ML20102A645

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-341/84-37.Corrective Actions:Electrical Circuits for Emergency Diesel Generator 11 Tested for Damage Associated W/Over Loading.No Damage Found

ML20102A645
Person / Time
Site:	Fermi
Issue date:	12/18/1984
From:	Jens W DETROIT EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20102A640	List: ML20102A639 ML20102A645
References
EF2-70221, NUDOCS 8502080492
Download: ML20102A645 (10)

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I Cyne H. Jens

. Ves Prssdent Nuclear Operatois -

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. Fermb2 6400 North Dixie Hghway Edison :=

oecember 18, 1984

.EF2-70221 Mr. James G.1Keppler Regional' Administrator Region III.

U. S.-Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Reference:

Fermi 2 NRC Docket No. 50-341

Subject:

Detroit Edison Response Inspection Report 50-341/84-37

'This letter responds to the items of noncompliance described in your Inspection Report No. 50-341/84-37..This inspection was conducted by Messrs. D. E. Hills, S. G. Du Pont, G. F.

O'Dwyer and Ms. P. R. Rescheske of NRC Region III between October l'and 26, 1984.

The items of noncompliance are 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-

compliances cited in the inspection report.

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

Sincerely, p

[HE t cc:

P. M. Byron.

'R. C. Knop USNRC, Document; Control Desk Washington D.C.

20555 hoMQ

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THE DETROIT EDISON COMPANY

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FERMI 2 NUCLEAR. OPERATIONS ORGANIZATION i

f RESPONSkTO.NRC.REPORTNO.: 50-341/84 37 y

DOCKET NO. 50-341 LICENSE NO.

CPPR-87 ta

' INSPECTION.AT:

FERMI 2', NEWPORT,, MICHIGAN INSPECTION' CONDUCTED:

OCTOBER 1 - 26, 1984 w

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RESPONSE. TO NRC INSPECTION REPORT NO.

50-341/94-37 m

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Statement of Noncompliance 84-37-01

-10 ' CFR - 50, Appendix B, Criterion V states that " activities

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Laffecting: quality shall be prescribed by documented instruc-i

~ tions, procedures, or drawings, of a type appropriate to the i circumstances and shall be accomplished in accordance with i

these instructions,' procedures, or-drawings."

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[ Contrary.toithe above, activities were not accomplished in

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v' 1accordance with Plant Operations Manual Procedure (POM)

.12.000.15 PN-21 (Nork Order Processing) which resulted in two separate occurrences of loss of configuration control.

In one' case, an abnormally open knife-type switch prevented

,a diesel generator from being loaded properly during routine surveillancentesting.

In another case, aut improperly' opened vent line resulted in a discharge of. water to the Reactor Building atmosphere during PRET (4100.001) Standby Liquid Control System, Testing.

' Corrective Action Taken and Results Achieved y

-The results of Detroit. Edison's investigation i nto these two

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occurrences-of ~1oss of configuration. control ana the correc-

'tive' action'taken are as'follows:

^G sAs stated inithe.NRC inspector's report, knife switch "RB"

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" in the ground connectionDfor the " wye" connected load meter

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.for Emergency-Diesel Generator.611 was found open.

This Jopen knife; switch caused the loadmeter to-indicate only a

. portion"(approximately 2/3 )f of L the actual load.during the -

performance of a surveillance procedure which.r'equired: load-2

~ing EDG filito greater than 2850: kilowatts (KW).

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LThe open! knife switch resulted in the inability to complete 1

Ja: surveillance test' on September n16,; 1984 r the same 'surveill ance test had'beenfsuccessfully completed on Augustfl9,- 1984.

LDetr'oit. Edison's investigationLrevealed that-only two1 tasks:

rs (which would put personnel in proximity.withLthe knife switch

werel performed:between the:datesiof-these surveillance-tests.

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_f Three independent <studiesJconcluded that neither of these'

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' tasks required.that the'loadmeter ground-connection knife..

i switch be opened.' These studies. consisted ofTreviews of.the C. - s <

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itagging deta'ils and work ~packagesLof the twoitaskst and' "4

Tincluded interviews,withfthe personnel-involved.

Each study

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concluded?thatineither: task =woul require the knife' switch ~

d to be; opened and that;it'.wascindeterminate as.to'why the-F

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switch =wasiopen.

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RESPONSE TO NRC INSPECTION REPORT NO.

50-341/84-37

~j Corrective ^ Action Taken and Results Achieved-(Cont'd)

The electrical circuits for EDG #11 were tested for damage Lass ~ciated;with overloading; no damage was found.

The sur-c o

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,veillance procedure which required loading EDG #11 was then

-repeatedysuccessfully.

(During the -course of the Standby Liquid Control initiation test,'theivent. isolation valves were'left open and vent cap (was.not installed due~.to the failure to use an abnormal lineup. sheet.. The test-required the replacement _of the squib assembly ~ for valve C41-F004A.

This task required vent-

'ing_and draining a portion of the system.

The personnel

g involved failed to. document the vent path valve lineup on an abnormalilineup sheet (ALS) and_ subsequently failed.to inform-the personnel who finished the work on the next shift.

Subsequently, the test was completed successfully.

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Corrective Action Taken to Avoid Further Noncompli_ance

'During the.^1ntestigations related to this item of non-compliance, Detroit' Edison concluded that more explicit guidance..on:the use-of the ALS was appropriate.

A change

.has been' issued to POM 21.000.01, " Shift Operations.and bi

-Control' Room" to clarify-when the.use-of an ALS is_ required.

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'In addition,-' personnel involved in-the squib replacement-

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wereicounselled by-their supervisors _on the purpose and

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importance of the-ALS,fand keeping the Shift-Supervisor

.-informed oflplantistatus was discussed at the next Startup

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Test-Group meeting.

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Date When Full Compliance Will Be Achieved 4

' Full" compliance,hasibeen; achieved.

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RESPONSE-TO NRC INSPECTION REPORT NO.

50-341/84-37 Statement of Noncompliance 84-37-02 H

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In lthe DECO 'FSAR Appendix A[ Detroit Edison Co. commits to

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the-requirements of Regulatory Guide 1.30 which endorses asia method of satisfying'the-require-

. ANSI N45. - 2.4-19 72 1

ments of 10 CFR 50,. Appendix B,,. Criterion ~XI.

As/imple-

. mented in;part by Plant' Operations Manual Procedure (POM) e 12.000;25T Interim Temporary Modifications Procedure, ANSI N45. 2. 4 -19 72 - states-that " temporary electrical connections,

-temporary piping sections, abnormal chemical solutions, unspecified setting of devices, the fixing of a moving com-s ponent,..or the effecting of any other abnormality if made l

tpreviously shall be rectified before final ~ testing except in icases where fuel loading or other critical operations

prevent using the complete assembly for test.

In these instances, a documented notice shall be prepared stating the substitutions'that existed for the test."

(Contrary to.the above, during.PRET A8100.001 ECCS Integrated s.

Testing, licensee personnel failed to identify the entire function of a-temporary modification which resulted in inoperative reactor. vessel ~ low-level isolation logic for the

. Torus Water Management System Isolation _. Block Valves which

was required to be functional-for-the test.

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Corrective Action'Taken and Results Achieved c

The :cause of the Sta'rtup, Test Engineer's (STE) failure to

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g, cidentify the entire function of: Temporary Modification (TM)

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1 No. 84-0201 has been determined to be' inadequate. preparation

andireview of the TM Record (TMR) form.

This TM was e

, originally issued as No. 365 in--Ja1uary 19 83 but was -

,re-issued:as No.84-201 after..the TM procedure wastrevised.

The. spec'ific; problem was;that the " Reason.for'Modificatio'n" a.

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section~of TMR-No. 84-0201~-identified'only thatTthelTM bypassed sump level switches-in'the containment--isolation logici itEfailed to: identify that'the.TM'also'was intended AL

.to and'did bypass-thefLow-Reactor Water Level and High.

'Drywell Pressure trip:for:the 8 containment' isolation valves

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the: Torus Water Management: System (TWMS).

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When..ECCS Integrated Tes't results indicatedith'at the'TWMS containmentiisolation~ valves-failed to clos'e:on a low:

reactor

water; 1evel signal, - the - problem e was - traced z to

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tags'4fandL5lof!TMR'84-201. LThe. jumpers assoc'iated-with-4 c4 x; ~

1tagsj4 Lands 5 were removed and all 8' valves were verified to:

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ioperateion a' low-reactorfwaterflevel isolation signal.

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~ RESPONSE $TO NRC INSPECTION REPORT NO.

50-341/84-37

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Corrective Action Taken and Results Achieved (Cont'd)

Regarding a<different Preoperational Test, an NRC Inspector reviewed Test. Exception 5 Disposition Report (TEDR) No. 4 to b,~

PRET. E1100.001 whichl addressed a missing "hard wired" V jumper.

It should be noted that the term "hard wired"

. ', jumper; refers to a= wire that is part of.the cabinets-designed. wiring.

At his exit interview on November 29, u

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. 1984,ithe NRC Inspector requested that Detroit Edison report

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Lthe; status'of this item in this report.

Detroit Edison has C J

'researchedLthis matter but was unable to determine the cause

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of this-discrepancy.

The jumper has been replaced to p.

conform to Drawings 6I721-2095-27 and 6I721-2095-28 and the f

,Preoperational Test.has been completed successfully.

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should:be noted that this discrepancy was. identified and

. corrected during the normal course of the Preoperational r

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. Test Program.-

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" Corrective Action Taken-to Avoid Further Noncompliance Plant; Operations-Manual-(POM) Procedure 12.000.25,

- " Temporary Modifications"'is-currently-being reviewed for.

approval; fit will replace'the current procedure 12.000.25T.

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'The new procedure incorporates many of the practices of-

,LInstitute of Nuclears Power Operations ~(INPO)'OP-202.

(Specific features of the new. procedure include n

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foi The requirements for the use of Jtemporary modifica-tionstare.more stringent.. Reflecting this change,-

R the TMR form requires more-explicit justification for'and description;of-the temporary. modification.

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,Each temporary modific'ation11s'to'be installsd in-

'o raccordance with POM 12.000.15, "PN-21 (Work Order)

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Processing."

This ensures.an additional'verifica--

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. tion of'the's_afety-related classification.

Safety-related work orders are: reviewed?by' Nuclear A" x 4

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Quality. Assurance ^to determinelinspection ~

requirements..

x c o.'.The Fermi 2 Technic'al. Engineer / designee will ensure that-Temporary Modifications;for' safety.-

' "G.} g 1related systems or components' receive'al safety.

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evaluation-(10CFR'50.59.);

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FPersonnaliresponsible for tihe_ preparation, ' review or appro-l c

svalLof_ Temporary Modifications will.be. trained to the

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Jrequirements'of,POM' 12.000.25..

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RESPONSE TO NRC INSPECTION REPORT NO.

50-341/84-37 Corrective Action Taken'to Avoid Further Noncompliance (Cont'd)-

.Upon activation ~of POM 12.000.25, existing temporary modifi-

! cations:will be reevaluated to ensure their compliance with

the-new procedure.

.'Date When Full Compliance Will Be Achieved

Full. compliance will-be achieved when POM 12.000.25,

- Temporary Modifications" is approved and activated.

This factivity will.be complete prior to fuel load.

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l RESPONSE TO NRC INSPECTION REPORT NO.

50-341/84-37 Statement of Noncompliance 84-37-03 10CFR.50,- Appendix B, Criterion XVI states in part that "in the.. case of significant conditions adverse to quality, the measures shall. assure that the cause of the condition is determined and' corrective action taken to preclude repeti-

- tion".

Contrary to the~a'bove', corre'etive action for 50.55(e) Item J

-o 127 was: inadequate in that the physical and administrative controls instituted to prevent re-entry of foreign material into the Residual Heat Removal Service Water reservoirs were

! ineffective.

(Corrective Action Taken and Results Achieved-

. In May 1984,-Detroit Edison reported the discovery of debris in'the Residual Heat' Removal Service ~ Water (RHRSW) Reser-

.voirs as110LCFR 50.55(e) Item 127.

The immediate corrective

. action included draining and' cleaning the reservoirs, stricter enforcement of-the Project. Cleanliness Control pro-

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.cedures-:in the RHR Complex and improved control of the access'to the open areas above the RHRSW reservoirs.

Additionally,, recognizing the difficulty of maintaining the cleanliness of large-open areas during the construction m

. phase, Detroit Edison committed'to drain and inspect both

-RHRSW res'ervoirs when construction was complete.' -During the-

. fulfillment-of : this commitment. in October of 1984, addit-Lional debris was. discovered in-~the reservoirs.-

Conse-i guently, the roof and'areangratings above the reservoirs y,

aware thoroughly cleaned and-both reservoirs were cleaned and-J 1 refilled.

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Corrective ActionfTaken to Avoid-Further-Noncompliance

The.possible sources of debr'is1 include:. ineffective clean-

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sing:and inspection when the reservoirs were 1ast. drained,.

construction: activities onlthe roof,of the RHR complexf and 7

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" sources:from nature.

Each of these possible sources has~

been: evaluated, and Detroit Edison"has concluded that the

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-most probable source.was. ineffective' implementation 1of

, housekeeping proceduresJduringjconstruction. activities on:

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, e-e RESPONSE'TO NRC INSPECTION REPORT NO.

50-341/84-37 s

-Corrective Action Taken to Avoid'Further Noncompliance (Cont'd)

The completion of construction-in the RHR Complex has sig-

.nificantly reduced.the traffic and activities in the areas Labove the open~ reservoir.

Additionally, implementation of t

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security controlled access from the RHR Complex to the areas above the reservoirs has limited -access to the areas where debris!could-be introduced into the reservoirs.

Detroit Edison.is also taking th'e following actions to pre-1 vent recurrences o

The requirements in POM Procedure 12.000.48, " Plant Housekeeping" for, Zone III Cleanliness areas will be enforced for the roof and reservoir areas.

During main-ctenance or modification activities in these areas, the cleanliness classification of the reservoir will be upgraded from'. Class D to Class C.

Signs will be posted on the-RHR roof area stating the cleanliness classifica-tion and requirements.

o Cleanlinesss control for maintenance and construction activities in.the areas above the reservoirs and in the

-reservoirs will be accomplished by cleanliness controls

.in.the work packages.

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.An awareness program.will.be developed 1which will in-struct.the. craft personnel on cleanliness and housekeep-

-ingirequirements for those-working the RHR complex, including;the roof.

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o' Detroit Edison"will perform an svaluatiOn of any item-known to have fallen into the RHRSWireservoirs and.not

< removed.

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i Date-When Full Compliance Will Be Achieved.

YFull compliance'will-be achieved prior to fuel load.

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- s k' sRESPONSE TO NRC. INSPECTION. REPORT NO.

50-341/84-37 t

Statement of Noncompliance 84-37-04 c

f l0.CFR 50, Appendix B, Criterion V, as implemented by DECO

- Qualityi Assurance Manual, QAP 9, requires that activities

?affecting: quality shall be prescribed by appropriate written

.' instructions and procedures.

Contrary to. the above, Reactor Engineering Procedure

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" Shutdown Margin Check", was not appropriate in

'thatithe calculational methods necessary for the determina-tion of shutdown margin were inadequate.

Corrective Action Taken and Results-Achieved The procedure for the shutdown margin check requires that the results of several in'termediate calculations be substi-tuted;into'the-final. equation for calculating the shutdown margin.

In_this final equation, the intermediate values are identified.by the step of the procedure in which the inter-mediate'value is calculated.

When a new step was added to

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the procedure.and th'e following steps were re-numbered, an oversight resulted in the final. equation not being modified to account for the change in the numbering of the steps.

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.Thisferroriin.the procedureJwould not have-resulted'in-the calculation of=an erroneous value for the shutdown margin; butiitlwould have prevented the operator from performing the calculation..

l LThe' author of the change and the reviewers failed to recognize thatlindividual steps.had to be revised to. reflect

.the renumbering'ofLprevious steps.- Reactor Engineering

. Pro'cedure~54.000.01,J" Shutdown-Margin' Check" has been

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, revised-to correct-this error.

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! Corrective Action Taken to Avoid Further Noncompliance p

LAt.the' time of.the.NRC inspector's observations, Detroit-Edison was:already taking aggressive action-~to improve the procedure: review and approval process.

-As, discussed.in.the b%P respon'se,to.NRCfIn'spection Report:84-20, on: October 11, 1984,.

1. m aidetailedisurveillancefof the procedure preparation and J%s

' review; process was conducted:by Nuclear Quality Assurance.

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_.Thef surveillance,. No.. S-QA-P-84-722, 'was designed to* deter-nainelwhether.or not the? review process as'specified in POM

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"E iProcedure. 12~.000;07,7 " Plant Operations ~ Manual Procedures"

.x zand Power Plant Ordert(PPO) EFP-1053 " Responsibilities for

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Reviewing ; Plant Operations Manual Procedures" is ef fective.

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. W. s RESPONSE TO NRC INSPECTION REPORT NO.

50-341/84-37 Correct'ive Actiori Taken to Avoid Further Noncompliance E

(Cont'd)-

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As a" result of this' surveillance, Detroit. Edison has placed

- special emphasis;on' improving the development and review of plant; procedures.

This effort is being focused by a

-thorough review and revision to POM 12.000.07, " Plant _ Opera-tions. Manual Procedures," which governs'the development and 4

approval of plant procedures.

Specific improvements which address preventing the types of errors identified by the NRC

- inspector include:-

o-Each safety-related procedure or change as identified

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in the approval column of the POM Index (i.e..SR) will be ~~ assigned-to a. technical reviewer who is not the author.

This reviewer will check for the technical'-

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. adequacy and correctness of the procedure.

The reviewer will sign the coversheet showing approval prior to~ submission of the procedure to the On-Site g:

. Review Organization (OSRO) for final approval.

o Power Plant-Order (PPO) EFP-1053'has been revised to incorporate _ practical guidelines for procedure prepara-tion and review.

These guidelines will be consistent with-and supplement.the requirements of POML12.000.07.

Date'When Full Compliance Will be Achieved

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Full compliance has_';been achieved."

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