982., This information is being e nnarized and will be sent to the-NRC in January,

-1984.-

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We trust this letter-satisfactorily answers the concerns raised in your report. lIff you' have questions, please contact Mr. G.M.~ Trahey, Assis-

Stant Director - Project Quality Assurance.

Very truly.yours, um/EHN/pnj j

lcc: -Mr. Richard DeYoung,. Director Office'of Inspection and Enforcement-LU.S. Nuclear Regulatory Comnission

. Washington, D.C.-

20555~

Mr. Paul-Byron, Senior Resident. Inspector

> U.S. ' Nuclear Regulatory' Cmmission.

~6450 North Dixie' Highway Newport, Michigan. :48166 fe s

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8312190225 831209 PDR:ADOCK 05000341 DEC 51983

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Mr.. R.L'. Spessard,. Director-November 21, 1983

EF2-66481

-Page;2

- bcci -F.E. Agosti T.A. Alessi

.A. Alexiou-C.R. Bacon L.P. Bregni

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.J.A. Cartmill W.F. Colbert O.K. Earle W.J. Fahrner.

D. Ferencz-E.P. Griffing C.M. Heidel W.R.'. Holland Institute of Nuclear Power Operations (INPO)

W.H. Jens-R.S. Lenart E..Lusis

~P.A. Marquardt/ Docket File (2)

- W.E. Miller, Jr.

E.H. Newton.

S.H. Noetzel J.W. Nunley.

E.M. Page R.G. Rateick W.L'.'Reid'

J.D. Ryan

.L.E..Schuerman

- D.: Spiers..

--G.M. Trahey

-R.A. Vance/L.E. Eix A.E. Wegele Site ncv,w nt Control

-NRC Follow-Up Book /NRC File.

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THE DETROIT EDISON COMPANY PROJECT QUALITY ASSURANCE ENRICO FERMI 2 PROJECT i

4-Response to NRC Report No. 50-341/83-21 Docket No. 50-341

-License No. CPPR-87 Inspection at: ~ Fermi 2 Site, Newport, Michigan Inspection Conducted:. August 3 through September 16,1983 Approved by:

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T.A. Alessi, D12kctor Project Quality Assurance N!/!63.

Date:

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,ResponsetoNRCInspectionRedortNb. 50-341/83-21 (83-21--03)

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Statement'of Nonempliance, 83-21-03 10CFR50,' Appendix B, Criterion XI, state's in part, "A test program shall

- : be. established.to-assure that.all. testing. required to demonstrate:that

-structures; systems, and cmponents will. perform satisfactorily'.in ser-

- vice is identified and performed-in accordance.with written test proce-.

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dures...".-

Startup Instruction 8.4.2.03, Section 4.4.1,= states in part,

~ "'Ihe following situation will. require generic CAIO retesting... corrective

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maintenance performed after original CAIO testing has been cmpleted."

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l Contrary to the above, the generic CAIO retesting was not done for the

. Division 1, safety. related spare battery charger (2Al-1) 'after corrective maintenance was performed.

'Ihis is a Severity Ievel 'IV violation.

Corrective Action Taken and Results Achieved

. Generic CAIO retesting on charger 2Al-1 will be done to insure that it performs satisfactorily.

. Corrective Action Taken to Avoid Further Noncompliance A formal-procedure which defines the requirements for retesting, Startup lInstruction 8.4.2.03, Supplemental Testing.was approved on OcWr 4, 1982.

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i Date When Full Ocznpliance will be' Achieved

.CAIO testing of charger 2Al-I will be cmpleted by namnhar 30, 1983.

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1 Response to NRC Incpection' Report No. 50-341/83-21 (83-21-04)

Statement of Nonempliance, 83-21-04 10CFR50, Appendix B, Criterion'XI,' states in part, "A test program shall be established.to assure that all-testing required to demonstrate that structures, systas, and cmponents will perform satisfactorily in ser-vice is idcntified and performed in accordance with written test proce-dures which incorporate the requirements and acceptance limits contained in applicable design documents." The vendor manual for the safety related battery chargers (C&D battery) requires that after a modification or corrective maintenance is performed, the chargars have to be

-rebalanced.

Contrary to the above, theLlicensee's preoperational, CAIO, and mainte-nance procedures did not incorporate the requirement to re-balance the safety related battery chargers after modification or corrective mainte-nance had been performed.

This is a Severity Ievel IV violation.

Corrective' Action Taken and Results Achieved Neither PRET.R3201 or CAIO.000.019 were written to perform retest after maintenance. PRET.R3201.001 was written to verify that the 130/260 Volt DC system meets its design requirements. CAIO.000.019 was written to perform initial calibration on the battery chargers with the chargers in

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the condition shipped by the vendor. The vendor manual contains section i

2.6 " Preliminary Instructions" in which all rev e ded CAIO activities i

are specified. CAIO.000.019 contains all of these activities. It is

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adequate for its intended purpose, which is initial calibration, but inadequate for post maintanance testing.

The battery charger instruction manual contains instructions for re-balancing the chargers. Re-balancing is recessary sfter " Field Modi-fications". These instructions are in the " Corrective Maintenance" sec-tion of the manual and should be addressed in the Battery Charger Maintenance Instruction " HIE.000.002 Battery Chargers 130V". This Maintenance Instruction does not have balancing instructions included, i

.' but references ~the vendor manual.

Corrective Action Taken to Avoid Further Nonempliance

' A formal procedure which defines the requirerrents for retesting, Startup Instruction 8.4.2.03, Supp1 mental Testing was initially approved on October 4, 1982. In addition, Maintenance Instruction MIE.000.002 will be -revised to include balancing instructions. The entire preoperational test, PRET.R3201.001 will be repeated using a new revision, Revision 2.

Date When Full Compliance will be Achieved

a. _Startup Instruction 8.4.2.03 is in effect at this time and all Startup personnel have received training on this instruction.

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MIE.000.002 and PRET. R3201.001 will be revised and the test repeated prior.to June, 1984.

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Response to NRC Inspection Report C. 50-341/83-21.

(83-21-05)

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Statement of Aru.auw11anceP 83-21-05

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t10CMtSO,H Appadix B. Criterion III, states in' part, (" Measures shal'. be nestablished to assure that,. applicable regulatory requirements and the

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design basis for those structures, systems,- and ocuponents.to which this appendix applies are correctly translated into specifications, drawings,

. procedures,'and_ instructions. These measures.shall. include provisions to assure:that: appropriate quality standards are specified and included in i -

design hunants and that deviations from'such standards are controlled."

FSAR,,Section-8.3.1.1.9, states _in part,."The 120/120 Vac,-15~kva, regu-u lated power for instrumentation loads, has.an output variation of 10.5 t

. percent forcinput variations of +10 percent, -20 percent." Test and Startup Administrative Procedures Manual,_Section 4.9.6, states in part,

'"After receipt of a written reply.frun Edison Engineering _to the Startup

- Field Report -(SFR), the design change may be made permanent when the required. design. change h=nant is issued." CAIO Procedure, CAIO.000.

c137,. states in part,: "'1he required output setvoltage shall' be '1201.25 -

7 Vac."

. Contrary to the above, the'following instances were noted during the

= review of-preoperational test results for Instrument and Control Power 1 System Preoperational Test, -PRET R3100.001 where management controls

failed to assure that' appropriate quality standards are specified and

-included in design hunants, and to contro1~ deviations fran such stan-dards.

-1 Contrary to the FSAR, Section'8.3.1.1'.9, the preoperational test

a.. ;results were accepted.with an acceptance criterion that deviated' outside the FSAR requirement without an appropriate request for a p

permanent revision to the FSAR.

lb'. -Contrary to.the CAIO procedure, a incorrect value was recorded for.

the required setvoltage and was' subsequently accepted by startup, l

'and audited and ac w t.ed by Ouality Assurance.

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. This is a Severity Ievel. IV violation.

L Corrective Action Taken and Results Achieved.

(a. An FSAR Change Notice, PCN-83-181 has been. written arid approved that will bring FSAR Section 8.3.1.1.9 into agrec=ent with the preopera-

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tional~ test results. This change will appear 1n Amendment 52 of the

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v FSAR'which is' scheduled to be issued in January, 1984.

[.y b.i No corrective:actionLis necessary for the following reasons:

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L1. !The STE misinterpreted the intent of-step 7.1.1 on 7.8 #496 BE.

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.He recorded the' voltmeter M&TE number used to verify the input 1

. voltage instead of the regulator output voltage.

'2. iThe intended regulator output voltage value is recorded in step

- 7.1.2'of the same test form.- Tne recorded value is within the

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acceptance criteria stated in step 7.1.1;

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f Response to NRC Inspection Report No. 50-341/83-21 (83-21-05)

Corrective Action Taken to Avoid Further Nonccrnpliance k

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a.

Although Detroit Edison has continuously updated the FSAR since the time it was first subnitted, additional measuras have been taken to further assure its accuracy.

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1.

An FSAR accuracy review has been initiated that will be performed h

by the individuals assigned responsibility for FSAR sections.

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E Personnel frcxn Nuclear Production, Startup and Project Design i

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will assist Nuclear Engineering in this review. The entire FSAR will be included in the accuracy review. Necessary revisions g.

will be processed and issued in an amendment to the FSAR.

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2.

Startup Engineering Assistance is re-reviewing preoperational test results on preoperational tests performed before issuance of E

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the noncmpliance. The purpose of this review is to ensure that C

E preoperational test results are in agreewnt with criteria stated in the FSAR. In addition, Field Engineering's Work Procedure FEWP-14 is being revised to assure that test results frcm all r

future preoperational tests are in agreenent with criteria stated

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K in the FSAR.

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3.

A directive has been issued re-emphasizing Detroit Edison Policy i-to maintain the accuracy of the FSAR.

E These measures will provide additional assurance that the FSAR E

will accurately reflect the plant design and proposed method of i-g_

operation.

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A letter (SU-12,017), pertaining to test results review, was sent to all STEs shortly after the noncmpliance was issued by the NRC. This r

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letter was the corrective uction for an interim period. Since then, y

Startup Instructic,n 8.4.2.05 (Test Results Package Preparation / Review)

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has been revised to address the subject of test results review.

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E Date When Full Cmpliance will be Achieved E-E a.

1.

Revisions resulting frcxn the accuracy review will be issued in an b=

FSAR Amendment in March, 1984.

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Reviews on previous preoperational test results will be cmpleted i

E in January, 1984.

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FEWP-14 will be reviced in January, 1984.

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Startup Instruction 8.4.2.05, Revision 2 was approved on November 9, g

1983.

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