ML20112E281
| ML20112E281 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/28/1984 |
| From: | Jens W DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| EF2-70226, NUDOCS 8503260479 | |
| Download: ML20112E281 (20) | |
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Wayne H. Jens i
Vice President Nuclear Operations f
Fermh2 6400 North Dxie Highway
' Newport, Mchigan 48166 (3'M 586 6 -
December 28, 1984 EF2-70226 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 September 20,1984, EF2-72247
Subject:
Detroit Edison Response NRC Meeting Report 50-341/84-56 i
NRC Meeting Report 50-341/84-56 provided comments about Detroit Edison's response (Reference 2) to the recommend-ations made by the Duke Power Construction Assessment Team l
(CAT).
Comments 1, 3, 6,
10, 13, 15, 16, 18, 20 and 21 were identified as requiring a written response.
The attached report provides the specific'information requested by each comment and is intended to supplement Detroit Edison's original response to the CAT recommendations.
No response is provided for comment 7 since the body of the inspection report states ~that no subsequent response is required.
F If you have questions concerning this matter, please contact Mr. Lewis Bregni at-(313) 586-5083.
t-Sincerely, cc P. M. Byron R. C. Knop C. E. Norelius USNRC, Document Control Desk Washington, DC 20555 8503260479 841228 Fd / 1 PDR ADOCK 05000341 G
PDRx 1
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-THE DETROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATIONS ORGANIZATION RESPONSE TO NRC REPORT NO.
50-341/84-56 DOCKET NO. 50-341 LICENSE NO.
CPPR-87 INSPECTION AT:
FERMI 2, NEWPORT, MICHIGAN
. MEETING CONDUCTED:
OCTOBER 31, 1984 z
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Response 1to NRC Meeting Report 50-341/84-56
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INTRODUCTION
.This report responds to NRC comments on Detroit Edison's response to
~
recommendations which resulted from the Duke Power Report on the
" Fermi 2~ Final Assessment of Construction" dated July, 1984 (Duke Power Report).
NRC comments on the " Fermi 2 Response to Recommend-ations from the Duke Power Company Final Assessment of Construction" dated September, 1984 (Fermi 2 Response) were received verbally in_a
- meeting at the Fermi 2. site on' October 31, 1984.
The NRC comments
- and Detroit Edison's reply to each comment are documented in NRC
~ Inspection Report' 50-341/84-56.
NRC. Comments 1, 3, 6, 10, 13, 15, 16, ~18, 20 and :21 required a supplemental response.
This report is intended _to satisfy that request.
The following documents are referenced in this report:
1
' Duke Power Company:
Management and Technical Services, Fermi 2 Final Assessment of Construction, July 1984.
2.
Detroit Edison, Fermi 2 Response to Recommendations From The Duke Power Company Final Assessment of Construction, September 1984.
3 U. S.-Nuclear Regulatory Commission Region III, Meeting Report No. 50-341/84-56 (DPR), November 14, 1984 (Note:- Meeting was conducted October 31, 1984).
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Response'to NRC-Meeting Report 50-341/84-56 X
Comment No. 1:
The following excerpt from NRC Inspection Report 50-341/84-56 identi-
- fies an.NRC Comment about the Fermi 2 Response (Ref. 2) and docu-ments the discussion between Detroit Edison and the NRC on
-October 31, 1984:-
As a general comment, the report did~not discuss a schedule.for completion of DECO actions,~especially with respect to items
. termed "long range plans."
The Region is concerned that some items will not be completed:in time to meet critical milestones such as fuel load.
Licensee Response.(During October 31,~1984 Meeting)
All items will be completed prior to fuel (SIC) load with the exception of Recommendation 17 regarding updating of drawings and Recommendation 24 regarding identification of electrical equipment.
. ith regard to recommendation 17 the licensee intends to update W
all drawings required for' operations (= 2000 drawings) by December 1,.19 84..
Other drawings will.be updated at a later date.
The governing document for the updating will be provided to the Resident Inspector.
With regard to recommendation 24 the action will be accomplish-ed in accordance with EFP-1066.
A copy of this document will be provided to the NRC.
NRC Comments The licensee should supplement their response reaffirming their commitment to complete all actions relative to all recommen-dations prior to fuel (SIC) load with the exception of 17 and 24.
c With regard to recommendations 17,and 24 the licensee should
- provide-~a summary statement with regard to what actions will be taken as well as when the actions will be completed.
Supplement to the Fermi 2 Response (Comment 1):
Detroit Edison defined the actions to be taken in response to the Duke Report (Ref. 1) recommendations in " Fermi 2 Response to Recommendations.from the Duke Power Company Final Assessment of Construction" dated September 1984 (Ref. 2).
As stated previously, Detroit Edison plans to complete actions associated with the Duke Report recommendations prior to fuel load with the exception of cer-tain portions of our response to Recommendation Nos. 17 and 24.
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i Response to NRC Meeting Report 50-341/84 Supplement to the Fermi 2 Response-(Comment 1) (Cont'd)
Duke Report. Recommendation No.17 addressed drawing discrepancies.
Edison is performing an evaluation 'of ' Fermi 2 ! drawings to define the scope of.this problem and to formulate the appropriate corrective
-actions.. The. extent of the evaluation and the anticipated response-is significantly more comprehensive than that recommended in the Duke Report.
.The interim results of this evaluation and the Detroit
. Edison program for resolving drawing discrepancies were presented to the-NRC on December 19, 1984.
Detroit Edison will prepare a final report to the NRC on the subject of drawing discrepancies.
This report'will be Detroit Edison's response to Duke Report Recommen-dation.No. 17.
Duke-Report Recommendation No. 24 addressed the need to assure that sufficient. identification labels existed for safety related electri-cal equipment.
Action has already been taken to correct the deficiencies in equipment labeling identified by Duke inspectors and more than 500 new labels for electrical equipment have been installed.
Additionally, Detroit Edison has initiated a program.for labeling station equipment.and components. 'This program is contained within Plant Order EFP-1066 and will be completed prior to commercial' operation.
4 Response to NRC Meeting Report 50-341/84-56 s
Comment No. 3 The following excerpt from NRC Inspection Report 50-341/84-56 identifies the NRC comment on the-section of the Fermi 2 Response (Ref. 2) cited and documents the discussion between Detroit Edison and:the NRC on October 31, 1984:
Section 3.3.2.b - In paragraph 4 DECO treats the apparent draft-ing error as an isolated case.
As identified in NRC inspection report 50-341/84-21, page'12, para.
8.m., several Duke findings were characterized by DECO as drafting errors.
This appears to bt. indicative of a potential problem in DECO's drawing check, review, and approval process which has not been addressed by DECO.
Licensee Response (During October 31, 1984 Meeting)
A supplemental ~ response will be provided~ describing steps which
-have been or.will be taken to prevent drafting errors.
Additionally the response will state when these actions will be completed.
Additionally, the 2000 drawings, for the control room, discussed in Item 1 will be checked for drafting errors prior to fuel load.
Supplement-to the Fermi 2 Response (Comment 3):
Detroit Edison is performing an evaluation of' Fermi 2 drawings to define the scope of_this problem and to formulate the appropriate corrective action.; The final presentation of this program will Laddress'the11ssue'of drafting erro~s as it relates to the overall r
program of correcting'and preventing drawing discrepancies, p
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Response to NRC Meeting Report 50-341/84-56
-Comment No. 6-The following excerpt from NRC Inspection Report 50-341/84-56 identifies the NRC comment on the section of the Fermi 2 Response (Ref. 2) cited and documents the discussion between Detroit Edison and the NRC on October 31, 1984:
Section 3.9.2.a - The second paragraph indicates that the radiographs may have been damaged prior to turnover from the contractor.
Was this damage detected by QA during the turnover?
If not, why?
Licensee Response (During October 31, 1984 Meeting)
A supplemental response will be provided describing the document control provisions applicable to turnover of radiographs.
NRC Comments The supplemental response should address why the watermarked radiographs were not detected at the time of turnover and describe the safety significance of this issue.
Supplement to the Fermi 2 Response (Comment 6):
There were no program requirements for Edison to perform a second review of these radiographs for acceptability upon transfer from the contractor. The radiographs were read and accepted by the contractor at the time of processing in 1972 and 1973.
They were also reviewed by Detroit Edison at that time.
No safety significance is involved.
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.7 Response to NRC Meating Report ~50-341/84-56
-Comment No. 10 The1following excerpt from NRC Inspection Report 50-341/84-56 identi-
_fies the NRC Comment 10'on the section of the Permi 2 Response (Ref.
- 2) cited and documents the discussion between Detroit Edison and the NRC on October' 31, 1984:
Section'3.18.2.a'.2 - DECO needs'a better basis for concluding that a generic problem _concerning control room panel wiring does not exist.
DECO statement that:
"this case was compared
~to similar modifications performed in the control' room to iden-tify if a generic problem existed. _In all cases, the field
-modification request requirements were clear in specifying qual-ity control 1 inspection and point-to-point continuity testing.
The work was done using a traveler requiring review and approv-al-by Field' Engineering, Startup and Quality Control.
Function-al. testing of. valves from the main control room on various systeas confirms that.no such problem exists in the main control room."
Based on the assigned NRC observer's L
understanding of the circumstances surrounding this matter, the exact same statement could be made concerning the switches in the remote shutdown panel which were found to be miswired.
The
.FMR for those modifications also required inspection, test, and review.
However, because of the way the documentation was completed, a reviewer would'not identify that the required L
inspection and test had not been accomplished.
In addition, the, circumstances that allow a small group of people to decide not to implement'QA program requirements and not to modify, inspection and test records to accurately reflect the activity that was performed needs to be reviewed by the applicant'such that recurrence is precluded.
f Licensee Response (During October 31, 1984 Meeting) iL During a review of the Remote Shutdown panel, one additional switch was found with the wrong configuration.
During recent preoperational tests including the integrated ECCS tests many valves were manipulated from the control room without any-switches being discovered having the wrong configur-ation.
During the upcoming Integrated Leak Rate (ILR) tests
.approximately 200 valves will be verified to have the correct configuration.
NRC Comments A supplemental response should be provided describing what steps have been taken by Detroit Edison to determine that the problems identified are isolated and that subsequent or future valve manipulation have confirmed or will confirm this discus-sion.
The rough percentage of safety-related valves manipulat-ed at the completion of the ILM test should be provided.
y Response to NRC Meeting Report 50-341/84-56 Supplement to the Fermi 2 Response (Comment 10):
Detroit Edison has reviewed the valve operation data frcm the recent-ly completed Emergency Core Cooling System Preoperational Tests and the Primary Containment Integrated Leak Rate Test (PCILRT).
There was no indication that a generic problem exists with improper wiring or misconfigured switches associated with remotely operated valves.
These tests have provided an additional margin of confidence that any problem with misconfigured panel switches is limited to the Remote Shutdown Panel, H21-P100, where the misconfigured switches were discovered.
During the PCILRT, the position indicating lights for two Target Rock solenoid actuated globe. valves failed to operate properly.
Although these problems have not been confirmed to have resulted from improper wiring or switch configuration, Detroit Edison will perform an additional verification of the safety-related valves operated from Control Room Combination Operating Panel Nos Hll-P601, Hll-P602, Hil-P603, Hil-P807, Hil-P808, and Hil-P817 and all valves operated from the two Remote Shutdown Panels, H21-P100 and H21-P101.
Approximately 200 of these valves have been functionally reverified.
The balance of the valves, excluding the Target Rock valves described above, will be functionally tested or verified through previous test records.
Corrective action for the-Target Rock solenoid valves will be addressed under our 10yFR50.55(e) Item 142.
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Response to NRC Meeting Report 50-341/84-56 Comment No. 13 The following excerpt'from NRC Inspection Report 50-341/84-56 identi-1 fies the NRC comment on the Section of the Fermi 2 Response (Ref. 2)
' cited andJdocuments the discussion between Detroit Edison and the NRC'on October 31, 1984:
'Section 3.19 - A review of QC inspection procedure implement-ation-for electrical cables and component installation / testing should be conducted-to; determine.why these discrepancies were
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not found during QC inspection and to determine if there are shortcomings in other areas.
(This may be. applicable for items 17, 18, 19, 20 and 22.-)
Licensee Response '(October'31, 1984~ Meeting)
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,A supplemental response will be provided.
NRC Comment The supplemental response should provide-information as to the
. adequacy of the check sheets used for QC' inspection of' fuses, as-built wiring, etc. relating to discrepancies identified dur-ing the Duke inspection and to determine why these problems were not previously identified and to determine if additional review is required.
Supplement to the Fermi 2 Response (Comment 13):
This response addresses why the problems associated with Duke Report (Ref. 1)' recommendations Nos.' 17, 18, 19, 20 and 22 were not identi-
- fied by QC inspections. -The adequacy of the review to determine the
-scope of each of-these problems is also discussed.
The areas of
, concern identified are:
fusing, motor sizing, rolling wires to obtain proper motor rotation, reversal of switch blocks, misalign-ment of limit switches, calibration problems and loose wiring.
a)
Fuse Discrepancies:
Fusing discrepancies were not previously identified ay QC inspection because, in the past,-fuses were installed by the Startup organization and independent QC verification of proper installation was'not required.
Currently, fuses are installed as specified in Section EJ of
-Specification 3071-128 and the installation is performed and verified by Operations personnel.
QA performs periodic surveillances to verify procedure compliance.
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3 Response to NRC Meeting Report 50-341/84-56 Supplement to the Fermi 2 Response (Comment 13) (Cont'd)
This concern has been addressed by Detroit Edison's fuse verifi-cation program.
Detroit Edison has superseded all existing QA Level I fusing information with Section EJ of Specification 3071-128. 'This resolved any document discrepancies.
Additionally, Detroit Edison has committed to a verification of safety related fuses to the requirements of this specification
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prior to fuel load.
This should resolve concerns about installation discrepancies.
b)
Motor Sizing Discrepancies:
Concerns about motor sizing dis-crepancies arose because the Duke Report (Ref. 1 Sections 3.12.2.4'and 3.12.2.5) identified that the drawing for a motor operated valve,did not accurately reflect the horsepower rating of the larger motor which had been installed by an approved design change.
Duke inspectors subsequently examined 13 additional motor operators; they found no other discrepancies and concluded that this was an isolated case.
This discrepancy was not discovered by QC inspection at the time of installation because the original QC installation inspection involved only verification of the adequacy of installation of the assembly (valve) and not the motor, since the motor was a subcomponent which was not field installed.
When motors are field installed, motor sizing is verified to be as specified in the installation package.
Detroit Edison did not rely on the Duke Report conclusion that this was an isolated case but conducted its own evaluation.
Concerns about the adequacy of.the review of this concern were resolved by the Fermi 2 Response (Ref. 2) Sections 3.17.2.b.1
- 11) and 111).
c)
Rolling of Motor Leads:
In order to obtain proper rotation, motor leads may be rolled during checkout and initial operation.
Terminations are then verified for compliance with the design document and, if a change has occurred, QC verifies that a design change request has been issued and approved and checks the configuration before sign-off.
For the case identified by Duke, testing was still in progress and final QC inspection had not been completed.
d)
Reversal of Switch Blocks:
The case of the reversal of switch blocks found by the Duke team for a valve switch on the remote shutdown panel has been dealt with in detail in the response to Duke Recommendation No. 18.
The apparent failure of the QC pw 3
I Response to NRC Meeting Report 50-341/84-56
.-c Supplement to the Fermi 2 Response (Comment 13) ~ (Cont'd) i
(;
' inspection tM discove tlie roblem is attributable to the following reasons:
point-to-point continuity verification was not performed although it.was required by the work package because the switch wiring:had not;been'determinated; and, the t
L possibility of loss-of_ configuration.upon reassembly of the L
switch'was not anticipated.
Procedures now-require point-to-
- point = continuity checks whenever work is performed on a-
' switch,even-when there is only mechanical disassembly of the switch _and no wires are actually determinated.
~ Concerns about the adequacy of the review of this item-should
- be resolved by Detroit Edison's response to Comments 10 and 16 in this report.
Detroit Edison is in the process of performing
=an extensive reverification of proper operation of safety related valves operated from the control room and the Remote l,
Shutdown Panels.
Proper operation of many of the valves operated from the control room was recently verified during the
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ECCS Preoperational Test and PCILRT.
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Limit Switches The scram valve limit switch misalignment l
(Ref 2 Sections 3.20 and 3.18.2.a.1) was not discovered by QC l
installation inspection because the misalignment-developed l'
during repeated oper'ation of the~ valve.
To prevent recurrence
-of this' problem, present procedures require repeated operation h
~ of a scram valve before the final' calibration of the limit
. switch is made.
L Concerns about the adequacy of the review of this item should L
be resolved by Section 3.20 of'the Fermi 2 Response (Ref. 2).
L This reference explains Detroit' Edison's Program to assure l-
. proper limit switch calibration of testable check valves, HCU L
inlet valves and pilot solenoid valves. 'For valves not included in this program, as discussed in the response to t
Comment 16 of this report, Detroit Edison has committed to an extensive reverification of proper position indication'for safety related remotely operated valves.
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Calibration Problems:
The issue of calibration accuracy L
involved instrument calibration to 0.5% accuracy in accordance with the Specification Sheet, when the manufacturer stated a calibration accuracy of 0.25%. This discrepancy had been
' identified by Detroit Edison in March 1984, prior to the Duke Power Assessment, and was in the process of being resolved.
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4 Response to NRC Meeting Report 50-341/84-56 Supplement to the Fermi 2 Response (Comment 13) (Cont'd) l
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. Loose-Wiring:
Concerns:about the adequacy of QC inspections of-
. cable terminations and the adequacy of Detroit Edison's review i
of thisiconcern should be-resolved.by the Fermi 2 Response Section'3.22.2.
This section describes Detroit Edison's i
extensive: evaluation of terminal connections.- -Based on the results of. this~ evaluation, that only ' 67 of the 11,311 terminations-checked.had any indications of looseness and that these 67 deficiencies did not. result'in a, single case of loss of circuit 1 continuity, Detroit Edison" concluded that QC inspections in this area were adequate.
Based on the results of its investigations, Detroit Edison has concluded that the QC activities have been adequate in assuring
.'that Fermi 2 has been constructed in compliance with' design requirements and that the Duke findings-were not indicative of any significant' breakdown or failure of QC inspections.
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. Response to NRC' Meeting 1 Report 50-341/84-56 A
Comment No'. 15
.The following excerpt from NRC' Inspection Report-50-341/84-56 identi-fies the NRC comment'on the section of the Fermi 2 Response (Ref. 2)
- cited and documents the discussion between Detroit Edison and the
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- NRC on October 31,.1984:.
Section 3.19.2.b -
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How have all DECO personnel (test engineers, craftsmen, etc.)Ebeen made aware of the fact that specification i
3071-128 section EJ.is the lead document taking precedence over all related design drawings?
DECO states "In time, fuse size and type for each QA level I application will be eliminated from other engineering documents."
Which' documents will-be eliminated and in how long a time?
1 How is this to be controlled?
Why not update existing drawings and documents?
Licensee Response (During October 31, 1984 Meeting)
. With regard to the first item a training program has been com-pleted.
.The training was to make personnel aware that the specification is the lead document.
With regard.to the_second issue, this item will be addressed in conjunction'with recommendation #17 discussed in Item 1 above.
NRC Comment.
.The supplemental response should be specific as to-how this process will be controlled and the~ rationale-as to why existing drawings and documents do not require updating.
. Supplement to the Fermi 2 Response (Comment 15):
Safety-related. fusing information is controlled by being consoli-
- dated in Section EJ of Specification 3071-128.
Personnel involved
.with~ fusing have completed:a training program and are aware that Section'EJ of Specification 3071-128 is the only source used for fusing information.
Procedures controlling the installation, test-D
-ing and maintenance of' fuses have been revised to reflect the use of Section.EJ; As part of the long. range drawing update program fusing information will'be removed from drawings,_ schematics, wiring dia-Jgrams, etc.,~although fuses will continue to be shown diagram-j matically.
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f Response to NRC Meeting Report 50-341/84-56 Supplement to the Fermi 2 Response (Comment 15) (Cont'd)
There were.several reasons for Detroit Edison's decision to consoli-date fuse information in a specification rather than update all of
'the drawings, schematics and wiring diagrams.
By avoiding revising a large number of drawings, many with redundant information, the task of disseminating the correct information could be completed quickly and with minimal chance for error.
Having one complete and authoritative source of information available immediately eliminated confusion and reduced the probability of error in the field during the period of time required to check, revise and reissue drawings.
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~ Response to NRC Meeting Report 50-341/84-56 Comment No. 16 The following excerpt from NRC Inspection Report 50-341/84-56 identi-fies the NRC comment on the section of the Fermi 2 Response (Ref. 2) cited and documents the discussion between Detroit Edison and the NRC on October 31, 1984:
-Section 3.20 - The response addressed the specific items which were" identified by Duke.
DECO did not appear to sample the population to determine the extent of the problem.
NRC Comment A supplemental response should:be provided describing what pro-
- gram will be in place to assure that limit switches for valve operators are showing their correct position as required.
Suppl'ement to the Fermi 2 Response (Comment 16):
Verification that limit switches for safety related valve operators are installed and operate properly was performed during the Primary Containment Integrated Leak Rate Test (PCILRT).
A review of the test ~results provides confidence that limit switches on air operated valves function as intended.
However, because of the malfunction of position indication on two Target Rock valves during the PCILRT, additional testing will be performed.
As discussed under Comment 10 of this report, Detroit Edison will provide additional verification of proper operation of safety related valves operated from the Control Room Combination Operating Panels Hil-P601, Hil-P602, Hil-P603, Hil-P807, Hil-P808, and Hil-P817 and all valves operated from the two Remote Shutdown Panels, H21-P100'and H21-P101.
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.i Response to NRC Meeting Report 50-341/84 Comment No. 18 The following excerpt from NRC Inspection Report 50-341/84-56 identi-p
.fies~the NRC' comment on the section of the Fermi'2 Response (Ref. 2) cited and documents'the discussion between Detroit Edison and the NRC on October 131, 19843-Section 3.23.21-DECO should include in their response'a discus-sionLas to why this situation was not identified'by DECO as part of their " pipe break (or crack) outside~ containment evalua-tion program" and what DECO will.do.to assure that other
'similar. situations don't exist in the plant.
Licensee Response The issue discussed was known by DECO.
In general all cabinets are sealed on top to prevent moisture intrusion.
Additional steps'such as wrapping pipes to capture spray are in progress.
NRC Comment-A supplemental response should be generated ~ describing in general terms the program for water spray and seismic inter-action.
The response should indicate when the safety-related activities will be completed.
Supplement to the Fermi 2 Response (Comment-18):
Jus-stated;in the Fermi 2 response, the spray impingement evaluation was conducted.by identifying the-system fluid-and operating pressure of the lines near each of the essential McCs and determining-if a postulated crack in any one of the pipes would result in spray impingement on the MCC panel surface.
It was assumed that direct spray impingement would functionally disable the MCC.
The evalua-tion concluded that the MCCs identified above required.the addition-alfprotection provided'by the wrapping of pipes in close~ proximity..
'This supplement to the Fermi 2: Response (Ref 2) amends Detroit Edison's commitment regarding water spray protection.
In-the~ Fermi 2
Response it was indicated that physical barriers would be erected
.to shield the McC's in question against' spray.
Subsequent analysis
. identified the undesirability of'having such barriers from a human factors standpoint.
The preferred solution is the application of wrapping on the pipes identified'as potential sources of spray.
It also has been determined that only MCC's 72F-4A, 72C-F, and 72C-3A have toLbe protected.
MCC's 72E-5A and 73B-3A are not needed for safe shutdown and, therefore, do'not need to be protected.
The application of the wrapping will be completed by fuel load.
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Response to NRC Meeting Report 50-341/84-55 Supplement to the Fermi 2 Response (Comment 18) Cont'd)
Regarding the request for a description of the seismic interaction program, the potential for interaction between safety-related and non-safety-related equipment during a seismic event was addressed through an extensive rattlespace program conducted during the past-two years.
Engineers walked all areas of the plant containing safety-related equipment.
Points of potential interaction were
-identified, evaluated and, if necessary, corrected.
Regarding the instance of contact between MCC-72C-3A and a Seismic Category II-over-I stairway, this case was not identified as a rattlespace problem because the rattlespace for both items was 0 inches; therefore, a gap of 0 inches is theoretically allowed.
However, the actual movement of the MCC and the stairway is small but greater than 0' inches.
Rather than justify what was thought to be'a minor effect by a complex engineering analysis, a small amount of clearance between these two items was established.
Informal reviews of the plant revealed no additional instances of this type of contact.
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~.3 Response to NRC' Meeting Report-50-341/84-56 Comment'No. 20 The following2 excerpt'from NRC Inspection Report 50-341/84-56 identi-fies an NRC comment on1the"section of:the Fermi'2 Response (Ref. 2) cited and documents-the discussion between Detroit Edison and the
- NRC on OctoberD31,_1984
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~Section-3.2.2.a - The HVAC contractor, Robert'Irsay, demobil-ized during. June'1981.
Bechtel completed the HVAC work under the: direction.of the System Completion Organization (SCO).
Who is the contractor referred to in the response?
If it is Irsay, it would-indicate there may be document control problems.
Licensee Response The' licensee responded that documents were placed in boxes and placed in-the vault.
'NRC' Comment'
.The' licensee'should respond to this item..The staff _ commented that three years after turnover appeared to be a long time before.theLdocuments were' incorporated into the document control system.
Supplement to the Fermi 2 Response (Comment 20):
This response addresses _the reason that the latest revisions
-(the as-builts) were' stored in the site QA records vault without having been processed through the site document control
~ center.
The contractor referred to in the' response to Duke Recommendation no. 2 is Robert Irsay (RICo).
RICo had their own1 document control system to handle' drawings produced by.
their design contractor, Fluor.
RICo was responsible for their
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ownias-built drawings and these were turned over along with the QC records for the job at the time of' demobilization.
The combined records were placed directly into the site QA records vault without having the latest revisions of the drawings.for the HVAC systems 1(the as-builts) processed through the Edison site document control center (DCC). This oversite has been corrected.
It appears to be an isolated incident as few of the Fermi 2 contractors had responsibilities for design and design document control.
A contributing factor wasithat RICo was among thejfirst contractors to demobilize.
Operational' Quality Assurance pr'ocedures! currently _in place will prevent
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recurrence.
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Response to NRC Meeting Report 50-341/84-56 Comment No. 21 The following excerpt'from NRC Inspection Report 50-341/84-56 identifips the NRC comment on the section of the Fermi 2 Response (Ref. It cited and documents the discussion between Detroit Edison and the NRC on October. 31,-1984:
/Section 3.16.2.a
-QA has had a housekeeping program in place in_ excess of a year; in addition, SCO had their own program.
.The discussion did not address these programs.
What assurance is there-that the new programs will be any more effective than those which were in place?
s Licensee Response (During October 31, 1984 Meeting)
The licensee's' discussion addressed the new programs and not the. effectiveness.of those already in place.
DECO believes that the new programs.will be effective because the plant will txt in an operational phase.
- NRC Comment-4 N
_ The lic'ensee. should respond to this item and address the programmatic effectiveness of programs at the time of the inspection and the adequacy of the newly installed problem (SIC).-
^
Supplement to the Ferm
-2 Response (Comment 21):
a Detroit Edison has' concluded that the high level of construction, 7
- testing and maintenance-activities in very,close proximity coupled
~
4
!with the. divided responsibility for housekeeping :was the principal
-reason that~the previcus program'was less'than totally' effective.
' With the completion of construction the plant has been cleaned and responsibility for housekeeping has been given to a single organiz-y
~
ation, Nuclear Operations.
POM Procedure 12.000.48, " Plant House-keeping", provides.for the administrative controls needed to assure
' proper control over housekeeping for activities performed by any
- group working in the plant.
cRecentiinspections, including NRC inspections, have verified the cleanliness of the plant'and the effectiveness of the current pro-
- gram.- Thus,.given the present state of preparedness for operations at Fermi ~2, the end of construction-related activities and singular responsibility for controlling housekeeping, Edison management is
' confident =that?the present housekeeping program is adequate to main-
~
tain' plant cleanliness.
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