NRC-95-0043, Forwards Rev 7 to Fermi 2 Updated FSAR & Fermi 2 Safety Evaluation Summary Rept

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Forwards Rev 7 to Fermi 2 Updated FSAR & Fermi 2 Safety Evaluation Summary Rept
ML20083A743
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 05/05/1995
From: Gipson D
DETROIT EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20083A748 List:
References
CON-NRC-95-0043, CON-NRC-95-43 NUDOCS 9505110122
Download: ML20083A743 (7)


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DIuglas n. Cipxn Sensrir Vice Presdent Nuclear Gerieraton DeirOil r.e 6400 North Disse Htghway Newport. Michigan .48166 (313) 586 5249 May 5,1995 NRC-95-0043 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

Reference:

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

Subject:

Submittal of Revision 7 to the Fermi 2 Updated Final Safety Analysis Report, Safety Evaluation Summary Report and Summary of Ouality Assurance Pronram Channes Pursuant to 10 CFR 50.71(e) and 10 CFR 50.59(b)(2), Detroit Edison hereby submits Revision 7 to the Fermi 2 Updated Final Safety Analysis Report (UFSAR) and the Safety Evaluation Summary Report. Also, enclosed please find a summary description of the changes to the Quality Assurance Program as a result of Revision 7 to the UFSAR. This summary (Enclosure 1)is being submitted to fulfdl the requirements of 10 CFR 50.54(a)(3)(ii).

In accordance with 10 CFR 50.71(e) the information provided in this submittal describes the plant configuration through November 7,1994 as a minimum and presents changes made since the previous submittal: (1) that are considered necessary to reflect information and analyses submitted to the Commission or prepared pursuant to Commission requirements; and (2) that were made under the provisions of 50.59 but not previously submitted to the Commission. Changes made to the Fire Protection Program since Revision 6 submittal of the UFSAR do not constitute an unreviewed safety question and meet Operating License Condition 2.C.(9)(a).

One (1) signed original and ten (10) additional copies of the UFSAR, Revision 7, are being submitted to the Document Control Desk. In addition, one copy will be submitted to Region III and one copy to the NRC Resident Inspector. Changes associated with Revision 7 are annotated by revision bars in the appropriate margin marked with a "7 All revised pages are marked "Rev. 7 5/95."

In an effort to reduce costs associated with compliance with regulatory requirements (i.e., regulatory burden reduction) Detroit Edison is remosing 9505110122 950505 M PDR ADDCK 05000341 g3)7 K PDR g

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' May 5,1995 l

,- NRC-95-0043

- Page 2 controlled Edison drawings from the UFSAR. These drawings were originally provided in the Fermi 2 PSAR and FSAR to support the initial licensing process. l In subsequent UFSAR updates the current drawing revisions were copied and included after title blocks were applied. In the future the controlled Edison i drawing number will be referenced in the UFSAR text when a drawing is removed l from the UFSAR. Current Edison drawings will continue to be available to the  ;

NRC Senior Resident Inspector at the Fermi site. 1 To initiate this cost reduction effort, Revision 7 removes UFSAR Figures 9.2-1 ,

(sheets 1 and 2) and 9.2-12 (sheets 1 and 2) which are the P& ids for the General l Service Water (GSW) and Turbine Building Closed Cooling Water (TBCCW) systems. A summary of the Safety Evaluation for this change is included in the enclosed Safety Evaluation Summary Report. Detroit Edison estimates this initiative, when fully implemented, will lead to a cost savings of over $250,000 over the life of the plant.

' Also enclosed (Enclosure 2)is the Safety Evaluation Summary Report containing a brief description of safety evaluations performed for changes to plant design, procedures, tests, experiments, temporary modifications, and the UFSAR.

Ifyou have any questions, please contact Mr. Hari O. Arora at (313) 586-4213.

Sincerely, [

I Enclosures (2) cc: T. G. Colburn (wEnclosures)

J. B. Martin (wEnclosures)

M. P. Phillips (wEnclosures)

A. Vegel(wEnclosures)  !

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USNRC May 5,1995 NRC-95-0043 Page 3 I, DOUGLAS R. GIPSON, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

M DOUGLAS R. 3IPSON Senior Vice President On this tN day of , dt/' .1995 before me personally .

appeared Douglas R. Gipson, begin first duly Mvorn and says that he executed the I foregoing as his free act and deed.

I Notary Public HAW

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N A ARhumis A MARYPUBUCSTATEoF%

MONROE CDUNTY WCOMM56M EXP. NOV. M1993

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L Enclosure 1 to NRC-95-0043 Page1 LhS2?TICN OF CHANGES TO THE OUALITY ASSURANCE PELQJA4 INCORT ORAT"D IN REVISION 7 OF THE FERMI 2 UFS AR. SECTION 17.2

1. Organization changes were incorporated into Section 17.2 due to corporate and Fermi 2 site reorganizations that were implemented since the last QA program changes. The organization changes are to enhance communications and performance and to better align the organization for the future. Each change was ev.iuated for QA program effectiveness. The basis to concluding that the revised program continues to satisfy the criteria of Appendix B and does not reduce Quality Assurance (QA) Program  !

commitments can be summarized as: 1) no QA functions were eliminated, l and 2) the QA depanment continued to report to the same level of management.

2. Numbering and minor editorial changes were made for consistency with l UFSAR format and clarification.
3. Section 17.2.1.5 was revised to change qualificatiun requirements for the i Director - Nuclear Quality Assurance and Supervisor - Inspection and l Surveillance. This change reduced a commitment to ANSI /ANS 3.1-1978.  ;

NRC review and approval of this change was requested on May 14,1993.  !

NRC approval of this request was granted in an NRC letter dated September 8,1993. This change added flexibility while increasing the ,

experience requirements for the position. i i

4. Sections 17.2.2.5,17.2.18.2 and A.1.144 were revised to clarify that supplier QA programs may be audited and evaluated by another utility provided an agreement to include Detroit Edison scope of supply and requirements has been established. These changes were presented, for information, to the NRC by Detroit Edison and Illinois Power representatives on June 15,1993. These changes do not cease to satisfy  ;

the criteria of 10CFR50, Appendix B or reduce commitments previously )

accepted by the NRC because Detroit Edison scope of supply and  !

requirements are included. j l

5. NRC review and approval of the following changes was requested on l December 22,1994. Because the NRC approval of this request was I granted in an NRC letter dated March 9,1995, Detroit Edison has l l

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NRC-95-0043 -l Page 2 f

j incorporated these changes in Revision 7 of the UFSAR. However, these i!

changes have not yet been implemented but will be implemented during this year.

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(i)- Sections 17.2.2.2 and 17.2.2.2.1 were revised to:

  • Redescribe location of QA program description from portions  !

of FMP and FMDs to Section 17.2 of the UFSAR. '  !

e Describe Fermi Conduct Manuals as the administrative i

implementing procedures.

l e Mention the Conduct Manuals are endorsed by management in l Management Policy Statements. j

  • Describe approval for Section 17.2 and Conduct Manuals.

e Relocate and expands matrix of 18 criteria of 10 CFR 50 . l Appendix B from Section 17.2 to QA Conduct Manual.

(ii) Section 17.2.2.2.2 was deleted. With the consolidation of - 1 administrative implementing procedure tiers, this information is redundant to information now in Section 17.2.2.2, except for the j sentence regarding QA review ofimplementing procedures directly l or during audits or suiveillances, which was already redundant to .;

Section 17.2.6.  ;

t (iii) Section 17.2.2.2.3 was deleted. The startup test program was j completed. Therefore, the Staitup Manual procedures are no longer appropriate to discuss in the QA program.

9 (iv) In Section 17.2.2.8, deleted mention of preoperational and startup test programs since they are completed. 1 (v) In Sections 17.2.1.5.2,17.2.2.1.3,17.2.2.3,17.2.2.6 and 17.2.4.1 ,

revised references to FMP and/or FMDs, since they are eliminated.

(vi) In Section 17.2.3, deleted " departmental" when referring to design control procedures. The Conduct Manuals will be organized by functional areas rather than departments.

(vii) In Section 17.2.4.1, deleted that procedures are issued by responsible organizations. The Conduct Manuals will be issued

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r Enclosure I to Ll L NRC-95-0043 I c Page 3 centrally and are organized by functional areas rather than by organization.

(viii) In Section 17.2.5, the list ofprocedures is revised to reflect Conduct Manuals as being administrative implementing procedures, and to group technical procedures. The technical procedures previously listed in Section 17.2.6 are now listed in Section 17.2.5 instead, and Section 17.2.6 now mentions technical procedures and Fermi Conduct Manuals rather than list some procedures.

(ix) Tab!c 17.2-1 was deleted. As discussed earlier, the matrix is now referenced in Section 17.2 and is being located in the QA Conduct -

. Manual.

This change will reduce the challenges to procedure users and also add efficiency to the procedure revision process.

6. The following changes are a reduction in commitment. NRC review and approval of these changes to the Quality Assurance Program was requested on June 9,1994. NRC approval of the request was granted in an NRC letter dated August 5,1994.

(i) Section 17.2.16 was revised from " Nuclear QA or Safety Engineering reviews all corrective action documents to determine, when appropriate, that the root cause of the problem is identified and corrective action is adequate" to: " Nuclear QA or Safety Engineering reviews all corrective action documents which delineate significant conditions adverse to quality or safety and some corrective action documents for other conditions adverse to quality to determine, when appropriate, that the root cause of the problem is identified and corrective action is adequate."

The reason for this change is to improve the Corrective Action Program at Fermi 2. The need for improvements was identified during the Spring 1993 Corrective Action Program audit and NRC inspection of Engineering and Technical Support.

(ii) Section 17.2.18.3 was modified to state that significant conditions adverse to quality and selected non-significant conditions adverse to quality are followed up by Nuclear Quality Assurance to determine that they are effectively corrected and corrective action precludes repetitive occurrences. This change coordinates with the change to Section 17.2.16. More importance should be given to significant 2

P Enclosure I to l NRC-95-0043 i Page 4 }

conditions adverse to quality regardless of whether they are .  !

identified by the line organization or Nuclear Quality Assurance.

(iii) Section 17.2.1.5 was revised to coordinate with the changes m .

17.2.16 and clarify that Nuclear Quality Assurance recommends solutions to quality problems, rather than actually dictating or ,

implementing the solutions. Additionally, the revised wording l' clarifies that Nuclear Quality Assurance makes recommendations and verifies implementation of solutions for NQA identified ,

problems.  !

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