ML20207L438
| ML20207L438 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/10/1986 |
| From: | Agosti F DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| VP-86-0153, VP-86-153, NUDOCS 8701120166 | |
| Download: ML20207L438 (9) | |
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II e"Y$E*l' Nuclear Operations N
Detroit re u Edison BIAEF" ra.
Novenber 10, 1986 VP-86-0153 Mr. James G. Keppler Regional Mministrator Region III U. S. Nuclear Regulatory Commission
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799 Roosevelt M.
Glen Ellyn, IL 60137
Dear Mr. Keppler:
Reference:
Fermi 2 NIC Docket No. 50-341 NRC License No. NPF-43
Subject:
Detroit Edison Response Inspection Report 50-341/IE028 This letter responds to the notices of violation included with your Inspection Report No. 50-341/86028.
This inspection was conducted by Messr. Z. Falevits of NBC Region III on August 7-22 and September 10, 1986.
Inspection report 50-341/86028 described a Detroit Fdison proposed corrmtive action plan, which wa.s developed to prevent recurrence of violations similar to those identified by Mr. Falevits. The special task force which drafted the proposed corrective action plan has, after further analysis, issued it's final recmoendations. The actions resulting from these recommendations have been given an in depth review by Fermi 2 management and are discussed in the appropriate violation responses.
On October 30, 1986, Mr. Lewis Brtgni contacted Mr. R.
DeFayette of the NBC Region III office and received an extension to the thirty day response due date of f
Inspection Report 86028. The extension was granted until November 10, 1986.
8701120166 861110 PDR ADOCK 05000341
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O PDR 1(t Nov i 21988
n Mr. James G. Keppler November 10, 1986 VP-86-0153 page 2 We trust this letter satisfactorily responds to the notices of violation cited in Inspection Report 50-341/86028. If ym have any questions regarding this matter,_ please contact Mr. Frank II. Sondgeroth, at (313) 586-5083.
Sincerely, h4 cca Mr. J. J. Stefano Mr. W. G. Rogers Mr. G. C. Wright USNIC Document Control Desk Washington, D. C. 20555
'IHE DEIROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATICNS OIGANIZATION RESPONSE 'IO NRC INSPECTION REPORT NO. 50-341/86028 DOCKET NO. 50-341 LICENSE NO. NPF-43 INSPECTION AT: FERMI 2, NDGORT, MICHIGAN INSPECTION CONDUCTED: AUGUST 7-22 AND SEPTDEER 10, 1986 4
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RESPONSE 'ID NRC INSPECTION REPORT NO. 50-341/86028 Statement of Violation 86-028-01 10 CFR 50, Appendix B, Criterion X, as inplemented by Detroit Edison's Quality Assurance Manual, Enrico Fermi Power Plant, Unit 2, Policy 11, Paragraph 11.0.1, requires that a program for inspection of activities affecting quality shall be established and executed to verify conformance to ch'==nted instructions, procedures, and drawings for acccuplishing the activity.
j Contrary to the above, conformance to design drawings was not effectively executed in that on August 12, 1986, the control circuit of Valve E4150-F012 (1 of 14 valves inspected) was found not to be in conformance with the design drawing. The control circuit contained a jumper between valve termination points 10 and 34 which was not shown on the drawing, and no junper existed between points 10 and 36 as required by design Drawing 61721-2221-7, Revision N.
The wiring of this valve was reinspected by licensee personnel on various occasions and the error was not detected.
Corrective Action Taken and Results Achieved
% e incorrectly terminated jumper wire has been properly re-terminated.
The Plant Manager established a Task Force to investigate the wiring error found in E4150-F012. A walkdown and visual inspection was performed on thirteen valves. The thirteen valves inspected had Environmental Qualification modifications performed on them in the Fall of 1985.
The Fall 1985 work packages for the same thirteen valves were reviewed by two separr.te groups. W e Interim Alterations checklists were coupared to the wiring schematics for the purpom of identifying any apparent deviations. The inspections, walkdowns, and work package reviews did not identify additional mislanded cables or junpers.
Corrective Action to Avoid Further Violation The Interim Alterations Checklist (IACL) used to connect the new operator for motor operated valve E4150-F012 was in error in that no de-termination information existed and the re-termination column indicated a junper between termination points 10 and 34. A review of design drawing 6I721-2221-7, Revision N, determined that no such connection shculd exist. Additionally, the design drawing identified the need for a jumper between termination points 10 and 36, which did not exist within the valve operator.
Had the IACL included wiring de-termination information, obtained 1
RESPONSE TO NRC INSPBCTION REPORT NO. 50-341/86028 Corrective Action to Avoid Further Violation (Cont')
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during the removal of the old operator, this discrepancy would i
have been avoided. Identification of the junper configuration j
from the old operator on the de-termination colum of the IACL would have precluded the erroneous connection of termination i
points 10 and 34 and led to the proper connection of termination i
points 10 and 36.
I QC did not identify the wiring errors because they did not yellow-line verify the inst-11ation. He yellow-line verification was not performed because the Engineering Design Package did not'
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require it. S e practice in Engineering is to request yellow-line verification for configuration changes only. The juuper installation on the new valve operator was not considered a configuration change, hence, no yellow-line verification was 4
required.
The order in which steps were to be accesplished was not always
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clear to maintenance personnel using them. We test procedures used to verify proper operation of the valve lacked detail with respect to how and when to perform testing. Also, testing i
requirenents were modified without the concurrence of the l
applicable discipline. During the Task Force investigation it was also noted that an additional wiring error had been made due to a mislabeling of the conductors.
To predra the future occurrence of the above mentioned deficiencies, the de-termination colum of the IACL will be ca pleted for maintenance installations. Where inpractical, 4
additional steps will be taken to assure proper termination of j
conductors. Maintenance procedures will be revised to provide additional guidance for testing and to prohibit the changing of post-maintenance testing requirenents without the concurrence of
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the applicable discipline. Diployees will be trained in the proper use of the revised procedures and steps have been taken to ensure that personnel performing work have been~ briefed on the scope of the job and understand the work package.
QC will continue to perform yellow-lining as specified by Engineering for. wiring configuration changes. Nuclear Engineering Procedure NE 3.9 (EDP Procedure) will be modified to more clearly
. prescribe where QC yellow-line verification is to be performed.
When QC verifies wiring de-termination /re-termination activities they will verify compliance with the IACL, which has been prepared in accordance with the Lead Design Document Index program and the IACL procedure.
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Date When Full Cm pliance will be Achieved The necessary valve operator modifications have been performed.
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RES M E E NRC INSPECTION REPOfE NO. 50-341/86028 Date When Full Caeliance will be Achieved (Cont')
'1he aforementioned procedures and checklists which have not already been revised will be revised and training will be provided in the proper use of these procedures and checklists by December 31, 1986.
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RESPONSE 'IO NPC INSPJ. ION RE10fe NO. 50-341/86028 T
Statement of Violation 86-028-02A Technical Specification Section 6.8.1 requires that procedures shall be inplemented for the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A to Regulatory Guide 1.33 requires procedures be prepared for equipment control and for replacement of equipment.
Contrary to the above, Temporary Modification Tag No.86-103 attached to a jtuper inside 480V MCC 72F-4A, Cubicle 4D, did not contain the name of installer, the date installed, and the correct description of the MCC cubicle it was installed in. This information is required by Temporary Modification Procedure No.
12.000.25.
Corrective Action Taken and Results Achieved Upon discovering the incorrectly coupleted Tenporary Modification Tag a Deviation / Event Report (DER) was initiated. The renedial action, required by the DER, was to replace the erroneously installed Temporary Modification tag with a correctly empleted tag. A properly completed Temporary Modification tag was installed and the DER has, subsequently, been closed.
Corrective Action to Avoid Further Violation Temporary modification 86-103 was performed at 0330 hours0.00382 days <br />0.0917 hours <br />5.456349e-4 weeks <br />1.25565e-4 months <br /> on August 10, 1986. Personnel performing the work were called to work at 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> on August 9, 1986. Their original assignment was to assist in repair efforts to restore Motor Control Center 2PB-1, which received fire damage in position 4C earlier in the week, to an operable condition. Subsequent to their efforts to repair the MCC, PN21-639581 was issued at 0100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> on August 10, 1986. This PN21 was written to install Temporary Modification 86-103.
The personnel who coupleted the information tag for Tenporary Modification 86-103 failed to follow procedure 12.000.25 in that they inproperly completed the tag. The personnel had received training in the proper use of procedure 12.000.25, Tenporary Modifications, in March 1986. The personnel, their lack of current familiarity with the improperly wired valve, and their failure to follow procedures led to the inproper completion of Temporary Modification 86-103.
Date When Full Compliance will be Achieved The anployees responsible for mislabeling Temporary Modification 4
RESPONSE 'IO NBC INSPECTION REPORT NO. 50-341/86028 Date When Full Conoliance will be Achieved (Cont')
Tag 86-103 have been reinstructed in the proper use of procedure 12.000.25, and have received disciplinary action consistent with Detroit Edison's disciplinary policy. Disciplinary action and retraining of employees in the proper use of procedure 12.000.25 is couplete. Fermi 2 is now in full ca pliance.
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RESPONSE 'IO NRC INSPECION REPORT NO. '50-341/86028 Statement of Violation 86-028-02B Technical Specification Section 6.8.1 requires that procedures shall be implemented for the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A to Regulatory Guide 1.33 requires procedures be prepared for equipnent control and for replacement of equipment.
Contrary to the above, the licensee failed to document on ECR'S rewiring of internal junpers on motor operated valves supplied by the vendor, as required by Replacement Procedure of EDP-1424.
Corrective Action Taken and Results Achieved The special task force inspected all thirteen valves that had Envirormental Qualification modifications performed during the fall, 1985, outage to verify their conformance with design documents. No similar wiring errors were found.
Corrective Action to Avoid Further Violation The intent of the note contained on page 1, section 7, of EDP 1424 was to verify that vendor supplied replacement motor operators were in conformance with our wiring schematic diagrams, without revising the operator wiring. Engineering acknowledged the possibility of receiving a vendor supplied motor operator utilizing a newer gen (ration design which, if received, could have required a change to the wiring schenatic diagrams.
Maintenance inspections confirmed the acceptability of the vendor supplied wiring with respect to the schenatic diagrams, with the exception of spare wires connected to unused switches. Since the sequence of valve operation did not require the use of all limit switches, and the spare wiring was not shown on the schunatic diagrams, the wiring was removed.
Plant procedures 12.000.15, 12.000.64 and NE 3.9 allow rework, which is necessary to bring the motor operator in conformance with its design, to be performed without initiation of an ECR.
Engineering personnel will be notified that a note, such as that included in EDP 1424 is no longer needed due to the adequacy of the plant precedures.
Date When Full Ccmpliance Will Be Achieved The Engineering notification will be ccmplete by Novenber 30, 1986.
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