ML20100J007

Responds to NRC Re Deviations Noted in Insp Rept 50-341/84-16.Corrective Actions:Util Committed to Provide Alternate Shutdown for Control Ctr Area

ML20100J007
Person / Time
Site:	Fermi
Issue date:	10/09/1984
From:	Jens W DETROIT EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20100H977	List: ML20100J007 ML20100J024
References
EF2-70022, NUDOCS 8412100189
Download: ML20100J007 (9)

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g Wayne H. Jens

. Vice Proskient -

Nclear Operations Fermi-2

- 6400 North Dxie Hghway

.. ) Newport. Michgan 48166 October'9, 198'4 (31si see-41so EF2-70022 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory-Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Reference:

Fermi 2 NRC Docket No. 50-341

Subject:

Detroit' Edison Response NRC Inspection Report No. 50-341/84-16 This letter responds to the deviations described in your Inspection Report No. 50-341/84-16.

This inspection was performed by Messrs. 'J.

Ramsey, F. Maura, R. Eberly, H.

Thomas, and T. Cappola on May 14-18, June 5, and July 10 and 11, 1984.

The items classified as deviations are discussed in'the attcched response and are arranged to correspond to the.

sequence of items cited in the body of your report.'

On September. 12,.1984, Mr. L. Bregni contacted Mr. J. McCormick-Barger of the NRC Region III office and-received an extension-to the'30 day response due date because Edison.did not: receive Inspection Report 84-16 (dated August 31, 1984) until September 10, 1984.

We trust this' letter wil1' satisfactorily respond to the deviations listed in your report.

If you have questions regarding this matter, please contact Mr. Lewis Bregni, (313) 596-5083.

Sincerely, f

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Mr. P. M. Byron Mr. R. C. Knop Mr. C. Ramsey 84121001898412{"

OCT 15 W DR ADOCK 050oop

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.,1 r-THE DETROIT EDISON COMPANY FERMI 2, NUCLEAR OPERATIONS ORGANIZATION-

- RESPONSE-TO NRC REPORT NO. 50-341/84-16 DOCKETINO. 50-341 LICENSE NO. CPPR '

INSPECTION AT:. FERMI 2, NEWPORT, MICHIGAN

. May 14-18, June 5, and July 10 -11, 1984 INSPECTION CONDUCTED:

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~ RESPONSE TiNRC INSPECTION REPORT NO. iS0-341/84--16

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s 7, Statemerit :of Deviation"84-16-02:, (/31

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By. letters datedlJuly. 31, 1981, Novemb'er - 24,;1981 and.

January;4, 1982, the'applicanttprovided;the-NRC.with the

-resultstof fire tests conducted on.the control. room' panels containinglthe controls., instrumentation and associated circuits for:all thefrequired_ safe-shutdown' systems. 'As a result ofstheDfireatest. conducted, the applicant committed-itoJcertain design modifications:to theopanels to enhance.

Ltheir fire _ resistive capabilities andl provide assurance that Jone train.of systems needed forJsafe shutdown would remain

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free of fire damage in'the event of a; control room fire..

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!The applicant committed to meet the requirements of. Appendix-

-R to110 CFR.Part 50 as discussed in a meeting 3with-the.NRC

.staffron May 27, 1981', and to demonstrate that a single fire would not' damage.both redundant safe, shutdown-trains.

Contr'ary to'the above, the appl'icant failed to provide.the design modifications to the-control room panels containing 7the controls,Linstrumentation and associated circuits'for

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t al1~of the required safe. shutdown' systems that were; SER and. letter: submitted to the NRC.

-described in the FSAR,

-The as-built' configuration.of these panels does not provide assurance that one train of. systems needed for safe shutdown will' remain free.of fire damage in the event of a control F

i' room fire.

The applicant-had.no planscto complete these

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. design modifications.

This'is consider'ed~a deviation from

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previous commitments'to the commissionLand is further:

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discussed in paragraph.4c(4) of<theLinspection report.

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' Detroit Edison' Response"and Action Takent In the' process of resolving the fire protection is' sue in 1981, Edison committed to a number of modifications-to'the:

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-plant. 'The specific agreed upon changes.werelidentifiedfin Supplement No.2 to the SER~. dated January, 1982. -Edison-had.

L completed these identified commitments.or was in the process

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.ofenegotiation with NRR at the time'of the Region III.in ~

spection.

In'the~ process of. negotiating with'NRR towards aniacceptable H

-solution'to the issues raised in Generic. Letter 83-33,-

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Edison has now committed to provide alternate shutdown for-

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the control' center area.- This commitment was made at-the

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July 11, 1984, meeting and supersedes the : earlier: commit-ments made in previous letters.

Official notice of.the g

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RESPONSE TO NRC INSPECTIUN REPORT NO. 50-341/84-16 commitment'to alternate shutdown'via Appendix R III.L was.

submitted to'NRR in-EF2-72718 d?ted August.16, 1984.

We understand that NRR will revise the'SER on this subject.

'In light:of the above, the findings-cannot be addressed without including the commitment to'use an alternate shutdown method, which reorders any-of the Control Center modifi-cations to an' interim measure status.

J The response to the seven deviations of the inspection report.84-16, Section 4c(4) is as follows:

-(a)

"The panels were not completely enclosed and free of penetrations."

(b)

"The panels were not provided with separate forced ventilation systems.

Instead, the applicant determined that natural ventilation was sufficient."

During'the review process with NRR, there were some discussions.regarding enclosing the backs of the remaining safety related panels.

However, enclosing the backs of the COP panels was not entered on our internal action-list and failed to show up as a-licensing conditionnin any SER supplement.

After

-Supplement 2 to the SER was issued, there were further' discussions with NRR.regarding the back on panell Hil-P602 and-the upper ventilation openings on the-other control room panels as part of-the description of the proposed COP ventilation modifications.

The notification for the change of the commitments for the panel ventilation was_made in Detroit Edison's Letter EF2-61562 dated March 1, 1983.

The ventilation and panel enclosure issue-was discussed.in Region III Inspection Report, Open Item 341/83-12-01, and~was open pending NRR's decision on the request.- NRR's decision on this subject was not indicated to Edison until the~ ventilation request was verbally denied 2at y

the' April 3, 1984 meeting.

This subject, as part of

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b the control room agenda, was discussed in the June 5, 1984 and July ll, 1984 meetings that resulted in the commitment by Edison to use alternate shutdown to meet Appendix R.

Edison intends to fully comply'with-the identified commitments made in the August 16, 1984 letter, but previously identified commitments for the i~

control center to meet Appendix R III.G are no longer applicable. -Theref fs there will not be a back installed on Hil-0602 nor will the upper ventilation lels Hil-P601 will not have a top louvers be clo 4~.

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,o RESPONSE TO NRClINSPECTION: REPORT NO. 50-341/84-16.

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~ installed nor willLthe ceiling panels require'modific-ationf(see item (g)).- The unsealed penetrations.

<between'the: opposite' division panels are discussed' Lunder item-(d).

Thesventilation-modificatio'n was identified in Supplement No.2 of the SER as a commitment.

The

> proposed modification. consisted.of supplemental fans, a

-fire dampers, and~ductwork.into"the COP's.V In the

' process of'de' signing the system, it became apparent.

c that the heat generated by,the panels'could be removed 1

by.a: simpler method. ;As mentioned above, the

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possibility of changing this commitment was discussed with NRR and' documented in'EF2-61562 of March 'l',119 8 3. -

cEdison' considered'this item as under! negotiation with

.NRR until the April.-4, 1984 meeting where thiscrequest

- was-verbally denied.

Additionally, Region 1III open.

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item 341/83-12-01 listed the ventilation 1 status:as open-l pending the NRR decision.

However,fthe' commitment lto

~use alternate shutdown as a-means of shutting.down from

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'a. control room fire supersedes;the previous commitments-3 S

for a COP.HVAC system.

Edison.does not intend:to install a COP ventilation-system.

(c). '"All plastic components such.as' face plates, annunciator boards and control switches were not m

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J' removed from the front of the panels =and replaced with glass or other noncombustible materials."

Edison agrees that there was a commitment to~ reduce ~the' g'

5 amoun6'of plasticiin the. COP, butinot all' plastic components-were included in that. commitment.

For.

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L, example,1 Edison' conducted a heat-up test on the plastic g

control 1'(CMC)'and pushbutton switches =to show theys

.could withstand the temperatures, as indicated in the November, -1981 report " Evaluation of Selected' Control Panel' Components Subjected to a.PostulatedfExposure Fire." fEdison would not have-conducted;such.testsTif.

y these plastics were.to be' replaced. ' Edison has' 7

replaced the plastic annunciator window inserts with glass'as stated in Supplement No.2 of.the SER, summary '

of the. proposed. modifications.

' Recorders that have plastic windows will be replaced.

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with~non-glare glass.

Thic replacement'will also l'

improve the ability to read the instrument..The commitment 1made at'the July 11, 1984-meeting to usel alternate shutdown for the Control Room actually-suoersedes;the need for the earlier commitments to reduce the-plastics.

Edison thereforedoes not plan to replace any other plastic other than the annunciator and' recorder windows.

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e RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-16 (d)' - "The panels contained-louvered openings and open spaces

~ t) floor: level between'the floor penetration seal' and a

the'four inch concrete. ped which the panels are mounted on.-

UnsealedLpenetration_ openings existed around a ground; bus barspenetrating the 3/16 steel plate between each set of panels."

. The ~ louvered openings at the floor level on the' back. of panels-Hil-P601 and Hil-P812 have a steel plate mounted behind the louvers.

(Panel Hil-P812 is a non-safety related panel that separates-the rear of panel'Hil-P601 lfrom the open~back.of Hll-P602)

The remaining shutdown panels do not have_ louvered openings at the floor' level'.

TheLopenings between the redundant panels at the floor penetration and around the ground bus bar should:have

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been sealed based on the SSER statement that the steel panels _are free of penetrations.

Edison has sealed-these openings.as indicated in the July ll, 1984 meeting and in EF2-72718.

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(e)

" Louvered access' doors covered with marinite board installed on the front of the' panels are interchange-ableLwith other control room panels that are not

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required for safe shut'down.

During the inspection, one.

of..these doors was-found installed on a control room panel not required'for safe shutdown.

A louvered access door-that was not covered with marinite board was' installed in safe shutdown panel P-602."

Edison-did complete the SER-commitment to install a-Marinite panel in front of the COP. lower access' doors.

'However, as indicated in the inspection report, a' Marinite covered and an uncovered access door were interchanged.

As soon as this problem was discovered,-

.the' access doors'were immediately switched so that the doors were.in the proper location.

As indicated in the July 11, 1984 meeting'and_in Detroit Edison's letter EF2-72718, Edison committed to.

' labeling the'outside of the doors ~or affixing mechanical' devices to ensure the doors aretinstalled on the correct panel.

(f)

" Unidentified' Division I and Division II cables were installed on,the west control room wall near the; rear of panel.P-602?and'in the. ceiling above panels P-601~

and-P-602."'

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RESPONSE-TOlNRC INSPECTION REPORT.NO.~50-341/84-16 n-

'A number;of safety related_ circuits are routed in.

'A tconduit on the west' wall and'above:the false-ceiling-overl panels'Hll-P6011and Hil-P602. 'These conduits 1are c

controlled'and identified ~in the cable' routing' program..

.None of the circuitsidirectly: behind cHil-P602 'were

' identified as being required for/ Appendix R shutdown.

Certain conduits located above the false ceiling.were-

identified as required by. Appendix ^ R,and. were ; included in the. conduit wrap program.. However,'the commitment.

'tx)-shut down the; reactor using an alternate shutdown

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capability-removes these circuits from the Appendix _R' n

program.. As indicated in the1 July 11, 1984 meeting and

~b in EF2-72718,ithe" fire wrapping will'not be' completed-anycfurther in-the control center.

Wrap;that is

' presently installed will be maintained until the alternate shutdown capability is operational'.

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(g)

"A1 false ceiling was installed above: panels P-601 and P-602 which was not previously described to the NRC and was not included in the applicant's prototype-for

-testing of-the panels."

The false _ ceiling referred to in this report-is

' believed to be~the facade-ceiling' extending down to'the top of the front panels, including panels lHll-P601'and Hil-P602.

This ceiling was in= place during the: time,of

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the.1981_NRR' inspection and was not raised as an issue._

-_The purpose of the' prototype' fire.testLof the-panels was to demonstrate that the circuits inside the

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adjacent. panels were not damagedafrom an exposure fire-

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outside the panels, potentially ' causing, fire damage 'tx) circuits'in.both divisions..The' commitment tofprovide-i's alternateishutdown capability, made at the.' July 11',

SS 1984' meeting andnin'EF2-72718,.supersedesLthe need to demonstrate that: fire damage would not occur -tx); both divisions..

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E" RESPONSE TO NRC. INSPECTION REPORT NO. 50-341/84-16 2

Statementof Deviation 84-16-09 In response to the NRC position stated:in Appendix9B,of the

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AFermi-2-FSAR, the' licensee.made.a-commitment to install.the fire pump 4 installations:in accordance with National Fire Protection Association' (NFPA) -Standard E 20. : NFPA 20 requires-

that theJfuel. oil storagestank for diesel 1 engine driven fire.

pumps beJfull at all' times and-be-freelof'all water and

-foreign material'.

The temperature of:the pump room, pump house.or areas where diesel--engines are. installed is required to1be maintained not less.than:the minimum recommended 1by the engine manufacturer.. 'This minimum is_

generally 70" F.

Contrary to~the above, the, diesel fire pump fuel o111 storage tank is installed above ground outside of the fire pump-4 house and is exposed to freezing -temperatures and gelling of the diesel fuel during winter--months.

Thisicondition does not meet the intent of NFPA 20 and could result-in.the failure of the diesel fire pump during cold weather.

This is considered a deviation from previous commitments to:the' Commission and is further: discussed in' paragraph 7.a. ofo the

. inspection report.

Detroit Edison Response-and' Action Taken-The current version of'NFPA 20 is 1983.

' Paragraph 1-2'2~

existing installations, states that "Where existing pump -

ins,tallations meet the provisions of1the standard in effect ~

- at the time of purchase, they may:remai'n in use' provided they.do not.. constitute:a. distinct' hazard to: life or

- adjoining property."

The Fermi 2 FSAR' identifies NFPA 20-1970 as the code version in effect.at the " time of purchase".

-The' system as currently installed meets the requirements ~of NFPA-20-1970'

,and the present. location of the tank does not " constitute a L

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distinct hazard to life.or' adjoining. property".

NFPA 20-1970 requires the tank be "... located-in accordance with municipal ordinances and requirements of'the authority having' jurisdiction." 'The tank met thisteriteria'at the time of installation.

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Supplement 2Hof-the SER identified the location of the diesel fuel oil tank as'being outside.'. This location is i

consistent with Appendix A of BTP.9.5.11and was accepted by-

. NRR in. Appendix. E, ' Supplement No. 2 of the ^ SER. Edison 1 believes.the tank location:is proper.

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RESPONSE TO NRC INSPECTION REPORT NO.-50-341/84-16 Detroit Edison does not regard this to be a. deviation, but to: assure that the diesel fuel will not gel in cold weather, a fuel blend of 50% #1 diesel fuel and 50% #2 diesel fuel is

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used.

This is in accordance with the manufacturer's recom-mendations for cold weather operation.- Fermi 2 has proce-

. dures in' place to test the fuel at'6-month intervals for-acceptable cloud point and pour point.

These tests are done in~ addition to the Technical Specification required testing for water and sediment content and kinematic _ viscosity of the fuel.

We believe these tests. meet the intent of the code to ensure operation of the pump in cold weather.

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