NRC-89-0025, Responds to NRC Re Violations Noted in Insp Rept 50-341/88-37.Corrective Actions:Improperly Annotated Drawings Corrected & Reading Issued to QA Audit Describing Need to Verify Intent That Tech Specs Requirements Met

Responds to NRC Re Violations Noted in Insp Rept 50-341/88-37.Corrective Actions:Improperly Annotated Drawings Corrected & Reading Issued to QA Audit Describing Need to Verify Intent That Tech Specs Requirements Met

ML20235Y708
Person / Time
Site:	Fermi
Issue date:	03/02/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-89-0025, CON-NRC-89-25 NUDOCS 8903140515
Download: ML20235Y708 (13)

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8. ROtph Sylvia senior vice nnioent

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(313) $86-4150 March 2, 1989-NRC-89-0025 1

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U. .S. Nuclear Regulatory' Commission -

Attention: Document: Control Desk Washington, D..C. 20555

References:

(1) Fermi 2

.NRC Docket No. 50-341.

NRC License.No'. NPF-43 (2) NRC Inspection Report 50-341'/88037, dated January 31, 1989 I

(3) NRC Diagnostic-Evaluation Team Report for '

Fermi 2, dated November 16, 1988 (4) Detroit Edison's Response to the Diagnostic Evaluation Team Report, NRC-89-0004 dated January 17, 1989z 1 1

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Subject:

Response to Notice of Violation Attached is the response to the Notice of Violation contained in reference'2. The inspection that resulted in these violations being issued was based upon the findings' described in reference 3.

The first violation;was against the red-lining practices used l for design changes'. Detroit Edison is revising its. design  !

change process and transferring the responsibility.for red-lining to the Plant System Engineers-from;the maintenance department.  !

In the second violation, activitics relating.to OSRO and NSRG l were cited as being in non-compliance with. Technical.

Specifications. Detroit Edison is denying some aspects of this  !

violation, based on the results of our investigation. Actions 3 have been taken.to further enhance the functi'ons of OSRO as' i described in the attachment.

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i U. S. Nuclear Regulatory Commission March 2, 1989 NRC-89-0025 i Page 2  !

a ISEG functions and activities that were potentially contrary to j Technical Specification requirements were addressed by the third violation. The concerns noted do not constitute a lack.

of appreciation for the Technical Specifications, but rather a difference in interpretations. Actions have been taken to ensure compliance with the interpretation given by the NRC.

I The final violation was issued for perceived inadequacies in l design controls and corrective actions related to discrepancies between the UFSAR and plant configurationyof the I Core Spray System. The discrepancy was identified in 1986. ]

Initially a revision to the FSAR was intended to correct this. I Engineering reviews between 1986 and 1987 later determined that an upgrade of the plant configuration to that described in the UFSAR was desirable, though not necessary to meet regulatory requirements. In 1988, the testing necessary to l upgrade the system was completed. Since'this was done as-an 1 enhancement, Detroit Edison is denying this potential violation.

If there are any questions relating to this response please contact Patricia Anthony at (313) 586-1617.

Sincerely, l cc: A. B. Davis l R. C. Knop l W. G. Rogers

! J. F. Stang l Region III l

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RESPONSE TO NOTICE OF VIOLATION 50-341/88037 Statement of Violation 88-037-01:

In reference 2, it stated:

"Three of ten control room drawings which were audited had red-lining deficiencies. Red-lined drawings served as an interim notification to the operators of a configuration change and remained in effect until the drawings are revised to incorporate the outstanding changes. Controlled drawing 6SD721-2530-12 was not red-lined to reflect the changes made ,

by engineering design package (EDP) 3793. Controlled  !

drawings 6I721-2679-1 and 6M721-5741 had incorrect red-line. l changes to reflect EDP 4800, even though the latest revision 1 of the drawings had already incorporated the correct EDP 4800' '

changes. The licensee determined that an STA had. incorrectly red-lined both drawings (DET Section 3.2.4.2). Procedure POM l 12.000.64 Revision 12 " Implementation of Modification,"

l Step 5.6.5 requires the Maintenance Support Technician to verify that all drawings have been red-lined. This is considered a violation of 10 CFR 50, Appendix B, Criterion i V". l Discussion:

1 Investigation of the red-lining of 6SD721-2530-12 per EDP 3793 has led to the following conclusions:

1) In revision 0, item 3 of EDP 3793, various drawings were ,

revised to delete control circuit fuse descriptions and {

add a note referring to Detroit Edison specification l 3071-128 standard EJ for control circuit fuse '

descriptions. It listed 6SD721-2530-12 as an affected drawing.

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2) Actually, drawing 6SD721-2530-12 did not require I red-lining, only I-2331-13 which was already included in l EDP 3793 needed to be listed. Therefore, when the individual went to perform the red-lining of 6SD721-2503-12 as specified in EDP 3793, the individual annotated the drawing on the apperature card as

" revised" in red but performed no red-lining since none was required.

The investigation of EDP 4800 revealed the original intent of the change was to remove instrumentation and provide a cap on the inboard side of the abandoned primary containment penetration. On November 29, 1985, the cap was installed and appropriate drawings red-lined.

A revision to EDP 4800 was issued on June 30, 1986, which l

removed the cap and returned the penetration to its original configuration. This change was implemented without revised Page 1 u - - _ _ _ _ _ - - - - - - - _ - . _

RESPONSE TO NOTICE OF VIOLATION 50-341/88037 Discussion (Cont'):

red-lining of the drawing. An individual who is no longer on site signed that red-lining was completed July 11, 1986.

Between this time and when EDP 4800 was "as-built" verified on July 5, 1988, the STA took each new revision to these drawings and transferred the incorrect red-lining showing the cap.

EDP 4800 was "as-built" verified on July 5, 1988. As part cf this process, a Maintenance Support Technician initialed for completion of the red-line verification without reviewing control room drawings as required by 12.000.64 Upon discovery by the NRC of the error, the STA investigated and determined that the cap was no longer pert of the as-built configuration. He then corrected the drawings to properly reflect plant configuration. The correct as-built configuration was incorporated into 6M721-5741 in revision N and into 6I721-2679-1 in revision U.

Corrective Actions Taken and Results Achieved:

In reference to EDP 3793, drawing 6SD721-2530-12 and another drawing (I-R-2371-09) were found to be improperly anotated as

" revised" have been corrected. No other drawings or apperature cards were found to be improperly red-lined or annotated per EDP 3793.

The drawings and apperature cards affected by EDP 4800 were reviewed to verify they reflected proper plant configuration. No other instances of inappropriate red-lining were identified.

Corrective Actions Taken To Prevent Recurrence:

Presently, Quality Engineering is performing a surveillance of red-lining practices. Additionally, Fermi 2 is revising its design change process. As part of this revision, the responsibility for red-lining has been transferred to the Plant System Engineers from the Maintenance Support Technicians.

Date When Full Compliance Will Be Achieved:

All previously identified drawing red-lining deficiencies have been corrected. Therefore, Detroit Edison is now in i compliance. I Page 2

RESPONSE'TO NOTICE OF VIOLATION' 50-341/88037 Statement of Violation 88-037-02:

A Severity Level IV violation was issued as"follows:

Technical Specification 6.5.2.8.a requires, inL part, that.

audits of unit activities shall be performed under'the cognizance of the NSRG. These audits shall.encompasc.the 'q conformance of unit: operation to provisions.. contained within -

the-Technica1' Specifications.

Technical Specification 6. 5.1. 6. j s t a t e s that the OSRO shall-be responsible for' review of the Security Plan.

Technical Specification 6.5.1.5 states'the quorum of the OSRO necessary for the. performance of the OSRO responsibility'and

. authority provisions of these-Technical Specifications shall consist-of the Chairman or a Vice Chairman and four. members including alternates.

1 Technical Specification 6.5.5.6 states the quorum of the NSRG q necessary for the performance of the NSRG reviev and audit.

functions of these Technical SpecificationsEsha11 consist of the Chairman or his designated alternate andHat least one half of the remaining NSRG members including alternates. l l

Technical Specification 6.5.1.7.b states the OSR01shall render determinations in writing toEthe' Nuclear' Safety Review- j Group with regard to whether or n o't each item' considered under Specification 6.5.1.6.a.,through f. constitutes an ,

unreviewed safety question.

Technical Specification 6.5.1.3 states all. alternate members shall be appointed in writing by the OSRO Chairman.to serve on a tempcrary basis.

Contrary to the above:

a. QA audit 88-0037 did not identify nonconformance of unit-operation to provisions contained in Technical-Specification 6.5.1.6.j.

b. OSRO failed to review revisions to the Security Plan.-

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.c. OSR0 meetings 262I, 262H, 263B, 264A, 282C, 284A, 262A I and 265A; and NSRG meetings87-05B, 88-01A,88-02A, I 88-02B,88-02C, 88-03A and 88-03B were conducted without meeting quorum requirements,

d. It was not evident.that OSRO rendered determinations in writing to the NSRG with regard to whether or not each J item considered under Specification 6.5.1.6.a. .through  !

f. constituted an unreviewed safety question.

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RESPONSE TO NOTICE OF VIOLATION 50-341/88037 Statement of Violation 88-037-02 (Cont'):

e. From June 3, 1988, to August 25, 1988, alternate members were used at OSRO meetings without any appointment in writing by the OSRO Chairman.

Discussion:

In part a.of the violation, a QA audit of the Safety Review and Evaluation Program was cited for failing to identify perceived nonconformances to Technical Specification 6.5.1.6.j. as findings. This occurred because the audit team leader incorrectly interpreted the intent of the Technical Specification as not applying to OSRO review of revisions to the Security Plan.

Relative to part b,of the violation, the statement in the QA audit report was incorrect since past revisions to the Security Plan had received OSRO approval. In September of 1988 DER 88-1636 was written to address the concern.

Resolution of thin DER showe6 that the conclusion of the QA audit report was erroneous. Revisions to the Security Plan issued since the receipt of the operating license had been reviewed and approved by OSRO as evidenced by the OSRO Chairman's signature on the attached cover letter to these revisions. Therefore, the condition cited in part b of violation did not exist and DECO denies this portion of the violation.

Part c of this violation dealt with conducting OSRO and NSRG meetings without a quorum. Review of the OSRO meeting minutes indicates that the subj ec t meetings were conducted by telephone poll or walk-through meetings. These meetings were l in accordance with the procedure in effect at the time and a quorum was ased for approval. In the report, it stated that OSRO Meeting 272 did not meet the quorum requirements of i Technical Specification 6.5.1.5 since at least one-half the l OSRO members, including the alternates were not present.

Technical Specification 6.5.1.5 actually states:

"The quorum of the OSRO necessary for the performance of the OSRO responsibility and authority provisions of these Technical Specifications shall consist of the Chairman or a Vice Chairman and four members including alternates".

Therefore, meeting 272 was held in accordance with this requirement since a chairman and four members, including one alternate, were present.

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RESPONSE TO NOTICE OF VIOLATION 50-341/88037 Discussion (Cont'):

At NSRG meetings88-01A, 88-02A,88-02B, 88-02C and 88-03B,.

some - members participated using a telephone conference call.

In meeting 88-02C, a quorum was established with onsite members and in the other instances, a. quorum was-established with some members onsite and others by. telephone conference.

Use of conference calls is necessary to' convene.the NSRG on relatively short notice. Since Technical Specification.

6.5.2.6 requires that only a minority of the NSRG quorum can have line responsibility for the unit, telecons are necessary. It has been standard practice to panafax or express mail materials to be discussed to the members that participate over the phone. Technical Specification 6.5.2 does not state that all quorum members must be onsite. In all cases cited, the involved NSRG members were able to participate directly in the dialogue concerning the item being discussed. In the case of meetings87-05B and 88-03A, telephone polls were held to ascertain the acceptance of.the items discussed in meetings87-05A and 88-02B respectively.

Therefore, DECO denies part c of the violation.

Relative to part d of the violation, when the concern over OSRO rendered determinations of unreviewed safety questions in writing was identified by the DET, prompt action was taken by the OSRO Chairman to correct this matter. Likewise, for part e of this violation, a list of approved OSRO alternates was promptly issued following identification by the DET.

Corrective Actions Taken and Results Achieved:

Required reading was issued to the QA audit group via an audit critique describing the need to verify that the intent of the Technical Specification requirements are met. The audit team leader for this audit is no longer with Detroit Edison. These actions address the concerns cited in part a.

Since the part b finding was erroneous, no corrective actions  ;

were necessary. QA Audit Report 88-0037 which contained this I error has been corrected.

The procedure governing OSRO activities, FIO-FMP-01, has been revised to eliminate telephone polls and walkthrough OSR0s.

OSR0s that are not conducted as on-site meetings (i.e.

telecons) must be followed-up with an on-site meeting on the-next working day. These are considered to be enhancements i that improve this program.

In order to resolve the concerns relating to part d of.this violation, the discussion of the possibility of an unreviewed safety question is documented by OCR0 for each item in the  ;

meeting minutes. This policy was implemented at the i beginning of October of 1988. It has been proceduralized in step 3.4.2 of FIO-FMP-01 revision 2.

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RESPONSE TO NOTICE OF VIOLATION 50-341/88037 Corrective Actions Taken and Results Achieved (Cont'):

Part e of this violation was resolved by issuance of list of OSRO members and alternates on August 3, 1988. This listing is being revised as necessary to maintain it up-to-date.

Corrective Actions To Be Taken To Prevent Recurrence:

All actions needed to prevent recurrence are complete.

i Date When Full Compliance Will Be Achieved:

l Fermi 2 is in full compliance.

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l RESPONSE TO NOTICE OF VIOLATION 50-341/88037 Statement 1of Violation 88b37-03:

1 L In the Notice,of. Violation, it stated as follows:

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" Technical Specification 6.2.3.1 states the ISEG shall l function to examine' unit operating characteristics.,NRC-l issuances, industry advisories. Licensee Event Reports, and other sources of plant. design and operating' experience-L information, including plants of similar design, which may l indicate areas of improving unit -safety. j

-Technical Specification 6.2.3.2. states, in part,. the ISEG shall be composedoof at least five dedicated, full-time engineers located onsite.

' Contrary to the above: .

a> ISEG was not reviewing NRC issuances or industry-advisories.

b. One of five ISEG members was detailed full-time to the l

Technical Specification Review Team".

Discussion:

The members of the ISEG had previously interpreted Technical-Specification 6.2.3.1 as applying to the' types of information that should be reviewed rather than an all inclusive listing of d o'oum e n t s to be reviewed. Additionally, an interpretation of Technical Specification 6.2.3.2.was made which considered l the role of the ISEG member in the Technical Specification "

l l Review Team to be in compliance with the requirements. l Therefore, neither of these instances constituted a lack of appreciation or awareness of the Technical Specification requirements, but rather a less stringent-interpretation of those requirements.

Corrective Actions Taken and Results-Achieved:

In December of 1988, the ISEG. implemented a policy which requires them to review all NRC and industry issuances that are identified through the corrective action program. This action brought ISEG into full compliance with the more stringent-interpretation of Technical Specification 6.2.3.1.

The ISEG member, who served on the Technical Specification  !

Review. Team, was reassigned to other duties:within the scope ~ j of Technical Specification 6.2.3.2 in September of 1988.  ;

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RESPONSE TO NOTICE OF VIOLATION 50-341/88037 Corrective Action To Be Taken To Prevent Recurrence:

Actions are being taken to ensure that ISEG obtains all NRC ,

and industry issuances received ~at Ferni 2. This will )

provide an independent check that these items are addressed.

l Procedure SGP-SR1-01, " Independent Safety Engineering Group" will be revised to delinente the policy of reviewing all NRC )

and industry issuances. Additionally..the revision will )

include restrictions that will provido' assurance that ISEG members maintain their independent functionu from the rest of the nuclear organization. )

Date When Full Compliance Will Be Achievad: ,

i Fermi 2 has been in full compliance with the Technical )

Specification interpretations for ISEG since completion of-the actions previously described. The revision of SGP-SR1-01 will be completed by March 31, 1989. These actions will ensure future compliance with the Technical Specification requirements for ISEG. '

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RESPONSE TO NOTICE OF VIOLATION 50-341/88037 Statement of Violation 3f_-037-04:

In the inspection report, it stated:

"From July 15, 1985, to March 16,. 1988, the Core Spray piping

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components between valves E2150-F004A/B and E2150-F005A/B l were only qualified to 500 psig and 212 degrees Fahrenheit.

The UFSAR requires a design pressure and temperature of 1250 psig and 575 degrees Fahrenheit, respectively (DET Section 3.6.2.4). This nonconforming condition was not identified until March 1986 and was not corrected until March 16, 1988.

This is a violation of 10 CFR 50, Appendix B, Criteria III and XVI".

Discussion:

In the first quarter of 1986, Stone & Webster performed an evaluation of the effectiveness of the processes used to

} identify and prioritize engineering work at that time.

Eleven concerns were identified as a result of this review including the concern identified above. The fact that the core spray piping between valves E2150-F004A/B and E2150-F005A/B did not have a pressure and temperature rating equivalent to the reactor coolant pressure boundary design temperature and pressure as shown in a FSAR drawing, was identified on March 21, 1986 na part of the Stone and Webster Engineering Evaluation Team (SREET) audit of the core spray system.

In response to SWEET potential finding / concern #007, engineering stated that the piping and gate valve i

E2150-F004A/B are downstream of pressure boundary isolation l valve E2150-F005A/B and that this piping will not be operated or be surveillance tested at pressures above 500 psig. The piping stress report and design specification reflected the lower pressure and temperature design conditions. Protection against overpressurization caused by leakage through check valve E2150-F006A/B and the coincident misalignment or misoperation of valve E2150-F005A/B is not a regulatory or code requirement. Provision for potential overpressurization I

was provided by specifying 900 # ANSI rated components.

Therefore, the design pressure and temperature of 500 psig/212 degrees Fahrenheit were adequate.

Through review of the FSAR at that time, it was concluded that the design conditions for the core spray piping between valves E2150-F004A/B and E2150-F005A/B were not specified as 1250 psig and 575 degrees Fahrenheit. NRC Supplement 4 to the Fermi 2 Safety Evaluation Report (SSER-4) Appendix K, Sections 3.1.7 and 4.1 supported this position. Since as previously discussed, the design pressure and temperature of Page 9

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I Discussion (Cont'): '

l 500 psig/212 degrees Fahrenheit were adequate.- no' condition, l adverse =to' quality existed. No-further engineering action

l. was required. However, the need'for clarification of the FSAR was evident and section 6.3.2.2.3.was to be changedEto clearly identify the valves and piping involvef as part of' the resolution of the SWEET finding. . DECO did"not' complete this upgrade to the FSAR since it was subsequently decided.to l upgrade the piping, q The question of-whether it was credible that a combination of.

isolation valve leakage and misalignment could cause:

overpressurization was being examined by Engineering. An incident occurred.in the LPCI system in March 1986 at another plant which caused similar piping in their LPCI system Eto be i I

pressurized to reactor pressure. 'Therefore, a decision was.

l made to upgrade the piping to design conditions of 1250 l

psig/575 degrees Fahrenheit and PDC 6349 was issued in i

September 1986. This change would.nake the FSAR changes.

unnecessary since the plant conditions would correspond to the most conservative interpretation of the FSAR. The piping; in question could-be upgraded to design conditions of 1250 psig/575 degrees Fahrenheit with only minor revisions to the ASME code design documentation and by performing a hydrostatic test since the components in question-were, rated to ANSI 900 f. EDP 6349 was issued on February.25, 1987 to-revise the design temperature and pressure of this piping.

i Upon staff QA review of the draft UFSAR change.to;close l SWEET-007, they concluded that engineering had not l implemented the actions previously committed to in response to SWEET-007 and DER 87-106 was initiated in March 1987. In the DER response, engineering stated that this was not a design deficiency but rather was being done to eliminate any fotential for an unlikely sequence of events which would allow pressurization of the piping beyond its design rating.

Also, Safety Evaluation 87-0097 was issued on April-7,_-1987, ,

justifying continued operation and showing that the deviation i l between the UFSAR and the installed configuration did not' '!

involve an unreviewed safety question.'  !

As can be seen from the discussion above, the design .j l conditions of 500 psig/212 degrees Fahrenheit originally specified for this piping vere adequate.. .However the FSAR could be interpreted as stating that the piping was designed to 1250 psig/575 degrees Fahrenheit.

l In order to perform hydrostatic' testing, the plant had.to be i in cold shutdown. It was decided to schedule the hydrostatic l l test along with the pressure test of the outboard isolation '

l valve during the next Local Leak Rate-Test. At that time'..

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RESPONSE TO NOTICE OF VIOLATION 50-341/88037 Discussion (Cont'):

both the appropriate equipment and personnel would readily available. Since the testing was for upgrade of the piping rather than a safety concern, this schedule was adequate.

The testing was performed as scheduled and proved that the piping could withstand the higher pressure.

i Since engineering properly identified and evaluated the Core Spray piping design against the discrepancy in the FSAR, a non-conforming condition or a safety concern did not exist.

Accordingly, DECO denies violation 88-037-04.

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