ML20101K574
| ML20101K574 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/16/1984 |
| From: | Jens W DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20101K566 | List: |
| References | |
| EF2-70040, NUDOCS 8412310399 | |
| Download: ML20101K574 (7) | |
Text
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Wayne H. Jens Vke Presdent Nuclear Operrone i
f Form &2 Edison =400 North Dme Highway 6
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November 16, 1984 EF2-70040 l
l Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 l
Daar Mr. Keppler
Reference:
Fermi 2 NRC Docket No. 50-341
Subject:
Detroit Edison Response Inspection Report 50-341/84-36 l
This letter responds to the items of noncompliance described I
in your Inspection Report No. 50-341/84-36.
This inspection l
was conducted by Messrs. S. G. DuPont, D. E. Hills, G. O'Dwyer and others of NRC Region III on August 20 through September 28, 1984.
The items of noncompliance are discussed in this reply as required by Section 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 itoms cited in the body of the inspection report.
The appropriate criterion and the number identifying the item are referenced.
We trust this letter satisfactorily responds to the non-compliances cited in the inspection report.
If you have questions regarding this matter, please contact Mr. Lewis i
Bregni, (313) 586-5083.
Sincoroly,
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cc P. M. Byron
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S. G. DuPont
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R. C. Knop i
USNRC, Document Control Desk Washington, DC 20555 5
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l THE DETROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATIONS ORGANIZATION RESPONSE TO NRC REPORT NO.
50-341/44-36 DOCKET NO. 50-341 LICENSE NO.
CPPR-87 INSPECTION AT:
FERMI 2, NEWPORT, MICHIGAN INSPECTION CONDUCTED:
AUGUST 20 - SEPTEMBER 28, 1984 l
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1 RESPONSE TO NRC INSPECTION REPORT NO.
50-341/84-36 Statement of Noncompliance 84-36-01, Criterion XVI 10 CFR 50, Appendix B, Criterion XVI as implemented by DECO Quality Assurance Manual,'Section 17.1.2 requires that condi-tions adverse to quality, such as failures, deficiencies and deviations are promptly identified and corrected.
Contrary to the above, during preoperational testing of Control Rod Drive Hydraulic Control Unit (HCU) 38-15, the HCU ball check valve failed to retain the required hydraulic pressure.
This condition was not identified, dispositioned or corrected prior to turnover and acceptance by Nuclear Production.
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Detroit Edison Response Detroit Edison does not agree that this item is a noncom-pliance.
The inability of Hydraulic Control Unit (HCU) 38-15 to maintain pressure above its alarm setpoint for 10 minutes without a Control Rod Drive (CRD) pump operating is not a condition adverse to quality.
The engineering evaluation of the requirements of Preoperational Test PRET Cll50.01 correctly interpreted and implemented Fermi 2 Technical Specifications regarding the operability of the control rod HCU accumulators.
Fermi 2 Surveillance requirements for HCU accumulator pressure drop tests are consistent with Boiling Water Reactor Standard Technical Specifications.
Neither require that the HCU accumulators hold pressure above the alarm setpoint for a specific length of time following CRD pump trip as a condition of OPERABILITY of the accumulator.
The Fermi 2 Technical Specification Bases for the accumulator pressure drop test specifically state that no action is required if accumulator pressure does not remain above the alarm setpoint for 10 minutes after loss of CRD pumps.
The requirements of Preoperational Test PRET C1150.001 are consistent with the final draft of Fermi 2 Technical Specification Survalliance Requirement 4.1.3.5b.
The PRET Cll50.001 test results package correctly identifies that the HCU 38-15 accumulator low pressure alarm was received less than 10 minutes after the CRD pumps were secured.
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f RESPONSE TO NRC-INSPECTION REPORT NO.
50-341/84-36
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-acceptance of the test results by the Test Review Committee was consistent with Surviellance Requirement.4.1.3.5b.
Detroit Edison has determined that no action was required as a result of HCU-38-15 failure to maintain hydraulic pressure above the alarm'setpoint for 10 minutes.
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RESPONSE TO NRC INSPECTION REPORT NO.
50-341/84-36 Statement of Noncompliance 84-36-02, Criterion v 10 CFR 50, Appendix B, Criterion V as implemented by DECO Quality Assurance Manual, Section 9.0.1 and American.
National Standard N18.7-1976, Section 5.2.2 requires-that activities affecting quality shall be accomplished in accord-ance with procedures.
-Contrary to thr. above, during preoperational testing certain activities were not accomplished in accordance with adminis-trative procedures.
This is evidenced by the following examples:
a.
Ten Test Exception Disposition Reports (TEDR) for preoperational test procedures PRET C1150.001 Control Rod Drive Hydraulic System, PRET C3202.001 Feedwater Control System, PRET C1100.001 Control Rod Drive Manual Control System, and PRET E2100.001 Core Spray System were not correctly initiated or dispositioned, did not properly indicate retesting, or did not provide adequate justification of dispositions.
b.
The testing method described in preoperational test PRET E2100.001 Core Spray System was changed without an i
approved Test Change Notice (TCN).
Corrective Action Taken and Results Achieved 2ach of the administrative errors identified by the NRC inspector was evaluated and none were determined to have adversely affected the results of the tests.
Corrective action was taken to provide documentation of retesting related to preoperational test Cll50.001.
In addition, training was provided to ensure that administrative requirements are initiated when required and that they are properly executed.
As recognized in NRC Inspection Report 50-341/84-29, Detroit Edison implemented actions to improve the administrative control and technical' quality of the preoperational test program in August of 1984.
A description of this improvement program is contained in Detroit Edison's response to 50-341/84-11-01, letter EF2-69661, W. H.
Jens to J. G. Keppler, dated July 24, 1984 and Detroit Edison internal correspondence SU 84-1312.
P RESPONSE TO NRC INSPECTION REPORT NO.
50-341/84-36 As stated in NRC Inspection Report 50-341/84-36, the test results packages reviewed by the inspector were tests that had been performed prior to. implementation of the improvement program.
The NRC inspector acknowledged that the new program should address the concerns he identifies in his report.
Corrective Action Taken to Avoid Further Noncompliance The cornerstone of the efforts to improve the Preoperational Test Program is the' establishment of test specific technical review subcommittees.
These subcommittees are comprised of representatives from each organization involved with the testing of a system program.
The subcommittees perform detailed reviews of the administrative and technical aspects of the test. package and results.
Upon completion of an in-depth review, the subcommittee presents its findings and recommendations to the Technical Review Committee.(TRC) during a scheduled Test Results review meeting.
As a result of the observations of the TRC subcommittees-and Nuclear Quality Assurance Surveillance Findings, Detroit Edison halted startup testing with the exception of generic Checkout and Initial Operation Testing (CAIO) on October 29, 1984.
Training was performed in the administrative requirements where weaknesses had been identified including the use of TEDR's and TCN's.
This formal training was conducted for Startup and other selected personnel on October 30, 1984 and included the following Startup Instructions:
S.I.
4.5.1.01,
" Administrative Controls of Startup Originated Procedures and Test Change Notices" (Test Change Notice Section)
S.I.
8.4.2.03,
" Supplemental Testing" S.I.
8.4.2.04,
" Resolution of Test Exceptions" The additional level of review for test result packages and the additional training conducted on the administrative controls ensure the accuracy and adequacy of preoperational l
testing.
Testing was resumed after the completion of this training.
Date When Full Compliance Will Be Achieved Full compliance has been achieved. <
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RESPONSE TO NRC' INSPECTION REPORT NO.
50-341/84,
l Statement of Noncompliance 84-36-08, Criterion V 10 CFR 50, Appendix B, Criterion V and Regulatory Guide 1.108 as committed to by DECO Final Safety Analysis Report,
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Appendix A and implemented by DECO. Quality Assurance Manual, Section 9.0.1 requires that logs shall include appropriate quantitative or qualitative acceptance data that an
-independent determination can be made of validity of tests.
Contrary to the above, the Emergency Diesel Generator start-failure logs did not obtain quantitative or qualitative data to independently determine the acceptance of valid tests or
' test failures.
Corrective Action Taken and Results Achieved Detroit Edison conducted a comprehensive review of available plant documentation which could be used to supplement the information in the Emergency Diesel Generator (EDG) Start /
Failure Logs.
EDG starts and failures which followed the EDG reliability runs (23 consecutive starts) were reconstructed using the Shift Supervisor Logs, Supervising Operation Logs, Preoperational Tests PRET. R3000.001 and PRET. R3000.003, EDG Sequence of Events (SOE R3000-1 through 46), EDG Run Logs and the individual EDG Startup Logs.
A start history was developed from these sources to serve as a baseline for EDG operation in accordance with the require-ments of Regulatory Guide 1.108.
An EDG start / failure log has been established and is being maintained.
Corrective Action Taken to Avoid Further Noncompliance Procedure 12.000.82, " Emergency Diesel Generator Start /
Failure Log Preparation and Evaluation" has been approved by the On-Site Review Organization.
This procedure defines how the requirements of Regulatory Guide 1.108 will be achieved and describes how this information will be evaluated by;the 1
Technical Section of Nuclear Production.
Date When Full Compliance Will Be Achieved
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Full compliance has been achieved.
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