ML20102C295

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Responds to Noncompliance Noted in Insp Rept 50-341/84-57. Corrective Actions:Program for Verification QA Level 1 Documents Implemented & Will Assure That Design Documents Adequate for Operation & Maint
ML20102C295
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 01/29/1985
From: Jens W
DETROIT EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
EF2-70231, NUDOCS 8503050462
Download: ML20102C295 (4)


Text

"-

Wayw H. Jens v e presoent c

Nuclear Operat,ons 400 North Dixie Hghway ISOn piases-4tso January 29, 1985 ne. port. u.cn.gan 4ates EF2-70231 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

Reference:

Fermi 2 NRC Docket No. 50-341

Subject:

Detroit Edison Response Inspection Report 50-341/84-57 The attached report responds to the item of noncompliance described in your Inspection Report No. 50-341/84-57.

This inspection was conducted by Messrs.

Z.

Falevits, K. Tani and A. Gautam of NRC Region III on November 7-9, 1984.

The item of noncompliance is discussed in this reply as required by Section 2.201 of the NRC's " Rules of Practice,"

Part 2, Title 10, Code of Fed,eral Regulations.

The appropriate criterion and the number identifying the item are referenced.

We trust this letter satisfactorily responds to the noncom-pliance cited in the inspection report.

If you have any questions regarding this matter, please contact Mr. Lewis Bregni, (313) 586-5083.

Sincerely, cc:

P. M. Byron R. C. Knop C. C. Williams U. S. NRC Document Control Desk Washington, D.C.

20555 8503050462 850129 TES E PDR ADOCK 05000341 G

PDR J$0/

e THE DETROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATIONS ORGANIZATION RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-57 DOCKET NO. 50-341 LICENSE NO. CPPR-87 INSPECTION AT:

FERMI 2, NEWPORT, MICHIGAN INSPECTION CONDUCTED:

NOVEMBER 7-9, 1984

RESPONSE TO NRC INSPECTION REPORT NO.

50-341/84-57 Statement of Noncompliance 84-57-01 10 CFR 50, Appendix B, Criterion III, as implemented by Detroit Edison Nuclear Quality Assurance Manual, Section 3.1.4, requires that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, proce-dures, and instructions.

These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that devia-tions from such standards are controlled.

Contrary to the above:

a.

The licensee failed to assure that deficiencies in the control logic schematic diagrams of the RHR system are properly identified, corrected and controlled.

The following discrepancies were identified.in the RHR Shutdown Cooling initiation and valve line up control logic, depicted on schematic diagram 6I721-2201-2 (sic)

[6I721-2205-2], Revision J.

(1)

Relay contact interlock transmitting reactor low pressure signal is designated as B21-K202A (M3-T3), indicating it as being part of Nuclear Steam Supply Shutoff System (B21).

However, review of the design logic indicated B31-K202A (M3-T3) to be the correct one.

(Reactor Recirculation System B31).

This was noted by the licensee.but the schematic diagram was not revised.

(2)

Reference drawing shown for the B21-K202A coil is specified as 6I721-2095-29.

However, review of drawing 6I721-2095-29 indicated that B21-K202A (M3-T3) is a spare contact.

(Ref. drawing should have been 6I721-2105-11.)

(3)

Description of Reactor Protection System (RPS) relay contact A71B-K17 (13-14) states " closes on reactor low level #3 or high drywell pressure (Ref. 9).

However, review of logic indicates that it should state " closes on reactor low level #3 and below."

RESPONSE TO NRC INSPECTION REPORT NO.

50-341/84-57

' Corrective Action Taken and Results Achieved As stated in items 1 and 2, drawing 6I721-2205-2 (identified as 6I721-2201-2 in the Inspection Report), Revision J, incorrectly identified contact B31-K202A as B21-K202A and identified the reference drawing.for this contact as 6I721-2095-29 instead of 6I721-2105-ll.

As identified in item 3, the note " closes on low level #3 or high drywell pressure" was not modified when the logic of the system was changed to delete the drywell pressure function of the contact.

These errors were known to the responsible engineer and were discovered by the NRC because they were marked on the copy of the drawing supplied to the NRC inspector for his review of the Residual Heat Removal initiation logic.

Indepen-dently, the contact numbering error was identified and corrected with a black pen on the copy of the drawing used by the test engineer as the yellow lined master for this system.

Although these errors were known to both design and test engineers, prompt action was not taken to correct these drafting errors.

The personnel involved did not believe these errors warranted immediate corrective action and intended to correct the drafting errors during the next revision.

Detroit Edison's~ investigation has determined that these drafting errors had no impact on installed hardware or system testing.

The drawing has been revised.

Detroit Edison personnel have been indoctrinated in the need for the prompt correction of drawing errors in accordance with existing procedures.

Corrective Action Taken to Avoid Further Noncompliance Detroit Edison has undertaken a program for the verification of QA Level I design documents.

This program, to be described in response to 10CFR50.55(e) Item 143, will assure that Fermi 2 design documents are adequate for' plant operation and maintenance.

Date'When Full Compliance Will Be Achieved Full compliance will-be achieved in accordance with the program in response to 10CFR50.55(e) Item 143.

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