ML19225A367

Responds to NRC Ltr Re Violations Noted in IE Insp Rept 50-341/79-09.Corrective Actions:Will Develop Updated Welding Insp Certification for Personnel Required to Submit Results of Eye Exams

ML19225A367
Person / Time
Site:	Fermi
Issue date:	05/22/1979
From:	Hines E DETROIT EDISON CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19225A362	List: ML19225A367
References
EF2-46-143, NUDOCS 7907190092
Download: ML19225A367 (6)

Text

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Edward Hmes / /

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, Detroi.t Ecison - -

May 22, 1979 EF2-46,143 Mr. C. Fiorelli, Chief -

Reactor Construction and Engineering Support Branch U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Fiorelli:

Noncompliances at Enrico Fermi Unit II Construction Site This letter responds to the one infraction and one deficiency con-tained in your IE Report No. 50-341/79-09 This inspection of Enrico Fermi Unit II Construction activities was performed by Messrs. R. J. Marsh, K. D. Ward, and M. J. Corcoran on January 3 and 4, 1979.

Th e cited infraction and deficiency mentioned in your report 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.

No unresolved items were identified in your report. However, the concern expressed as to the action to be taken to assure that NDE s e rv i ces provided in the past, meet applicable requirements, is addressed in " Corrective Action Taken And Results Achieved" on page two, paragraph (b) of the enclosed report.

The enclosed report is arranged to corresp nd to the sequence of items cited in Appendix A of your report. Finding numbers have been assigned to both noncompliances and are referenced along with the allegation numbers from page four of the body of your report.

We trust this letter satisfactorily answers the concerns raised in your report. We shall be glad to discuss any further points that you may have.

Sincerely yours,

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RWE/pm Attachment cc: Mr. John G. Davis, Acting Director Office of Inspection and Enforcement Division of Reactor Inspection Programs U.S. Nuclear Regulatory Commission Washington D. C. 20555

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THE DETROIT EDISON COWANY Q'JALITY ASS 1'PANCE DEPAPDIENT

- ENRICO FEPMI 2 PROJECT Response to NRC Report No. 50-341/79-09 Docket No. 50-341 License No. CPPR-87 Inspection at: Ferri 2 Site, Monroe, Michigan Inspection conducted: January 3 and 4, 1979

/7 - /4 ;i Prepared by: Y- ' #

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h. A. Walker Site Project Q.A. Engi,eer Detroit Ediscn Company A

Approved by:

R. W. Barr Project Q.A. Director Detroit Edison Company

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Response to NRC Report # 50-341/74-09 Statenent of Infraction 79-09-01 Appendix A, Item

• 1 Allegations

• 1 and 2 Infraction: Contrary to 10CFR50, Appendix B, Criterion IX, measures were not sufficient to assure that welding and non-destructive testing activities were accomplished by qualified personnel. Improper qualifications were as follows:

a. A General Electri: individual was continuing to perforn liquid penetrant examinations after his Level II liquid penetrant certification had expired.

b. A Materials Assurance Company individual was performing liquid penetrant exaninations even though he did not have the experience, training, and an eye test as shown on his certification records and as required by ASME Sections III and V.

Corrective Action Taken and Results Achieved

a. e Certification was updated and sent to the site on January 4, 1974 e Generated NCR-II-121 dated January 17, 1979; DDR (W)2576 dated February 22, 10~ Th e s e listed the PT's and l'T 's per-forced by the individual during the period of lapsed certification. Proposed resolution was to accept toer based on individual's experience and the fact the lapse was only due to an administrative oversight. Th i s resolution was approved by GE-ISSE, Daniel, Detroit Edison, and the ANI.

b. Allegations 1 and 2 e The NDE parsonnel from Materials Assurance Company (MAC)

(identified as M-2, M-3), were removed from the site when it was known there was some question 'of their certification.

This was completed January 4, 1979 at Fermi, and all other sites February 28, 1979.

e A complete reaudit of MAC personnel certification documen-tation at another site was completed. Items checked were documentation on eye examination, certifications, including copies of examinations, work experience, and training.

This was completed February 15, 1979.

e In process audits were performed on M-2 and M-3 at another site. They were found to be technically capable of per-forming the NDE exacination to which they were certified.

Also, M-3 was completely re-certified including eye test and certi ication examination. Th e in process audits and examination were monitored by General Electric NDE Level III personnel. This was completed February 15, 1979.

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(cont'd)

Response to NRC Report 79-09 Corrective Action Takea and Results Achieved Cont.

e G.E.-16SE will develop a plan for the CE-I6SE Project Q.C.

Supervisor to evaluate the examinations previously per-formed by all MAC NDE personnel used at the Fe rmi II Site.

This plan will include a list of the welds to be re-inspected with the results to be evaluated. Also, the plan will include acceptance criteria for the renainder of the welds based on the results of the inspected welds.

NCR's/DDR's will be initiated to resolve unacceptable results. This plan will be submitted for Daniel / Edison approval by May 25, 1979 Re-inspection and evaluatio of hardware will be completed by July 13, 1979.

Corrective Action to be Taken to Avoid Further Noncompliance

a. e The individual will be re-instructed of the "requirenent of certification" as per I6SE PQ S000.

e A tickler file will be established in the Region Office to ensure the eye examination and certification will be performed at required intervals.

b. e A new NDE subcontractc- has been hired for the Fermi II Project. This subcont ractor has been subjected to a e re rigorous review which includes requiring proof of doc'c.en-tation for certification (cye examinations, certifice. ion examinations, work experience, and training). ThI was completed January 8 through 12, 1979 prior to their use on site.

e A letter will be sent to all site NDE subcontractors stating they must show proof of: eye examinations, work experience, training, and certification including copies of the examination. This will be accomplished by May 25, 1979.

e G.E. Corporate survey and site auditing systems will be improved. Personnel involved in these systems wi'l be instructed that the NDE company and their persont _1 re-porting to the site must show proof of documentation. This will include names and addresses of ' eye examiners , certifi-cation of prior work experience, proof of formal training (i.e. diplomas), and proof that certification examinations were performed by qualified personnel. This will be done on an individual case basis.

e The Materials Assurance Company has been removed from CE-1&SE's Approved Vendor List.

Date When Full Compliance Will be Achieve J

a. e The certification was updated and individual was reinstructed on January 4, 1979 on the requirement of ?Q 8000.

e NCR and DDR were completed on February 28, 1979.

e Tickler file will be completed on May 25, 1979.

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i Response to NRC Report

• 50-341/79-00 (cont'd)

Corrective Action to be Taken to Avoid Further Noncompliance cont.

5 e Materials As surance Compan y was removed from the Fermi 11 Site on January 4, 1979 - -

e Hiring and qualification of the new NDE contractor for the Fermi Site was completed en January 12, 1070 e The letter to site NDE suocontractors will be sent by May 25,

_ 1979.

e The improvements in the G.E. Corporate survey and site auditing system have been improved as stated. Additional improvements will be made as consi !ered necessary.

e The Materials Assurance Company was removed from the GE-I&SE Approved Vendor list on May lo, 1979.

e Disposition of hardware items tested by personnel whose certifications are in question will be completed by July 13, 1979.

Statement of Deficiencv 79-00-02 Appendix A, Item 4 2 Allegation

• 3 Deficiency: Contrary to 10CFR50, Appendix b, Criterion XVII, the Material Assurance Company NEE Specialist did not maintain records of an individual's test in Liquid Penetrant (PT) examination and that he was certified.

Corrective Action Taken and Results Achieved:

e A coc;'ete reaudit of MAC personnel certification documentation at another site was performed by GE-I65E. Itens checked were documentation on eye examination, certifications, including copies of examinations, work experience, and training. This was completed February 15, 1979.

e In process audits were performed on M-2 and M-3 at another site.

They were found to be technically capable of performing the NDE examination to which they were certified s Also, M-3 was c on.-

pletely re-certified, including eye test and certification examination. The in process audits and examination were moni-tored by General Electric NDE Level III personnel. This was completed February 15, 1979.

Corrective Action to be Taken to Avoid Further Noncompliance e A letter will be sent to all site NDE subcontractors stating they must show proof of: eye examinations, work experience, training, and certification including copies of the examination.

This will be accomplished by May 25, 1979.

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6 Response to NRC Report

• 50-341/79-09 (cont'd)

Statement of Deficiency 79-09-02 (cont'd)

Corrective Action to Taken to Avoid Further Noncompliance Cont'd e G.E. Corporate survey and site auditing systems will be improved.

Personnel involved in these systens will be instructed that the NDE company and their personnel reporting to the site must show proof of documentation. This will include names and addresses of eye examiners, certification of prior work experience, proof of formal training (i.e diploma-), and proof that certification examinations were performed by qualified personnel. This will be done on an individual case basis.

e The NDE personnel from Material Assurance Company (MaC) were removed from the site when it was known there was some question in their certification. This was completed January 4, 1979 at Fermi and all other sites February 2E, 1979.

e A new NDE subcontractor has been bired for the Fermi II Projec*-

This subcontractor has b e e i, aubjected to a more rigorous review which includes requiring proof of documentation for certification (eye examinations, certification examinations, work experience, and training). This was completed Januacy 8 through 12, 1979 prior to their use on site.

La t- When Full Compliance Will be Achieve d

.m: 1 Compliance will be achieved by Fay 25, 1979 p

tJU m of