ML19254E854

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Responds to NRC 790828 Ltr Re Violations Noted in IE Insp Rept 50-341/79-16.Corrective Actions:Qa Engineer to Approve All Releases for Pipe Support Installation
ML19254E854
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 09/28/1979
From: Hines E
DETROIT EDISON CO.
To: Fiorelli G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19254E853 List:
References
NUDOCS 7911020411
Download: ML19254E854 (7)


Text

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Edward Hines Ass stani vice P es. cent Ovant, Aswance Detroit 3331 W B g Be ISOn ass"aprRoad **

September 28, 1979 EF2-46,349 s

. Mr. G. 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:

Subject:

Noncompliance at Enrico Fermi Unit II Construction Site

  • This letter responds to the infraction contained in your IE Report No. 50-341/79-16. This in:;pection of Enrico Fermi Unit II Site Construction activities was performed by Mr. I. T. Yin on August 1-3, 1979.

Only the cited infraction c.entioned in your report is disct.ssed 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 unresolved item has been acted on. We will be prepared to report in detail on our progress and corrective action on this matter to your inspectors on their next visit.

The enclosed response is arranged to correspond to the sequence of items cited in the body of your report. The finding numbers from the report are referenced as well as the section numbers.

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, 129 Attachment ec: Mr. John C. Davis, Acting Director Office of Inspection and Enforecuent Division of Reactor Inspection Programs U.S. Nuclear Regulatory Commission Washington D.C. 20555 1252 034 OCT 4 1979 79110*

THE DETROIT EDISON COMPANY QUALITY ASSURANCE DEPARTMENT ENRICO FERMI 2 PROJECT ,

Response to NRC Report No. 50-341/79-16 Docket No. 50-341 License No. CPPR-87 Inspection at: Fermi II Site, Monroe, Michigan Inspection conducted: August 1-3, 1979 Prepared by: ,

. 4C- v H. A. Walker Site Project Q.A. Engineer Approved by: g, R. W. Barr Project Q.A. Director Detroit Edison Company

). ) .

'. Response to NRC Report #50-341/79-16 Page One ,

Statement of Infraction 79-16-01 Appendix A:

Pages 3-5 paragraphs 1 (a-k)

Infraction: Contrary to 10CFR50, Appendix B, Criteria XVI, the deficiencies s identified relative to the installation of safety related hangers had not been corrected from November, 1978. In addition, the corrective action to avoid recurrence and to allow lifting of two previously issued stop work orders dated September 8, 1978 and March 15, 1979 were ineffective in stopping similar problems from recurring.

Corective Action Taken and Results Achieved Item la:

The work releases for the numerous safety related hangers previously released for installation were rescinded during the inspection. .

Corrective Action to be Taken to Avoid Further Non-Compliance Item la:

A program has been implemented which requires the Edison Site Project Quality Assurance Engineer to approve all releases fer pipe support installation. There are to be no more than ten (10> large bora, twenty (20) small bore, and twenty (20) instrumentation and control supports being installed at any one time. In addition, Edison Letter F2S9-1406 dated August 21, 1979 and Danic1 Letter DIC9-5667 dated August 24, 1979 describe the various methods used to identify, control and maintain QA Level I Supports. These letters are available on Site for your inspectors to rev:ew on their next inspection.

Date When Full Compliance Will Be Achieved Item la:

The control system described aanve has been implemented.

Corrective Action Taken and the Results Achieved Item Ic:

WB-Q-ll2 has been revised to show those categories of deficiencies used during inspection of hanger per form EF-136 in WB-C-Il4. A new treri analysis is being developed to meet the new categories which appear in WB-Q-ll2.

Corrective Action to be Taken to Avoid Further Non-Compliance Item Ic:

Future trend analysis will meet the WB-Q-ll2 requirement.

- 1252 036

Response to NRC Report #50-341/79-16

. Page Two Da*e When Full Compliance Will Be Achieved Full compliance will be achieved by October 2, 1979.

Corrective Action Taken and the Results Achieved s

, Item Id:

The subject drawings will continue to be released showing " clouds" around areas requiring fabrication / installation changes. These drawings will be reviewed by the joint Daniel-Wismer and Becker field hanger engineering task force. The task force will provide additional specific written work direction, as appro-priate, in order to direct the craf te who perform the work. This direction is provided on the work assignment sheet which forms a part of the hanger traveler.

Corrective Action to be Taken to Avoid Further Non-Compliance Item Id:

By providing adequate direction on the work assignment sheets, the craft will have the necessary information available for future modifications of hangers.

Date When Full Compliance Will be Achieved item Id:

The method described above has been implemented.

Corrective Action Taken and the Results A .eved Item le:

Hanger P44-3189-G16 was inspected as of August 29, 1979 and accepted by Q.C.

Further steps are being taken to revise WB-C-114 to show how the hanger is turned over to Q,C. for inapc: tion.

Corrective Action to be Taken to Avoid Further Non-Compliance Item le:

The problem appears to be a lack of clarification regardit.g the timing of turn-over of + *) anger from construction to Q.C. The steps being taken to resolve this mattgr are:

a. A training session is to be held which will specify that hangers are to be released to Q.C. for inspection within five days follcwing con:ietion of installation.
b. An Interim Change to procedure WB-C-114 will be prepared to incorporate that time limit.

. 1252 037

', Response to NRC Report #50-341/79-16

t. Page Three Date When Full Compliance Will Be Achieved it<m le:

The first raining ces son was hel3 on September 26, 1979. The Interim Change to WB-C-ila is expected to be appre 'd by October 5, 1979. ,

- Co" recti etion Taken aid the Results Achieved Item if:

Traveler packages have been reviewed to ass tre that those released for construc-tion are complete. This review was initiaced September 8, 1979. The packages are being initially reviewed by Wismer and Becker and Daniel. This review includes Q. A. , Q.C. , Engineering and Construction eersonnel. Individuals within the construction groups have been designated to co..*inue this effort.

Corrective Action to be Taken to Avoid Further Non* Compliance Item lf:

Traveler package procedure WB-E-109 was revised to clarify package contents and was formally approved the week of 9/17/79. A training class has been held and the procedure is released for construction. In addition, the Traveler package detail for QA-I hangers is being revised to clarify work.

Date When Full Compliance Will Be Achieved Item if:

The ongoing review of packages will continue until work is complete. The revised Traveler package procedure will be fully implemented by October 1, 1979.

Corrective Action Taken and the Results Achieved Item Ig:

The responsibility for verification of work performed, to Field Modification Requests (FMR's) has been delegated to the Daniel Discipline Managers by Edison.

The contractors have been instructed to develop procedures to accomplish this FMR Verification and submit them to Daniel for approval- On September 12, 1979 L.K. Comstock's FMR procedure was approved for implerentation.

Corrective Action to be Taken to Avoid Further Non' Compliance Item Ig:

Procedures will be developed by the necessary site contractors and implemented to assure all work completed per QA Level 1 FMR's is inspected and approved by a QC organization. Procedural conflicts resulting from changing the responsibi-lity of PSR inspection from Edison Field Engineering to the various site QC organizations will be corrected. ,

a Response to NRC Report #50-341/79-16 Page Four Date When Full Compliance Will be Achieved Item ig: Full compliance will be achieved in a continuing process as contractors' procedures are approved and implemented. All necessary procedures are expected to be com-pleted by December 3, 1979. Corrective Action Taken and the Results Achieved Item lh: All non-installed Q.A. Level I fabricated support assemblies have been segregated and placed on hold. A 100% Q.C. inspection will be conducted to verify configura-tion prior to release from hold. Corrective Action to be Taken to Avoid Further Non-Compliance Item lh: For non-delivered supports, a 100% source inspection will be conducted until confidence has been established in the various manufacturers / fabricators.

       ,Dare When Full Compliance Will be Achieved Item lh:

The policies described above have been implemented. I, 1252 039

a ( tesponse to NRC Report #50-341/79-16 Page Five Corrective Action Taken and the Results Achieved Items li anc lj: As discussed with your inspector subsequent to the inspection, Quality Assurance Level I strut assemblies presently designed with " drive fit" load pin holes will be re-designed based on the latest available loading informatioa. The re-design

     - effort will incorporate struts with spherical end bearings. These bearings will be equipped with close fitting load pins or cap screws. Special care will be taken both in design and installation / inspection to insure that threaded por-tions of load pins or cap screws will not be in the load path.

Corrective Action Taken to Avoid Further Non-Compliance Items li and lj: Implementation of the actions indentified above will be sufficient to prevent simi-lar type discrepancies in the future. Date Whe1 Full Compliance Will be Achieved Items li and lj: The redesign effort will be a continuing activity with completion scheduled prior to fuel 1x' ding. Corrective Action Taken and the Results Achieved Item ik: A review of the hanger sketch in question was made by Engineering. It was deter-mined that the complete dimension description for the lug in question is provided in the Bill of Material that accompanies the sketch ( " x 4" x 3" pipe lug). The single 4-inch dimension for the lug shown on the sketch was provided only for the purpose of depicting the proper orientation of the lug on the pipe. A review of item 103 lug retainer indicates that the lug retainer was properly chosen for the application; that is, its load rating and dimensional configura-tion are compatible with the subject special lug. Corrective Action to be Taken to Avoid Further Non-Compliance Item ik: Additional corrective action is not required. Date When Full Compliance Will be Achieved Item ik: Full compliance has been achieved. 1259 040

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