NRC-91-0098, Provides Explanation & Justification of QA Level Assigned to 11 Recorders Used for Category 1 Instrumentation,Per Evaluation of Plant Compliance W/Reg Guide 1.97 by NRC Insp Team During Wk of 910624

Provides Explanation & Justification of QA Level Assigned to 11 Recorders Used for Category 1 Instrumentation,Per Evaluation of Plant Compliance W/Reg Guide 1.97 by NRC Insp Team During Wk of 910624

ML20077K025
Person / Time
Site:	Fermi
Issue date:	07/31/1991
From:	Catola S DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-91-0098, CON-NRC-91-98, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 9108060165
Download: ML20077K025 (3)

Text

1. ' Stanley G Catot.

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Ecison EF" m-July 31, 1991 NRC-91-0098 U. S. Nuclear Regulatory Ccramission Attn Document Control Desk Washington, D. C. 20555

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) Detroit Edison Letter to NRC, NRC-89-0201

" Regulatory Guide 1.97 Revision 2 Design Review."

dated September 12, 1989

3) NRC Letter, " Fermi 2 Emergency Response Capability - Conf ormance to Regulatory cuide 1.97 Revision 2 (TAC No. 59620) ." dated Sept ember 1.1987

4) NRC Letter, " Emergency Response Capability -

Conformance to Regulatory Guide 1.97 Revision 2 (TAC No. 59620) " dated May 2,1990

5) Detroit Edison Letter to NRC. NRC-90-0095

" Compliance with Regulatory Guide 1.97 Revision 2 (TAC No. 59620) " dated June 6,1990

6) EG&G Technical Evaluation Report, EGG-NTA-7763 "Conformance to Regulatory cuide 1.97: Fermi 2."

dated November 1989

7) NRC Inspection Report 50-341/91014, dated July 16, 1991

Subject:

Regulatory Guide 1.97 Supplemental u Information During the week of June 24, 1991, an NRC inspection team evaluated Fermi 2's compliance with Regulatory Guide 1.97. The NRC representatives had a concem with the Quality Assurance level assigned to 11 recorders used for Category 1 instrumentation. Detroit

! Edison committed to formally address the QA level of these recorders L

in a submittal to the NRC. This letter provides the explanation and

[- 9108060165 910731 PDR ADOCK 05000341 p L FDR 1-9

.e a USNRC July 31, 1991 NRC-91-0098 Page 2 justification of the QA level for these 11 recorders to the NRC for review.

The recorders are as follows:

Recorder Parameter Recorded B21R615 Reactor Level B21R623A Reactor Vessel Level and Pressure B21R623B Reactor Vessel Level and Pressure C51R603A. B. C. and D Neutron Monitoring - APRMs C51R607A. B. C. and D Neutron Monitoring - 1RMs These recorders are classified as QA Level IM. which means they were procured as commercial grade rather than as Class 1E instruments, but are maintained and operated to the came criteria as safety-related equipment. !In the Reference 2 response. Category 1 variable instrument loops were considered to have met the Regulatory Guide 1.97 QA requirement if 1) all the instruments in the loop were QA Level 1 or 2) the indicator / recorder was procured under the original purchase order from General Electric (GE) and was classified as QA Level 1H and the rest of the inattuments in the loop were QA Level 1. If any component other than indicator / recorder was classified as QA Level 1M or NQ (not quality related), the loop was provided with a clarification and/or justification note in the submittal.

Recorders B21R615.. B21R623A and B21R623B are L&N Speedomax Series M.

These recorders were procured under the original GE purchase order prior to= the inception of Regulatory Guide 1.97. These recorders are treated t.s safety-related QA Level 1- for their maintenance and surveill.inces as required for QA Level 1H items. All other components, power supplies and cables are QA Level 1 for these loops.

These record 0rs are similar (same manuf acturer andemodel) to other Fermi. 2 recorders classified as QA Level 1. Furthermore, the seismic

• qualification of these recorders has been. accepted per the Safety Evaluation Report NUREG-0798. Section 7.5.2. ' as__ stated by note 1 in Reference 2.

Based on the above discussion. Recorders B21R615. B21R623A and B21R623B meet the intent of the Regulatory Guide 1.97 Rev. 2 requirements for Category .1 variables. These recorders at +be time of replacement will be replaced with QA Level I retorders.

Recorders C51R603A through D and C51R607A through D.also are L&N Speedomax Series M. These recorders were procured under the original GE purchase order prior to the inception of Regulatory Guide 1.97.

These recorders are treated las safety-related QA Level 1 for their maintenance and'surveillances as required for QA Level 1M items. The '

instrument loops do not have QA Level 1 power supplies or cables.

e, s USNRC July 31, 1991 l NRC-91-0098 Page 3 These neut ron flux monitoring recorders are similar (same manuf acturer and model) to other Fermi 2 recorders clansified as QA Level 1.

Furthermore, these instrument loops have been accepted for interim operation per Reference 3. as stated by note 5 in Reference 2.

Reference 6 also found the det(ctors and cables acceptable for interim operation pending NRC review of the EWR Dwners Group Report on neutron flux monitoring. At the May 1991 Regulatory Information Conf erence.

It was announced that the NRC is accepting the BWR Dwners Group's position.

Based on the above discussion, recorders C51K603A through D and C51R607A through D meet the intent of the Regulatory Guide 1.97 Rev. 2 requirements for Category i variables. The classification of these recorders will be maintained as QA Level IM.

If there are any questions considering this information, please contact Ms. Lynne S. Goodman at (313) $U6-4211.

Since rely, e 'D cc C. E. Carpenter, Jr.

A. B. Davis R. W. DeFayette G. M. Hausman S. Stasek

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