ML19261B877

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Responds to NRC Ltr Re Violations Noted in IE Insp Rept 50-341/78-18.Corrective Actions:Instructions Given to Assure Liquid Penetrant Matls Removed After Insps
ML19261B877
Person / Time
Site: Fermi 
Issue date: 02/06/1979
From: Hines E
DETROIT EDISON CO.
To: Heishman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19261B873 List:
References
EF2-45-613, NUDOCS 7903070463
Download: ML19261B877 (6)


Text

Edward Hines Au s'a": V c t Mm e OsaM, Ass /a ce Edison m'e+a.c Aca?

333 AB3B February 6, 1979 EF2-45,613 Mr. R. F. Heishman, Chief Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Roao Glen Ellyn, Illinois 60137

Dear Mr. Heishman:

Noncompliances at Enrico Fermi Unit 2 Construction Site This letter responds to the two (2) infractions and one (1) deficiency contained in your IE Report No. 50-341/78-18. This inspection of Enrico Fermi Unit 2 Site Construction activities was performed by Messrs.

H. S. Phillips, C. M. Erb, K. R. Naidu, and H. M. Wescott on November 13-17, 1978.

Only the cited infractions and one 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. The unresolved items have been acted on.

We will be prepared to report in detail on our pregress and corrective action en these matters to your inspectors on their next visit.

The enclosed response is arranged to correspond to the sequence of item-cited in the body of your report. 'Ihe finding numbers from the report are referenced as well as the section numbers and subheadings.

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

Very truly yours, b/dvs'

/pm Encl.

90307oqn

EB 121979

THE DETROIT EDISON COMPANY QUALITY ASSURANCE DEPARTMENT ENRICO FERMI 2 PROJECT Response to NRC Report No. 50-341/78-18 Docket No.50-34I License No. CPPR-87 Inspection at:

Fermi 2 Site, Monroe, Michigan Inspection conducted:

November 13 through 17, 1978 Prepared by:

H A. Walker Site Project Q.A. Engineer Detroit Edison Company Approved by:

. W.

rr Project Q.. Director Detroit Edison Company

Response to NRC Report No. 50-341/78-18 Statement of Infraction 78-18-02 and 78-18-09 Appendix A, Item 1:

Section I, Paragraph 3b (78-18-02)

Section III, Paragraph 5b (78-18-09)

Infraction: Contrary to 10 CFR 50, Appendix B, Criterion IX, which requires nondestructive testing be con-trolled and accomplished by qualified personnel using qualified procedures, five instances were found after Liquid Penetrant (PT) exa~minations had been made, the penetrant and developer had not been removed.

This was a violation of G.E.

I. & S.E. Procedure NDE-PT-1002, Revision 3, dated August 2, 1978. One instance was identi-fied where no test report had been completed or nonconformance tag attached.

Corrective Action Taken and Results Achieved Section I, Paragraph 3b, Item 1:

An investigation of the problem revealed that the subject penetrant inspection was an in process (information) inspec-tion, which is not used as a final acceptance inspection. As an information only examination, no documentation of the re-sults is required.

Information only examinations are not per-formed by Q.C. personnel; however, a final Liquid Penetrant examination follows when production people feel that the area is ready for final inspection.

Q.C. inspectors are called to perform the final P.T., which is documented on a Liquid Pene-trant Materials and Process Data Sheet.

Since the final NDE inspection had not been made, no nonconformance report or tag was required.

It is the normal practice to leave +.he inspection results in order to identify an area which requires additional process-ing within the scope of task's documents (FDI 50-33800). The processing of the nozzle was not immediately resumed after the P.T., which resulted in the P.T. material remaining on the nozzle for an excessive amount of time. The inspector notified G.E. and the subject area was immediately and cor-rectly cleaned.

Section I, Paragraph 3b, Item 2:

The penetrant stains which extended down the wall of the Vessel Wall were the result of a small penetrant spill which had not been cleaned off due to insufficient scaffolding in the area.

The operator could not safely remove all the spill-Response to N"E Report No. 50-341/78-18 Corrective At. ion Taken and Results Achieved (cont'd)

Section I, Paragraph 3b, Item 2 (cont'd) ed penetrant, so it had to be left until adequate scaffolding could be erected.

Since the necessary scaf folding had been installed, the stain was removed immediately, after being p inted out by the inspector.

Section I, Paragraph 3b, Item 3:

The residual penetrant solution near the bottom of the Vessel 0 azimuth was found to be washdown from a at approximately 350 jet pump adaptor inspection, which had been inadequate,1y clean-ed on post final inspection.

The subject area was immediately and correctly cleaned after the inspector's notification of the problem.

Section I, Paragraph 3b, Item 4:

The jet pump adaptor veld had recently been repaired due to a radiographic inspection deficiency, which required that the final P.T. be re performed and recorded. The area was immedi-ately and correctly cleaned af ter the inspector's notification.

Section III, Paragraph 5b:

Rework of the welds at the bottom of the standpipes on the Steam Separator had been recently completed and 100% P.T.

examination made. Upon notification by the Region III inspector, the 11 standpipe welds which had not been cleaned were immediately and correctly cleaned.

Corrective Action Taken to Avoid Further Noncompliance All G.E. I. 6 S.E. NDE inspectors, Q.C. personnel, and pro-duction personnel have been given further instruction to assure P.T. materials are completely and properly removed after inspections have been completed.

Date When Full Compliance Will Be Achieved All the subject areas of noncompliance have been corrected.

Response to NRC Report No. 50-341/78-18 Statement of Infraction 78-18-03 Appendix A, Item 2:

Section I, Paragraph 3e Infraction: Contrary to 10 CFR 50, Appendix B, Criterion XIII, one swing check valve in the RHR Building and two check valves in the Reactor Building were not ade-quately stored, protected, or controlled in accord-ance with work and inspection instructions to pre-vent damage or deterioration.

Corrective Action Taken and Results Achieved Action has been taken to replace all missing end caps and tape any holes that may exist in end caps of valves. The miscellane-ous metal has been segregated from the valves.

Corrective Action Taken to Avoid Further Noncompliance 1.

Wismer and Becker will provide specific instructions to foremen at the next training meeting emphasizing storage requirements for Q.A. Level I valves.

2.

Wismer and Becker Q.C. will increase their surveillance of storage requirements.

3.

WB-C-102 will be revised to clarify the requirementa con-cerning end caps.

Date When Full Compliance Will Be Achieved Full compliance will be achieved on March 15, 1979.

Response to NRC Report No. 50-341/78-18 Statement of deficiency 78-18-05 Appendix A, Item 3:

Section I, Paragraph 5.C (1)

Deficiency: Contrary to 10 CFR 50, Appendix B, Criterion XVII records, which establish minimum qualifications for personnel who perform quality assurance func-tions, such as visual acuity tests, were not available for one Civil Q.C. inspector.

Corrective Action Taken and Results Achieved Daniel Procedure AP-VII-01, entitled " Selection. raining and Indoctrination of Quality Control Personnel" reibes the method of qualifying and examining Danie' q.C. personnel who perform inspection activities.

During a previous NRC audit in Mc;,

i77, it was noted that the requirement for administering eye examinations to Q.C.

personnel (other that NDE inspectors) needed further clarific-ation. This was identified as an unresolved item at that time.

Subsequently, AP-VII-01 was revised to state: "q.C. personnel shall be required to have an eye examination prior to perform-ing surveillances or inspections. Personnel shall be re-examined on an annual basis".

The unresolved item was closed, based on this Revi.sion.

The Daniel Safety /First Aid Department was given the responsi-bility to have these examinations conducted and had a more complete set of records than the Q.C. Department. A review of their records by Daniel Q.C. disclosed that the individual in question had an eye examination on June 16, 1977, as well as June 9, 1978. This record, along with others pertaining to eye examinations for Daniel Quality Control personnel, have been removed from the Safety-First Aid Department Records, verified by the Daniel Q.C. Services Supervisor as being current,

and are now on file in each individual's record. Henceforth, the Daniel Q.C. Services Supervisor will maintain these records.

Corrective Action Taken to Avoid Further Noncompliance We feel that since Procedure AP-VII-01 has been revised to clarify the requirement for eye examinations and current records are on file for Daniel Q.C. inspection personnel, that further corrective action is not required.

Date When Full Compliance Will Be Achieved Full compliance was achieved upon verificatisn of all Daniel Q.C. personnel records.

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