ML20129H047

Responds to Violations Noted in Insp Rept 50-341/85-10. Corrective Actions:Policy Statement Issued Requiring Design Change Documents Be Used for All Future Revs & Proper Nameplates Be Applied to Electrical Equipment

ML20129H047
Person / Time
Site:	Fermi
Issue date:	05/24/1985
From:	DETROIT EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
EF2-70453, NUDOCS 8506070452
Download: ML20129H047 (4)

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Cayne H. Jens Vc3 Presasent Nuclear Operatens FermF2 May 24, 1985

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. Ed, son 6400 North Dixie Highway i

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EF2-20453 Mr. James G. Keppler Regional ~ Administrator-Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Reference:

Fermi 2 Docket No. 50-341 NRC License No. NPF-33

Subject:

Detroit Edison Response Inspection Report 50-341/85010 This letter responds to the item of noncompliance described in your Inspection Report No. 50-341/85010.

This inspection

.was conducted by Mr. C.

H. Scheibelhut of NRC Region III during February and March, 1985.

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 Federal Regulations.

The enclosed response is arranged to correspond to the sequence of items 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-complianc'e cited in the inspection report.

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

Sincerely, zo~A f./

.cc P.

M. Byron N.

J. Chrissotimos USNRC, Document Control Desk Washington, D.C.

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N THE DETROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATIONS ORGANIZATION RESPONSE TO NRC INSPECTION REPORT NO. 50-341/85010 DOCKET NO. 50-341 LICENSE NO. NPF-33 INSPECTION AT: FERMI 2, NEWPORT, MICHIGAN INSPECTION CONDUCTED:

FEBRUARY AND' MARCH 1985 a

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r RESPONSE TO NRC INSPECTION REPORT NO. 50-341/85010

' Statement of Noncompliance 85010-01 10;CFR 50,' Appendix B, Criterion X, as implemented by DECO

. Operational Quality Assurance Program Requirement 10,.re-quires that' inspections shall be performed of activities affecting quality to verify conformance with the documented-instructions, procedures, and drawings for accomplishing the activity..

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' Contrary to the above, numerous PN-21s (work orders) written to provide proper labeling of specified plant equipment were not adequately reviewed subsequent to the work-being com-pleted.

This resulted in the existence of nonconforming conditions not being-properly identified and reviewed for root cause determination.

Corrective-Action Taken and Results Achieved The Duke Power Company Construction Assessment Team (CAT)

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finding / concern No. 16 dealt with ; labeling problems on elec-trical;switchgear.

In response to this concern, Detroit

-Edison started'a program to provide proper labels (name-plates) for major electrical equipment such as switchgear.

Using the latest drawings, Detroit Edison inspected the

. equipment, not'ed the deficiencies and wrote PN-21s (Work Orders) to provide labeling.

Labels were subsequently installed on the equipment.

Thereafter, an NRC inspector requested a field tour to inspect.a sampling of the equipment for proper nameplates.

The latest revisions of the applicable drawings were obtained froa'the Document Control Center.

This inspection-again ' found discrepancins between the drawings and the equipment nameplates.

An investigation of this situation revealed that drawing revisions had been issued af ter the nameplates had been

-installed to address the CAT concern.

.These drawing revisions included, among other things, changes to some of.

the nameplates.. However, a drawing change notification, which would have: highlighted changes affecting the name-plates, was.not issued.

Therefore, when the inspector

. reviewed'the equipment nameplates'against the later drawing revisions; discrepancies were noted.

~Because of the incident, on February 11, 1985, a stop Work

- Order was issued by Nuclear Quality Assurance on all electrical and I&C labeling.

The order was lifted on

. February 19, 1985 af ter:

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. Drawings that were issued without change notification were identified, and -

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RESPONSE.TO-'NRC INSPECTION' REPORT NO. 50-341/85010 i

Corrective Action Taken and Results-Achieved (Cont'd) 2.-

_ Fermi 2. Engineering issued a policy statement-(F2E-85-0256,: dated February 11, 1985)~ requiring that s s Nuclear Operations design change documents must be used

'for all future revisions to> design documents.

Engineer-

--ing procedures were subsequently. revised tas implement this.

R Based on the identified drawing list, field.walkdowns were performed and discrepancies-between the nameplates and 4

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drawings were documented on Deviation / Events Reports (DER).

After evaluation of these DERs,'the drawings will be revised L

accordingly'and/oreproper nameplates will be installed.

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. During the previous nameplate installation program,'had the PN-21s been properly--reviewed, the existence of noncon -

forming' conditions'would have been identified with sub-equent_ DER initiation and determination'of-cause.

To address this' concern, on March.20, 1985, the Plant Superintendent issued a memorandum to Section Heads,-

" Reviewing PN-21's for Possible Non-Conformance."

It. stated that, "The purpose of.this memorandum is ta) point out this

. recent occurrence (of an inadequate. review] and to remind Section' Heads and their designees of the importance of an

- adequate-review of PN-21's for potential'non-conforming conditions.'

' Corrective Action Taken to Avoid Further Noncompliance As stated previously in this response, Nuclear Operations design change documents must now lui used~for all; future revisions to. design documents. =This ensures that plant

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personnel;are notified of'all changes to affected drawings so that appropriatefaction may be~taken.

Date When Full' Compliance Will Be Achieved

- The remaining item,to complete is the revision of'necessary drawings and the installation'of required nameplates for the:

electrical equipment.

This will be completed before commercial operationi.after which Detroit Edison will be in._

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full compliance an'this matter.

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