ML20108D268

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Amends 850218 Response to Violations Noted in Insp Rept 50-341/84-68.Corrective Actions:Startup Instructions Revised,Drawings Corrected & Incorrect Labels on Instrument Lines Removed
ML20108D268
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 02/22/1985
From: Jens W
DETROIT EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
EF2-70400, NUDOCS 8503080308
Download: ML20108D268 (23)


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  • Cayne H. Jens Vico President Nuclear Operations Fermi-2 6400 North Dune Hghway ISOD (Newport, 3:3)Michgan uS4tw 48166 February 22, 1985 EF2-70400 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) Letter, W. H. Jens to J. G. Keppler, February 16, 1985, EF2-70390 (3) Letter, W. H. Jens to J. G. Keppler, February 18, 1985, EF2-70386

Subject:

Detroit Edison Amended Response Inspection Report 50-341/84-68 This letter amends Detroit Edison's response to Unresolved Items 50-341/84-68-02, 84-68-17 and 84-68-19. The changes to the original response, Reference 3, are identified by a revision bar in the right hand margin.

We trust this letter satisfactorily responds to the item of noncompliance and the unresolved issues cited in the inspection report. If you have questions regarding this matter, please contact Mr. Lewis Bregni, (313) 586-5083.

Sincerely,

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'/ fl cc: P. M. Byron R. C. Knop C. C. Williams USNRC Document Control Desk Washington, DC 20555 9503090308 850222 DR ADOCKObOOg1 pg j $85'

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THE DETROIT EDISON COMPANY FERMI 2 NUCLEAR ~ OPERATIONS ORGANIZATION

- RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 DOCKET NO. 50-341 LICENSE NO. CPPR-87 INSPECTION AT: FERMI 2, NEWPORT, MICHIGAN INSPECTION ~ CONDUCTED: DECEMBER 19-20, 1984 JANUARY 3-5, 1985 JANUARY'10-12, 1985 c.

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RESPONSE TO NRC : INSPECTION REPORT NO. 50-341/84-68 c

Statement of Noncompliance 84-68-20

-10'CFR-50, Appendix B, Criterion VI, as implemented by DECO

-Quality _= Assurance Manual, QAPPR 6, Revision 1 requires that measures be taken 'to assure that documents such as 1 instructions , procedures, and drawings,- including ' changes lthereto, are reviewed = for adequacy. . .and ' are distributed to and rused at the ' location: Where the prescribed activity is performed.-

Contrary to_the above, the licensee failed to assure that changes and revisions.to drawings were adequately distributed, reviewed, and ' controlled when used in checkout

' and initial ~ operation -(C&IO) testing of safety-related systems.

' The following discrepancies were identified:

9*' . a.- _There was a lack of consistent procedural requirements.

(C&IO)'Sta'rtup Instructions Procedure (SIP) 7.7.2.01

Revision-6 requires that superseded revisions of '

drawings be filed ;in the Startup . Resource' Center, While procedure SIP 4.7.4.02 requires that [ unmarked]

superseded revisions be ' thrown away.

b. . ' Revisions D, E, F, G, H, I and J of drawing

.6I721-2201-2 did not icontain the proper . stamping

-- signatures'and dates, contrary:to procedure SIP

  • '7.7.2.01.
c.  : Revision.D.of. drawing 6I721-2201-2 was not-stamped

" superseded" or " testing void" as required by procedure p

> - SIP 7.7.2.01' when portions of the schematic had been.

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changed or when subsequent revisions-required new testing.

' 'd. Revisions E'and I of drawing 6I721-2201-2 were found

missing _ from the files, = contrary to procedure SIP 7.7.2.01.-

h r y.

f. -- e. Sections of schematic 6I721-2201-2 were observed to be yellownlined indicating ~ that these sections ~were tested, 'alth'ough there was no evidence that tests had

'been' performed.-

f.- ' There was no one consistent method applied among the startup engineers'toldocument the status of performance of C&IOctesting. required by procedure SIP 7.7.2.01.

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4 REF.PONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 Corrective Action Taken and Results Achieved

- The L following corrective actions are arranged to correspond

. to the sequence of items in the statement' of noncompliance:

a. Startup Instructions (SI) 7.7.2.01, " Electrical Checkout Instructions" and SI 4.7.4.02, " Control and Handling of. Electrical System Drawings," have been revised.- Superceded drawings are being stamped or marked " Superceded" and - are filed in the Startup

,' Resource Center.

b. 'Each-revision of drawing 6I721-2201-2 has been reviewed and updated in accordance with SI 7.7.2.01. In accor-dance with the SI, each revision of the drawing was reviewed by the Startup Test Engineer.(STE). Yellow-

.line! updating and necessary . retesting, with the

' appropriate marks, star ps and. signatures, were performed to the latest drawing revision.-

. c. -See' Item b above.

s - d. The intermediate revisions were missing from-the' file Las a. result-of the Document Control practice of removing and discarding' superceded' prints which did not have. yellow marking. The effect,of a missing

' intermediate. drawing revision is not significant since the latest- drawing revision reflects the LC&IO testing

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- status by yellow-lining the- tested portion of the drawing. Document Control personnel have'been~ directed not to discard any drawing from the " Yellow-Line-Master" drawing file .and the SI's have been revised-appropriately. Additionally, the need for timely review of. drawing ~ revisions in accordance with-SI' L7 7.2.01 has been emphasized during training sessions given to the STE's.

  • _ e. Drawing.6I721-2201-2 has been corrected and updated through Revision L to. reflect C&IO testing status in accordance with SI 7.7.2.01.
f. SI 7.7.2.01 has been revised to clarify the require-

< ments for yellow-lining the status of C&IO testing.

' Training has been 1 conducted to promulgate the requirements of the revised procedure.

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y RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 Corrective Action Taken to Avoid Further Noncompliance All electrical STE's were directed to ensure that drawing revisions are processed then received in accordance with Startup Instruction 7.7.2.01. For the case where multiple

-revisions are issued'over a short period of time or more than one revision exists in-the file for review, the Startup Instruction has been revised to clarify that the STE will

. perform his review for each revision, but the yellow-line

, updating and . retest will be performed to the latest drawing revision only. It was emphasized that this clarification

. does not preclude the need for timely response to drawing

. revisions _ by STE's.

To : remind personnel of the procedural requirements, the DocumentLControl Satellite Clerks have been instructed, via Startup letter.SU-85-0040 dated January 29, 1985, not to discard superceded-revisions of unmarked " Yellow-Lined Master" drawings.

The actions taken will ensure that " Yellow-Line Masters" are

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- maintained in accordance with SI 7.7.2.01.

The Date When' Full Compliance Will Be Achieved s - Full compliance has been achieved.

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RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 UNRESOLVED ITEM 84-68-01 The NRC inspector and the licensee's representatives performed a physical walkdown of the as-built field configuration of the main steam line high flow instrument sensing lines B21-LOO 3A and B21-LOO 4A, which provide isolation signals to the MSIV B21-F022A and B21-F028A. It

.was determined that the sensing line installation appeared to be adequate per the as-built isometric drawing; however, the inspector observed the following discrepancies :

(1) Main stem line D instrument tap condensing chambers fed by lines B21-LOO 3D and B21-LOO 4D, were observed to be separated by three (3) inches of free air from other sensing lines that were labeled as B31-LOOlA, Division I, and B31-LOO 2B, Division II.

(2) Instrument sensing lines labeled B31-LOOlA, Division I, B31-LOO 2A, Division I, B31-LOOlB, Division II, and B31-LOO 2B, Division II, were separated from one another by'six (6) inches of free air.

.(3) Instrument sensing lines labeled B31-LOOlA, Division I, B31-LOO 2A, Division I, B31-LOO 1B, Division II, B31-LOO 2B, Division II, and B21-LOl6, Division I, were all routed through one common penetration labeled Pen.

X-28D.

The NRC inspector queried the licensee as to what separation requirements apply to redundant instrument sensing lines at Fermi 2. The licensee responded that they will be inves-tigating the above discrepancies to determine if this is a separation violation or a mislabeling of the sensing lines.

Pending a review of~the licensee's investigation results, this item is considered unresolved (341/84-68-01).

RESPONSE TO UNRESOLVED ITEM 84-68-01 The basis for separation criteria is Specification 3071-536.

This. specification defines the design cequirements which account for the effects of pipe ruptures inside the primary containment. A walkdown and evaluation was conducted to verify compliance with this criteria. No discrepancies were identified. Detroit Edison's. report of 10 CFR 10.55 (e)

Item 115, August 20, 1984, EF2-69694 informed the NRC of the results.of this evaluation.

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RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68

-RESPONSE TO UNRESOLVED ITEM 84-68-01 (Continued)

. Detroit Edison's investigation of unresolved item 84-68-01 revealed that there was no violation of separation criteria.

Each of'these. instrument lines belongs to Division I. The appearance of separation criteria violations was created by

--labeling errors. The incorrect. labeling-was documented on a Deviation / Event Report. To correct this discrepancy, the identification ofLthe instrument lines has been verified and the incorrect labels will'be removed. The policy for labeling instrument lines in the drywell -is. being reviewed.

RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 UNRESOLVED ITEM 84-68-02 The inspector reviewed P&ID 6M721-2089, Revision K, and other electrical drawings (discussed below) and observed the following discrepancies:

(1) Fermi.2 FSAR Figures 7.3-10 sheets 1, 2, and 3 do not appear to reflect the implementation of FMR S-1109 dated March 15, 1979.

(2) It appears that the correct reactor low water level interlocks are not used in the MSIV isolation logic (Ref. drawings 6I721-2095-14 & 15, Revision C).

(3) _ Color code discrepancies exist between the drawings listed in the brackets. (6I721-21-16

[ sic-6I721-2155-16] and 17, Revision C, and 6I721-2282-55, 60, 65, and 70, Revision F. ) (Ref.

DCP-B2100-IO5 and IO6, IDCN-442, IRMR-1087 and DCN-5990.) It appears that some of the referenced design change documents were not properly and com-pletely implemented.

RESPONSE TO UNRESOLVED ITEM 84-68-02 (1) Detroit Edison made an effort to keep the FSAR updated during the construction phase. FSAR Figure 7.3-10, sheets 1, 2, and 3, " Nuclear Boiler System FCD" are covered under Interfacing Procedure 11.000.121, "FSAR and ER Amendments." This procedure provides for annual updates of the FSAR beginning two years after the operating license is issued. Typically, however, there is a significant delay in the incorporation of changes

-into FSAR drawings issued and -maintained by General Electric'if the' change is not initiated by GE. This is the case with FMR S-1109. To alleviate this problem, Detroit Edison will'obtain'the mylars for these drawings and will maintain.these drawings internally.

The revised drawings will~be annotated to show that the GE issued drawings are being maintained by Detroit Edison. FSAR Figure 7.3-10 is being revised by FCN-84-579 which is scheduled to be incorporated by July, 1986.

RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 RESPONSE TO UNRESOLVED ITEM 84-68-02 (Continued)

(2) The reactor low-water level interlocks shown on Revision ~F of drawings 6I721-2095-14 & 15 are correct.

As noted in the inspector's review, ' drawing 6I721-2095-14, Revision C, does not identify the source of-the required Level 1 trip for the Main Steam Isolation Valves. However, Revision F, which was in effect at the time of the inspection, shows that C71AK260A (B, C & D) provides the required Level 1 trip. The input to C71 AK260A (B, C & D) comes from the wide range level transmitter, B21-N081A (B, C& D) through meter trip unit B21-N681A (B, C & D). The actual -input is taken from a slave trip unit B21-N684A (B, C & D).- This slave unit is set.to trip at Level 1.

(3) The inspectors observations concerning color code discrepancies are correct. These particular color code discrepancies exist because an acceptable alternate cable type was used due to material availability when the cables were installed. In this case, Cable Code No. 119 was substituted for No. 111. DCN-5990, which documented the change, corrected the cable color on the pull card and wiring diagrams 6I721-2282-55, 60 and 70, but failed to change the color on schematics 61721-2155-16 and 17. This error was corrected on Revision D of the schematics-except for 2 cables which were again overlooked.

Cable color does not affect the function of the circuit. In accordance with the electrical and I&C as-built program, a Deviation / Event Report (DER) was used to document this discrepancy. This DER.will be posted against the drawing to prevent confusion until the drawing is updated.

' RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 UNRESOLVED ITEM 84-68-03

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I As-built wiring drawing 6SD7212501-40, Revision E. , was

= reviewed for general arrangement of devices, identification

' of devices and external cables.

Device' locations' wore found - to be in accordance with the s .above-as-built drawing.. External' cables 200022 A and B were reviewed, in ~ the. rear compartment of position E8 and found

. identified : and located per above as-built drawing.

During' this review it was observed that the following devices andftermination blocks, identified on the above as-built-drawing,=had either temporary or missing "

identification tags in the field: PK, PL, PM, PG, LA,.LB, LC, LD, AA, AN, RA and'RZ. The licensee reported there was no current program in place to identify such devices inside.

cabinets.- 'Pending further ' review, - this is an unresolved 1

item-(341/84-68-03A).

During inspection of the 4KV switchgear core spray pump

cubicle, the inspector observed that numerous terminal

- blocks had .not "been labeled in accordance with the connec-

. tion diagrams. Labels were observed to be missing from most l

of the terminal. blocks'in the 4KV Bus No. 65E position E10 cubicle.'

. .The' inspector observed missing identification tags inside the cubicle for the following components LA, LB,.LD, LC, AF,.

AE and AZ. The licensee does not have a current program in

- place' to identify missing identification tags inside a

!L cubicle. .'This' matter will be reviewed in a subsequent inspection'and is. considered unresolved ~(84-68-03B).

RESPONSE'TO UNRESOLVED ITEM 84-68-03 For' electrical equipment, Detroit Edison's policy is to -

(; provide adequate and accurate ' identification labels on L -components which are operated by operations personnel.

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Identification. numbers are Lplaced cx1 internal components as

'an aid -to wire and tect the -unit and . they are applied as

. determined by the manufacturer and . testing personnel.

Therefore,,not all' positions, components, or' panels will be-tagged.to:the same. degree. J Other than . fusing type and size which is being . covered under an ongoing . program, Detroit-Edison. engineering'does-~not. require internal component identification' tagging.

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RESPONSE TO NRC INSPECTION REPORT NO.- 50-341/84-68 RESPONSE TO UNRESOLVED ITEM- 84-68-03 (Continued)

If Detroit Edison determines that an internal component must be operated by an-operator, permanent tags will be installed to facilitate. operation and prevent operator error. In Unresolved-Item 84-68-03, the components identified as not having identification tags are either automatic control

-devices or passive circuit components Which do not require operator action.

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, TRESPONSE TO NRC-INSPECTION REPORT NO. 50-341/84-68 UNRESOLVED ITEM 84-68-08

-Electrical road maps [ Lead Des.gn Document Index - LDDI] for

,- ~480V and 4160V;tvitchgear were reviewed for adequacy and clarity ofainformation. The following discrepancies were

- observ d.

_ _ _ (1) Attachment-3, page_3 of 47, refers;to wiring diagrams as having -modifications which deviate from standard internal connections. There was no clarification.as to

-what these deviations entail.

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,(2) Attahcment 3,_ page 13 of _47, refers to wiring diagrams as not f alwaysf showing exact locations of devices. It could not be determined how:many drawings and how much variation ofa-location was being indicated.-

. ( 3 ), Attachment 3, - page 14. of ,47, indicates.that schematics-

,show relay and limit switch l contact developments, "as applicable." It could not be determined what devices and developments were not applicable.

~ ( 4)' Attachment 3, page 13 of 47, references wiring diagrams

, not : to 'beilead documents for identifying spare cable conductors. There was i no reference to - the correct lead

. documents for identifying 1 spares.

( 5)' ' Attachment 3, page 13_of 47, regarding the use of wiring-diagrams _ states, "May not_' reflect'as-built wiring' configuration of1 actual equipmente but is functionally correct in accordance with lead document,

. . schematic." This disposition was not considered acceptable because it is contrary to as-built

-requirements:as itlcould inadvertently cause errors during-maintenance.

The items above,are considered unresolved (341/84-68-08).

=-RESPONSE-TO UNRESOLVED ITEM 84-68-08 The~ elect'rical and IEC1 road maps ~have been. revised twice

-since 1the subject NRC~ inspection. .The; revisions have'incor-

_ porated a numberJof' changes based on comments from the NRC; recommendations from Nuclear-Quality Assurance based upon their verification'of.the utility'of.the Lead. Design Docun.ent Index (road, maps) and - comments from.the users. The current revision of'the: Lead Design' Document Index (LDDI)'is substantially more functional.

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- RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 RESPONSE TO' UNRESOLVED ITEM'84-68-08 (Continued)

.The specific discrepancies documented by the NRC in the inspection report are-addressed below: t (1) . The. modifications referred to are those due to the craftsman. option,'i.e., the connections are electri-cally equivalent and consistent with the. schematic, bu.

may not accurately-reflect-the point-to-point wiring.

Such deviations- were ' identified during the walkdowns .

'the' electrical and IEC equipment and evaluated. -Their resolution.will occur When the drawings are updated under the electrical. and IEC as-built program.

(2)L Detailed dimensions for locations of devices found on the wiring diagrams can be obtained . from the vendor drawings. For future design changes Which affect the location of.such devices, location details will be

^ included on the drawings in.the Engineering Design Package. .The LDDI has been-revised to delete the.

statement abo'ut device location information on wiring diagrams.

(3) The "as~applicabis" statement refers to the devices illustrated on the individual schematic.

-(4) ' Revision 2 of the LDDI refers to the cable pull cards to. identify sipere conductors.- If the cable pull card 3 indicates that' the- cable has 16 or more conductors, then the wiring diagram is the lead document for 1 spare

' conductors.

-(5) The statement-by the NRC is acknowledged. Wiring.

interconnection and termination-deviations were identified during the walkdowns of : the electrical and' I&C equipment and evaluated. Their resolution will occur When the drawings are updated under the electrical and I&C as-built: program.

RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68

-UNRESOLVED ITEM 84-68-09 Connect' ion' points on drawings 6SA721-250 52

~[ sic-6SD721-2501-52] show that or terminai block 1B, two

. conductors-terminate on points 5 and 6. According to the drawing, a number eight1 conductor is! terminated on point 6-and a~ number twelve is terminated on point 5. The inspector observed that the above connections were reversed in the

. field. The drawing-designated these conductors as being connected .to the main current transformer on the _ incoming

power _ leads. The connection of the No. 2 conductor should

'be-to the ground ofLthe current transformer, but according to the as-built connection, the No. 12 conductor was connected on the positive side of the current. transformer.

JBoth' Division II core spray pumps (B&D) have this discrepancy. This matter is considered unresolved.pending

'further review ton determine whether the drawing is incorrect or .whether the : field installation is incorrect.

'(341/84-68-09).-

iRESPONSE TOtDNRESOLVED ITEM 84-68-09 This discrepancy between the drawing and 'the installed

. wiring has'been documented and evaluated under Detroit Edison's' electrical an'd I&C as-built pro' gram. The

. evaluation indicated that' the ' installed wiring is '

functionally equivalent to the wiring shown on drawing

-6SD721-2501-52; although, the routing of wire between termination- points in the field does net match exactly the wiring shown on the drawing. Since functionally equivalent wiring has no effect-on the operation'of the equipment, the discrepancy was not detected when the system was tested.

This discrepancy 1was documented on: Deviation / Event Report

_(DER) No.85-109 and'the drawing'will be updated prior,to exceeding 5%fpower. To prevent confusion to operations _and maintenance personnel;using this drawing, the DER which documents ' this discrepancy will be posted against the drawing until the-drawing is updated.

, -Detroit-Edison has recently completed extensive walkdowns of

' electrical,and I&C, equipment in order to identify and resolve _ differences between the as-built plant and design drawings. This program has ,provided assurance that ,

~ deviations'are documented and corrected. Refer to Detroit Edison's final report on 10CFR50.55(e) Item 143, Reference

2, for-additional information.

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RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 UNRESOLVED ITEM 84-68-10 The inspector observed that inside the core spray pump D

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cubicle, the positive and negative conductor terminations were reversed. Shen connected to current transducers identi-fled as XCCC-5. Drawing 6SD721-2501-52 shows the black

[ sic-white] conductor connected to the negative terminal and the white [ sic-black] conductor connected to the positive terminal of the current transducer. The field installation was observed - to be the reverse of the above connection.

Additionally, the schematic diagram also indicates that the positive and negative connections do not agree with the field installation. The licensee stated that the termi-nation of the other end is to an AC ammeter and was of no consequence. However, schematic diagram 6SD721-2211-4 shows the connection to a DC ammeter. It apoears that testing or start up personnel switched the wiring without initiating the proper design change paper to revise the schematic and wiring diagrams. This matter is considered unresolved.

(341/84-68-10).

RESPONSE TO UNRESOLVED ITEM 84-68-10 As discussed above, a DC ammeter was installed using black cable for the negative lead and white . cable for the positive lead. Detroit Edicon's standard practice and the design

. drawing call for black leads to be positive and white leads to be negative. Cable color has no effect on the function of the circuit. This discrepancy has been documented and

.the cables will be corrected to maintain the site standard.

As. previously discussed in this report, Detroit Edison has recently completed an extensive program to identify, correct and prevent .the recurrence of similar discrepancies between the drawings and the as-built plant. Details of this program are being supplied to the NRC in Detroit Edison's final report of 10 CFR 50.55(e) Item 143.

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i RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 N.

UNRESOLVED ITEM 84-68-11 "}

4 During observation of the terminations inside panel H11-623, g(

the inspector noted an extra connection on points 9 and 10 g on a relay identified in the panel as AX-K120. Drawing No. yr 6I721-2045-60, Revision H, Which shows the control develop-ment of this relay, indicated that this was incorrect. -

These points were later verified to be normally closed $

contacts that were not identified during testing by startup G personnel. These normally closed contacts are in series with control room indication and could if undetected provide g -

false indication to control room operators. This issue is considered unresolved pending further review of this matter {

(341/84-68-11). c j

3 RESPONSE TO UNRESOLVED ITEM 84-68-11 i

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The Core Spray Pumps are operated from the control room by __

back lighted switches which flash if the pump switch is in #

the OFF position. In the auto mode, the Core Spray Pumps will start automatically When reactor water level is low or

)T drywell pressure is high. During normal plant operation, y the flasher warns the operator that the Core Spray Pump is i not prepared to start automatically.

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As installed, the flasher would operate correctly during ,

normal operation and would warn the operator that the pump e was not prepared to respond to an emergency. However, after jl an automatic start signal is received and the Core Spray '

Pump has responded, if the Core Spray Pump is manually j stopped, the flasher will not operate. This discrepancy g existed on all 4 Core Spray Pumps. ]

Detroit Edison's investigation revealed that this f -

discrepancy resulted from insufficient control of consecutive design changes to the same circuit. FMF-1030 E Revision B (implemented GE FDDR-KHI-567 Revision 0) was  :

issued on May 27, 1979. This FMR added the contacts Which 1 are described by the Inspector. FMR-1396 (implemented GE j FDDR-KHI-620) was issued on January 1, 1980. This FMR 1 removed these contacts. However, FMR-1030 was revised and  ;

re-issued as Revision C on April 29, 1980. Therefore, the j contacts, Which were required by FDDR-KHI-567 and later Z removed by FDDR-KHI-620, were re-installed. FDDR-KHI-620, -

which superceded FDDR-567, did not reference the document it j superceded. =

Detroit Edison has initiated action to implement 9 FDDR-KHI-620 for all 4 Core Spray Pumps. I a

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RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 UNRESOLVED ITEM 84-68-12 The following are examples where the equipment connections were installed such that the electrical components will function as designed but are not in accordance with the connection and/or schematic diagrams. The licensee has indicated that they will identify and document the deficiencies and revise the connection diagrams to reflect as-built installation. These matters will be followed-up in subsequent inspections.

(a) Limit switch compartment of core spray minimum flow bypass valve "B" was checked against drawing numbers 61721-2211-9, Revision G. According to the drawing, the connection from terminal point 36 is green block

[ sic] conductor, the field installation was observed to be red. The schematic diagram also shows this connection to be incorrect. The inspector observed that this field connection is properly terminated at motor control center cubicle E2150F031B. The above discrepancies were noted as deficiencies and documented by the licensee.

(b) During review of the connections inside a motor control center cubicle it was observed that the field termina-tions were CR to R to F relays instead of CR to F to R relays as shown on drawing SSA721-2521-9

[ sic-5SD721-2521-9], Revision B. Additionally, conductors identified as No. 10 and No. 12 to contactors F and R respectively, were not in accordance with this same drawing; also in this cubicle, the drawing indicated a ground at the 120V/24V transformer low side connection, while the connection was to the 480V/120V transformer low side connection.

The issues (5) (a), and (5) (b) above are considered unresolved (341/84-68-12).

RESPONSE TO UNRESOLVED ITEM 84-68-12 Item (a) addresses a wiring drawing and schematic that show a conductor as Green-Black when the installed conductor is Red. The Green-Black conductor gas replaced with the spare Red conductor from the same cable by DCR E-3993. The DCR revised the pull card and cable routing report but did not change the schematic. The schematic has been revised to show the correct color of the conductor.

RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68

-Itera (b) addresses two items where the installed wiring was functionally equivalent to the design drawing; although, the point-to-point' wiring did not match the drawing exactly.

This discrepancy will be resolved in accordance with Detroit Edison's as-built program as - described in this response under Unresolved Item 84-68-09. In this case, the drawing will'be updated.

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, a.t 4 r RESPONSE.TO NRC INSPECTION REPORT NO. 50-341/84-68

, UNRESOLVED ITEM 84-68-14

The inspector reviewed the as-built inspection program performed 1by the licensee utilizing the licensee's LDDI.

The auxiliary relay room high pressure coolant injection-relay cabinet Hil-P620 was visually inspected by the NRC inspector to ascertain the effectiveness of the licensee's as-built verification program. The visual-inspection consisted of a comparison between the number of wires landed

at the panel terminal points and the number -of wires shown on the applicable design drawings. This effort included relay terminations, . plugs, etc...

The.following discrepancies were identified:

(1) Schematic Diagram 6I721-2225-1, Revision K dated

. September. 28, 1984, indicated the following:

(a) Contact 3-4 of relay K3 is being utilized to interlock valve E4150-F021. However,'this contact

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was found to be a spare in panel Hll-P640.

(b) Contact 3-4 of relay K4 is being utilized to interlock valve E4150-F021. However, this contact-was found to be a spare in panel Hll-P620.

(c). Contacts 1-7, 3-7, and 2-8 of relay K82 were being utilized to interlock relay K35. However, relay K82 was found to be a spare in panel Hil-P620.

(2) ~ Schematic Diagram 6I721-2225-1 [ sic-6I721-2221-12],

Revision C-[ sic-F] dated October.4, 1984![ sic],

indicated that contacts 1-2 of relay K92 are being utilized. Inspection of the relay in panel ' Hil-P620 indicated

  • that' contact T1-Ml~ was being- utilized.

(3) Schematic Diagram 6I721-2225-5, LRevision I dated

. October 4, 1984, indicated that Fuse F22 was wired to TBDD point 13 and fuse F21 was wired to TBDD point' 14.

However, field'and applicable connection diagram 6I721-2045-54,. Revision L, indicated that F22 was wired to TBDD-14 and F21.was wired ~to TBDD-13. Items 8.a.(1)(2) and (3) are considered unresolved pending licensee action (341/84-68-14).

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RESPONSE.TO'NRC' INSPECTION REPORT NO. 50-341/84-68

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RESPONSE TO UNRESOLVED ITEM 84-68-14 Field'Modif.. cation Request (FMR) 4378 and Design Change (1)

Package (DCP) 3500IO2 modified the wiring to the

configuration that is currently installed and changed the design drawings. . However, the FMR and DCP failed to-include drawing 6I721-2225-1, "HPCI System Notes _ and

.-Relay- Tabulations," among the drawings to be revised to reflect this modification. Revision M of the relay-tabulation. drawing has been issued and properly-incorporat'es the FMR and DCP.

(2)- FMR 4378 replaced the GE HFA type relay designated K92 with an Agastat type GP relay. This -changed the relay contact numbering convention, but not the function of the relay-designated as K92. Contacts 1-2 on the old relay became contacts T1-M1 on the new relay. This change was'made on drawings 6I721-2225-1 and 6I721-2221-12 Where the contacts were still shown as

.1-2. The K92 relay development shown on 6I721-2221-12 has been . deleted on Revision G because the information is redundant to the information shown 6I721-2225-1 and 6I721-2225-6.

(3) This-discrepancy, a drafting error, reversed the leads-used to monitor the fuse condition for fuses F21 and -

F22. These fuses are in the same circuit. As wired, the fuse condition, which is not a safety-related function, was still being monitored. The schematic

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diagram, 6I721-2225-5, has been revised to Revision J which corrects the drawing to show fuse F21 -wired to TB-DD-13 and fuse'F22 wired to TB-DD-14.

This unresolved item involves 3 drawing errors. Two of the-errors 'resulted from the failure - to identify and correct all of the applicable information shown on the drawings When a

- design change was made. The third error was a drafting error.- To reduce these types of errors, an improved ' design verification program under Fermi 2 Engineering Procedure 4.3 has been instituted.. Additionally, Detroit _ Edison personnel

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- have ' conducted ' extensive walkdowns of Fermi 2 electrical and.

- I&C' equipment and performed' drawing-to-drawing checks'to identify and correctLexisting errors. A. detailed

~ description of'.this Fermi 2 as-built program is. contained in the final report of 10CFR50.55(e), Item 143, Reference 2.

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RESPONSE TO NRC INSPECTION REPORT NO. 50-341/84-68 s UNRESOLVED ~ ITEM 84-68-17

< CEIO test procedure TF.000.017.01, Revision 4, dated January 25, 1983, relating . to the tests and inspections performed to shielded cable 234427-26 [ sic-234437-2C]. indicated by the

> documented -signatures of the test engineer 'that the cable i

was checked . for' proper -termination (ref. 3.3), that the cable shield-is grounded where applicable (ref.-7.1), that

.the : cable _ was checked ' for proper phasing and continuity N " working drawings" are. yellow-lined (ref. 7.3). Contrary.to

- _the above, the shield of the above cable was :found tungrounded and improperly terminated ' during licensee's walk-X - down . ' This item is considered unresolved pending licensee 4 review and< action (341/84-68-17). ,

. ' RESPONSE'TO UNRESOLVED ITEM 84-68-17 .

.This item is a continuation of the previous item, Open Item 84-68-16,- which discusses a jumper between TBAA-80 and TBAA-84. 1This jumper.is shown on the wiring diagram, J 6I721-2045-54, Revision K, although the jumper is not installed in the field. The schematic shows the shield as

. grounded.: ~ TBAA-84 is a ground connection. The cable shield is terminated ' at TBAA-80. 'Without the jumper installed, the shield for cable 234427-2C was correctly terminated, as 3

. documented in C&IO. Test-TF.000.017.01, but the shield was "

' not . grounded aus was documented in DER-85-021 during the

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walkdown. -

The jumper was apparently removed without documentation N

during' testing to prevent-connecting terminal TBAA-80 to ground because TBAA-80.was also being used as part of=an energized circuit. This occurred because' two design . changes werefissued'against drawing 6I721-2045-54 which required using terminal TBAA-80. DCP E4100001'used TBAA-80 to terminate the' shield of cable 234427-2C and installed a jumper from TBAA-80 to ground (TBAA-84) . FMR 4198 used TBAA-80 to conn'ect~ the relays in Hil-P612 - and Hil-P614 tx)

-the coils which activate the "HPCI AUTO' ISOLATION SIGNAL B"

'in Hil-P620. This error was not identified when the design~

- changes were incorporated. As installed,'both circuits worked properly although the cable shield _was not grounded.

.Had thefjumpersbeen installed, it would have resulted in a single ground on a DC system but the HPCI Auto Isolation

' Signal- B would still have been functional.

Engineering Design Pack, age (EDP) 2135 has been issued to

= correct this discrepancy.  ;

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RESPONSE TO NPC INSPECTION REPORT NO. 50-341/84-68 UNRESOLVED ITEM 84-68-19 During the as-built review, the inspector examined FMR 7096, Revision O, A and B. This FMR addressed the requirements of GE FDDR KH1-1041, Revision O to provide bypass of limiting resistors EDl-R1 during manual mode of RCIC turbine and GE FDDR KH1-1086, Revision O, addressed the same in the HPCI turbine control. The inspector noticed that on sheet 4 of FMR 7096, Revision 0 and A, the circuit had been modified by the licensee's engineer and sent to the field for incorpora-tion without written documented approval from GE for this change. Revision B of the FMR again modified the GE circuitry in a different way than Revision A, but no written approval was available. It also contained GE FDDR KH1-1086, Revision O, without superseding it; therefore, having two open FDDRS addressing the same item.

Furthermore, review of incorporation of above FMR into the applicable design schematic diagram 6I721-2042-15, Revision F, indicated that the circuit shown on this drawing does not conform to FMR specifications and was modified during the incorporation into the drawing. Note that the drawing revision block reads: "Per FMR-7096, Revision B..." even though drawing did not reflect FMR-7096, Revision B as specified. ,

The above appears to be another example where an engineer or a draftsman modified a design drawing arbitrarily without following the specific requirements of the design change document.

This matter is considered unresolved (341/84-68-19).

RESPONSE TO UNRESOLVED ITEM 84-68-19 Detroit Edison was authorized verbally by the GE Project Manager to revise GE design prior to GE's approval, where necessary at design interfaces, on an "at risk" basis. The risk is not related to plant safety, but to additional cost

, for rework if GE disagreed with the design change. Changes to GE design by Detroit Edison were listed on the cover of the related FMRs and transmitted to GE for their review and concurrence or comment. GE, in turn, would revise their FDDR or FDI or send a letter sta. ting their concurrence or disagreement.

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RESPONSE TO NRC INSPECTION REPORT NO 50-341/84-68 Changes to FDDR KH1-1041, Revision O, were transmitted to GE on FMR 7096, Revision O, by letter EF2-69,460, dated June 21, 1984. FMR 7096, Revision 0, was approved by the responsible discipline engineer on June 19, 1984. GE subsequently issued FDDR KH1-1086, Revision 0, to address the design change. The latter FDDR was more conceptual in nature and lacked sufficient detail, by itself, to perform the necessary construction. FMR 7096, Revision B, expanded on the design of FDDR KH1-1086, Revision 0, to allow construction to proceed. Since FMR 7096, Revision B, did not change the GE conceptual design, Revision B was not transmitted to GE for review and concurrence.

The NRC inspector was correct relative to two (2) FDDRs being open and applicable to the same design item. GE superseded FDDR KH1-1041 Revision 0, by issuing FDDR KH1-1041, Revision 1, on December 28, 1984. The latter revision cancelled FDDR KH1-1041 and referred to FDDR KH1-1086 for the applicable design. Relative to construction activities, FMR 7096, Revision B, issued FDDR KH1-1086, Revision O. Per Detroit Edison procedures governing the FMR process, preceding revisions of a FMR are superseded by the latest FMR revision issued. FDDR KH1-1041, Revision 0, was for construction purposes superseded by FDDR KH1-1086, Revision 0, through FMR 7096, Revision B. Revision B of the FMR was issued on August 24, 1984.

Detroit Edison has investigated the Inspector's concern that a design document was changed arbitrarily. During incorporation of the FMR into drawing 6I721-2042-15, Revision F, the draftsman recognized that sheet 9 of the FMR contained an error. This observation was based on having reviewed previous sheets of the FMR, specifically sheets 2, 3 and 7. Realizing the arror, the draftsman incorporated the correct design into the drawing. It is recognized that such practice is not appropriate and should not take place.

Procedural changes have been implemented which address this concern. Additional controls (including the use of a checklist) are being implemented during verification of the drawing revision process. Additional related information is provided in the response to 10CFR50.55(e) Item No. 143.

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