ML20107K470

Final Deficiency Rept,Item 143 Re Deviations in Instrument Racks from Applicable Instrumentation & Controls Design Drawings.Initially Reported on 841219.Checklists Will Be Used During Verification of Drawing Rev Process

ML20107K470
Person / Time
Site:	Fermi
Issue date:	02/16/1985
From:	Jens W DETROIT EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
143, EF2-70390, NUDOCS 8502280292
Download: ML20107K470 (5)

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Vice Presedent

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Nuclear Opochons Form 6-2 cg 6400 North Duue Hghway

[33NY" February 16, 1985 EF2-70390

-Mr.' James G.'Keppler Re gional : Administrator Region 'III

-U.

S.: Nuclear Regulatory Commission 799 Roosevelt Road

-Glen Ellyn, Illiaois 60137

References:

(1)

Fermi 2 NRC Docket No. 50-341 (2)

Detroit Edison letter EF2-70237,

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same subject, dated January 18, 1985 Subjects' Final Report of 10CFR50.55(e)

Item No. 143 " Deviations of As-Built Plant from Design Documents" OncDecember 19,c1984, Detroit Edison's Mr. J.

E. Conen, Engineer - Licensing,. telephoned Mr.

P.

Pelke of NRC Region III, to. report a potential deficiency concerning deviations

-in instrument. racks from applicable instrumentation and controls - (I&C) design drawings.

Subsequently, this item-was determined to_be reportable under 10CFR50.55(e) and is identified as Item No.-143..

-Description of Deficiency

.Walkdown inspections have identified some deviations, Jprincipally'non-functional in nature, between,the design drawings and the electrical and I&C scope of the as-built plant.- The deviations represent a small percentage of the applicable' drawing' details.

Their importance is recognized and prompt corrective action is being taken.

Details of the deviations are documented and available for review at the

. Fermi 21 site.

Item No. 143 is. considered reportable under.

i, 10CFR50.55(e) due toia numberfof identified drawing

deviationsif hardware discrepancies and the extent of the evaluation. program required to ' analyze the individual deviations.

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Mr. James G. Keppler February 16, 1985 EF2-70390 Page 2 Analysis of Safety Implications Some of these deficiencies are considered to have potential safety implications, in that if left undetected, they could have resulted in the loss of or incorrect function of a safety-related component or system.

Corrective Action Corrective action is discussed below in two parts:

correc-tion of the deficiency and actions to prevent recurrence.

The following actions have been taken or are scheduled to correct the deficiency:

o Walkdown. inspections to verify design document conformance with the as-built plant were performed on

-Quality Assurance Level 1 (QA-1) electrical and I&C equipment.

The justification for the few items not included in the ~walkdown inspection is documented and a vailable for review at the Fermi 2 site.

o The initial walkdown-inspections addressed _ mechanical,

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electrical and I&C attributes for QA-1 instrument racks.

Additional walkdown inspections addressed wiring drawings for other I&C equipment and-electrical equipment.

The remote shutdown panels, safety and non-safety related, and balance-of-plant wiring contained in QA-1 equipment were also included in the walkdown inspections.

-o The deviations are documented and are being processed in accordance with Fermi 2 nonconformance reporting

' procedures.

The corrective action process includes evaluation for testing or retest requirements.

o Drawing deviations, as described in Nonconformance l

Reports (NCRs) and Deviation Event Reports (DERs), will be posted against the applicable-drawings before fuel load.'

The NCRs and DERs will be cleared as the drawings are updated, o

The evaluation results were categorized into three groups:

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Mr. James G. - Keppler February ~16,n1985 EF2-70390-1 Pa ge 3

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Component' Operability Category A -

A' deviation which, if left undetected, could result in the loss of or incorrect I

' function of a' safety-related component V'

or system.

' Operation / Maintenance

' Cate gory B --, -

A deviation which, olf.left uncorrected, E,

could ' result in_ impaired performance of the operations and raaintenance personnel.

Category C -

~ Other Minor hardware or drawing discrepancy.

These: evaluations are documented and available for review at-the Fermi 2 site.

o The deviations are to be corrected on the following schedule:

Category A~ - The, goal is fuel load, but no later.than-by Fermi-2 Technical Specification system

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operability requirements.

Category.B - Before exceeding.5% power.

Category C - Under.the Long-Te rm-Program,' the goal is for resolution by December 1986,.but not

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'later than the start-up following the

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first refueling outage.

Design document-reconciliation wil1~ be accomplished by

-revision' or the issuance of an. As-built Notice, and field work will be performed. to Nuclear Operations

procedures.

The walkdown -inspections, evaluations and the corrective actions per.the above schedule address and resolve the identified electricial and I&C deviations.

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Mr.; James G. Keppler February 16, 1985 EF2-70390 Page 4

.o Tolfurther reduce the potential for operator confusion

due to drawing deviations,- the accuracy of the drawings in the Control Room (less selected balance-of-plant

drawings) has been established and verified.

L Additionally, the. lead information on Tagging Center

.CA-1 drawings has been established and verified.

In conjunction with. the foregoing,- compatibility between component -labels and the Functional Operating Sketches will be accomplished by system before.the need for a system is required by the Fermi-2 Technical specifications.

o-The remaining balance-of-plant. drawings in the Control Room will be verified to be accurate before exceeding 5%

power, and the broader plant labeling' program, as defined in Plant Order EFP-1066, will be' completed under

-the Long-Term Program.

o To' assist the users of Fermi 2 design drawings, a Lead Design Document Index (LDDI) was established to identify the accurate information: on various types - of drawings..

o Under[the Long-Term Program, the.need for the LDDI in conjunction with Tagging Center drawings and the same drawings in other. locations,- e. g., the Production i

'Information. Center,'will be.elkninated.'

In addition, an.

evaluation 1willLbe performed :to -determine the need for a: drawing consolidation and update' program.

. Underlying;causes of Ehe ' deviations in the ' electrical and I&C

. drawings are: 11ack of. sufficient detail-in. engineering t

direction which allowed interpretation by. craft personnel

performing -the. work and - draftsmen incorporating. design changes, improper incorporation of design change documents and lack of as-built requirements in the electrical and I&C procurement. specifications.

- The.following actions have been taken or are scheduled to.

prevent recurrence:

o Checklists are used during the verification of the

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drawing revision process.

o-Design: changes are marked' on the base configuration document.

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Mr. James'G. Keppler-February 16,~1985 EF2-70390

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" Yellow-line" verification is performed by Nuclear:

. Quality' Assurance (NOA) on the design change documents

~ during the in-process ; field inspection.

Deviations from

'the " yellow-line". verification are identified and dispositioned before returning the equipment to service.

The as-built information is communicated back'to engineering.

o Design changes affecting QA-1 electrical and I&C internal wiring connections, issued after the walkdown of the affected equipment and before February 11, 1985-(start. of the revised verification process), will. be -

verified by NQA to assure the drawing reflects the plant configuration.

o Under the Long-Term Program, implementation of configuration management will be completed, and its effectiveness will be evaluated.

o A training program -has been established and implemented

~for those personnel involved with the corrective actions described above.

.This training' program and its

. implementation have been - documented and are available for review at the Fermi 2 site.

If_you have questions concerning this matter, please contact Mr. Lewis Bregni, (313) 586-5083.

Sincerely, l

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P. M.

Byron

R. C. Knop R. C.'DeYoung J.

M. Taylor-USNRC.-Document Control Desk Washington, D. C.

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