ML20084Q268
| ML20084Q268 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/11/1984 |
| From: | Jens W DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 101, EF2-68541, NUDOCS 8405210189 | |
| Download: ML20084Q268 (6) | |
Text
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- Edison EEFL May 11, 1984 EF2-68541 Mr. James G. Keppler
. Regional Administrator Region III
.U.S. Nuclear Regulatory Commission 799' Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Reference:
(1) Fermi 2 NRC Docket No. 50-341 (2) Detroit Edison Letter (EF2-65288) to NRC Dated October 20, 1984 (3) Detroit Edison Letter (EF2-66490) to NRC Dated December 22, 1983
Subject:
Interim Report of 10CFR50.55(e) Item #101 Debris in Piping Systems On September 20, 1983 Detroit Edison's Mr. W. R. Wingfield, Quality Engineer-Construction Quality Assurance, telephoned Mr.'H. M. Wescott 'of NRC Region III to identify problems related~to RHR Pump "B". This was subsequently confirmed by-letter on October 20, 1983. This letter (Reference 2) listed various items of debris in piping along with mechanical problems with the RHR pumps. On December 22, ,, 1983 (Reference 3) Edison advised the NRC Region III that Project Quality Assurance was going to separate the mechan-ical problems (i.e. , linear indications on the RHR pump impellers)-from the debris in piping item. The mechanical
. problems were assigned 10CFR50.55(e) Item Number 107 and the
. debris in piping problem was assembled under 10CFR50.55(e)
-Item Number 101. This letter provides an updated report on the debris in piping item.
- Description of Deficiency During.the preoperational testing phase, construction debris was found within safety-related piping systems contrary to approved Detroit Edison cleanliness requirements.
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Mr. James G. Keppler Jhy 11, 1984 EF2-68541 Page 2 Analysis of the Safety Implications
' Debris remaining in safety related piping systems could result in the affected system not performing its intended function, - thus possibly degrading those functions in an indeterminate manner. Safety analyses are performed on a case-by-case basis as debris is identified. Results of all '
safety. analyses for specific debris found will be presented in the Final Report on this item. Corrective-Action In order to provide a comprehensive response to the subject i deficiency, the discussion of corrective action is presented
' 'as described below.
- 1. The. initial discussion addresses the specific debris '
identified to date. The inspections and safety analy-ses initiated to scope the extent of the problem and assess its impact on safety are also identified.
- 2. In addressing the concern on a generic system basis, the Fermi 2 programs in place to purge debris are des-cribed. This discussion 'is provided to indicate lthe comprehensive nature of the Fermi 2 approach to clean-liness.
- 3. In addition, a description of the revisions made -to .
Fermi 2 ' inspection and maintenance procedures that will more positively control materials and personnel access - to open systems is provided. A discussion of the safe-ty -reviews which are initiated as a result of identi-fled debris is also included.
' ' It is the. Edison position that subsequent to completion of these programs, the operation of safety-related systems will .
L not be. impaired due to debris in piping. Actions taken' specific'to debris found: ; Reference 2 provided a description of the immediate correc-
.tive actions initiated after identification of theIndebris addition, (i.e. , set screw and plywood) in the RIIR line.
4 subsequent investigations were ' performed on related portions of the affected system to ensure cleanliness. Similarly, as a , result of" subsequent incidents involving debris in safety-
-related~ piping systems, follow-up inspections were conducted as follows:
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.May 11, 1984
- EF2-68541 o 'Page 3
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r 1) adjacent to...'the. location where debris was found;
- 2) at piping _ orientations...-within the affected system
'where debris-may be expected to lodge or come to rest (e.g., dead-{egs, orifices).
- The; final report to~this 50.55(e) will.more specifically delineate the debrisethat was found, the nature of that debris,7and-the areas of safety related systems that were
. inspected to insure they were free of; debris.
Upon-identification of. debris, Edison initiated a safety
-_ review to' assess _the potential safety impact of the debris.
y General Electric has provided support in this task. As a
" result of reviews performed, GE has recommended additional locations within the affected piping systems where further
. inspections may be required. Edison has/will address these recommendations on a case-by-case basis considering what has
.been inspected-to date. The final report to this 50.55(e) will-provide the-results of the following: GE and Edison safetyEreviews recommendations; the initial and followup inspections; and final justification to support Edison's conclusion that the existing systems are free of significant debris.
Programs to Ensure Cleanliness: Detroit Edison has several programs in place which have been developed and implemented to minimize the probability of debris.being left'in piping. The two primary programs that serve to ensure system cleanliness are the flushing program (virtually complete) and the preoperational test program (on-going). . ' Both programs are briefly discussed below. o Flushing Program 'The purpose of the ' flushing program was to adequately ensure-that closed systems were pro-perly purged of foreign material. In' order to properly flush these systems, Fermi 2 utilized a temporary system which provided1 flushing paths for. systems that could not normally be flushed during the construction phase. iThis temporary flushing system allowed systems to be flushed at flow rates meeting or exceeding their normal design rates. L._
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< fMr. James;G.'Keppler
% - May 11,L1984-1 IEF2-68541
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-PageL4 1 Hall-? systems connected to th'e reactor vessel were c rinitially back_ flushed. Those systems with discharge
-lines' connected tcr the reactor vessel were then flushed with.the temporary flushing system, when available,,and
* ,s ;the: system pumps, when available. In addition, all f _ ,
Class'B lines were only accepted ~as clean after both a
< : chemistry. analysis and timed flushes through flush
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cloths were acceptably performed. 4 - 'Aireview of the flushing program indicates that the
, program either removed the debris from the system:or moved it to a location or orientation that would be " preclude its removal under subsequent system operation xor additional' flushing.
. , -Onceia system.had been flushed, all subsequent con-
'struction was to be performed to'the same cleanliness classiasithe criginal flush. This requirement was n
identified-on.the work documents.and compliance con-
- firmed'via signature of appropriate' individuals on the work-document.
Y o 'Preopera'tional Test Program - Subsequent to system 2 flushing, the systems were or.will be. operated in
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.accordance with the preoperational test program. This a, , 4 program is performed - to verifyidesign flow ' rates,
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> . 1 pressure = drops,'leakageirates,;and ensure. proper
.overall operation of'thel system.1 .For these tests k ' ya .various operating ; parameters are ' monitored and recorded. Any. discrepancies. indicating less than _
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;; CM ; acceptable system performance will be documented and'
, . 3, ; , addressed.; ;(For. example,.if~aiflow obstruction is-r"- ~ " ' ~
JpreVentingsthe.: system <from> achieving its required flow, it .will' be . identified, documented 'and resolved. )
< /, Additional:Actionito PreventARecurrences' H~ ~
y/ c< - , u LAsLindicated previously, Edison has also reviewed and
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e~ < fre' vised, where.necessary, many.of.its maintenance, testing-
.s a'nd' inspection procedures to. enhance both the materiali inventory control procedures and the opening and closing-( ,' ;
cleanliness practices:used.inLthe-vicinity of open systems.- 1The 4 revisions encompass all . intrusions into QA Level:I, 'II _ ' ~ rand LIII'syntems by" construction and into safety-related
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systensibyLmaintenance personnel. The following examples ~ er,T are?provided -to indicate how Edison -procedures have :been-revised., ^ _Sm
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.fo- -Additional training of plant personnel to increase
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their awareness of.the;importance of; system
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cleanliness.1
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s . "o* Administrativ'e Procedure' 12.000.48 was revised'to irequire..an; independent verification for-cleanliness of safety-related systems, when systems are' initially
. opened and prior to their closure.
li Project ? Procedure ~ 7. 27, Rev. fl, and ! Procedure 12.000.48
- ' identifyimore comprehensive housekeeping criteria for aworkiin defined cleanliness zones (e.g., minimize
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traffic?in proximity with an open' system; inspect
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iclothes and tools for loose. articles and parts,-
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a -. ,respectively; assign a? responsible craft person or 37 , securityLto oversee work while system is open and
. 'A secure closed when not present).
- NOTE: This item;is more specifically discussed'in j f"' . ' Edison's~ response to Inspection Report-( ,j No._50-341/83-28.
o SCO Procedure 13.1, . Rev. $ requires a daily. walkdown to ensure: " Cleanliness is-maintained; spare.and disassembled components are properly tagged and
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segregated;' ope 64 ended pipes,' conduits andJtubing are properly: protected;;and=that all-deficiencies"are' e "
. identified'and promptly addressed.
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- 1 LTheLpreceding" discussion has1 focused on progba~us and proceduresfin. place to. prevent debris from befag introduced into or remaining in"a safety related system. If~ debris is found~upon opening a safety-related system," Procedure, F 12.'000.48 requires Edison Engineering to be notified..
E < 1 Engineering wills ~
- a 41. ' ensure the debris'is documented,-
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. 2. ' conduct or: authorize the conduct of a safety analysis
.to determine the safety implications of the debris,
- 3. . determine the need for supplemental inspections on the 2" " ,same.and other systems (supplemental inspections'can be
- -performed in'a number of ways, such as direct' visual 4 ' ,. inspection, inspections using boroscopes,. cameras,
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X-rays, and personnel crawling.through piping if it is reasonable to'do so),
- 4. document resolution.
The; procedure-(12.000.48) described above was used in
! assessing. nafety impact of ' debris addressed in' this report.
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.. Mr. Jam:0~G. Kappler May 11, 1984 EF2-68541.
Page 6 Edison feels.that the programs in place at Fermi 2 provide
- adequate assurance that the systems in their final configuration will;be free from debris that could impair
' their proper operation.
.The final report on this 50.55(e) will' provide specific results for the reviews identified as ongoing in this submittal. If you have any questions concerning this matter, please contact Mr. Lewis'P. Bregni,-(313) 586-5083.
-Sincerely, 1
cc:. P. M. Byron 1(( 1h) R. C. Knop US NRC, Document Control Desk Washington, DC 20555 4 N.'}}