ML19261D719

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Responds to NRC Ltr Re Violations Noted in IE Insp Rept 50-341/79-07.Corrective Actions:Wisner & Becker Procedures Were Modified
ML19261D719
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 05/04/1979
From: Hines E
DETROIT EDISON CO.
To: Fiorelli G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19261D714 List:
References
NUDOCS 7906260108
Download: ML19261D719 (5)


Text

.

Edward Hine:

Ass s my m. .r ..

$ c c en s a .,,

Edison 5EJE="

May 4,1979 EF2-46,134 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:

Noncompliances at Enrico Fermi Unit II Construction Site This letter responds to the infraction contained in your IE Report No. 50-341/79-07. This inspection of Enrico Fermi Unit II Site Con-struction activities was performed by Mr. I. T. Yin on March 14 -

16, 1979.

Only the cited infraction mentioned in your report is 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 progress and corrective action on these matters 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 satisf actorily answers the concerns raised in your report. We shall be glad to discuss any further points that you may have.

Sincerely yours,

-r Encl.

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/ 1 0 1979 7 9 0 6 2 6 0\cS

THE DETROIT EDISON COMPANY QUALITY ASSURANCE DEPARTMENT ENRICO FERMI 2 PROJECT Response to NRC Report No. 50-341/79-07 Docket No. 50-341 License No. CPPR-87 Inspection at: Fermi 2 Site, Monroe, Michigan Inspection conducted: March 14 - 16, 1979 Prepared by: . M H. A. Wa er Site Project Q.A. Engineer Detroit Edison Company Approved by:

R. W. Barr Pro'ect Q.A. Director Detroit Edism Company 2313 048

Response to NRC Report # 50-341/79-07 Statement Of Infraction 79-07-03 Appendix A " Notice of Violation" Paragraph 3, " Review of Hanger Installation Program" Infraction: Contrary to 10CFR50, Appendix B, Criterion XVI, adequate measures were not established to assure that conditions adverse to quality, such as deficiencies and nonconformances relative to the installation of safety-related pipe hangers, are promptly identified and corrected.

Corrective Action Taken and Results Achieved Following the issuance of a new Stop Work Order by Wismer and Becker on 3/15/79, a Wismer and Becker Corrective Action Plan was initiated as follows:

a. Wismer and Becker Procedures were modified to incorporate the fol-lowing requirements:

(1) WB-0-112 Discrepancy Trend Analysis and Reporting. Revision 3 approved on 4/26/79 was issued to include requirements for Trend Analysis of Q.A. Level I Support Installation. A monthly Trend Analysis will be performed by Wismer and Becker Project Quality Manager using the information on the Hanger / Support Checklist (Form EF-?' 5) included as part of WB-C-114. In addition to Wismer and Becker Corporate Quality Assurance personnel, copies of the Trend Analysis Reports will be supplied to Daniel and Edison Management.

(2) WB-C-ll4 and WB-C-128 - Q.A. Level I Support Installation. A re-vision of these procedures was issued to include the following requirements:

(a) The Support Installation Inspection will be performed by Wismer and Becker Quality Control within 10 days following the date the Wismer and Becker Project Superintendent ad-vises the W&B Project Quality Manager of the support's com-pletion status as indicated on the operation process traveler.

The support Installation Inspection will NOT as part of its acceptance criteria include the following items:

Final Adjustment on Alignment Weldo Final Tightening of Threaded Parts The Installation of the Piping NOTE: The items above will be reviewed during final inspection.

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Corrective Action Taken and Results Achieved (cont'd)

(b) Correction of minor items such as loose nuts, bolts, etc.

but not including welding or configuration, f ound during the Support Installation Inspection will be corrected at the time of inspection. Items not corrected at the time of Support Installation Inspection will be considered discrepant, and documented by W&B Q.C. on the Hanger /

Seismic Support Checklist Form EF-136.

The W&B Project Q.C. Manager will review the discrepancies and forward for corrective action in accordance with Dis-crepancy Trend Ana?.ysis & Reporting Procedure WB-Q-ll2. A DDR will be prepared for nonconforming supports and a Hold Tag will be placed on the affected support. Rework resulting from a DDR will be initiated within 10 working days following the final disposition.

(c) Af ter completion of piping installation and prior to the system hydrotest, the supports will again be inspected for final acceptance.

The Wismer and Becker Project Quality Manager shall verify that the items not previously accepted receive Final Inspection and acceptance. Discrepancies identified during Final Inspection will be handled as indicated in Item (b) above.

The above procedural changes were reviewed and approved by a committee of Detroit Edison, Daniel International, and Wismer and Becker Manage-ment, Engineering, and Quality Assurance personnel in meetings held on 3/22 and 3/23/79. The week of 3/26/79, training sessions were conducted and completed on thecurrent revisions to these procedures for personnel involved in Hanger Installation (Q.C., Foreman, General Foreman, Engi-neers).

b. A formal Action Plan was developed by Detroit Edison on March 23, 1979 at a meeting for the purpose of discussing the Stop Work Corrective Action Plan. This Action Plan outlines the special controls which will be employed during the period the Stop Work Order is in effect. After approval by Edison, controlled releases of specific traveler packages were accomplished in accordance with these guidelines. The Stop Work remains in effect with release of design approved work packages, which are subject to review by Daniel and Edison prior to initiation of work, in accordance with the revised controls established by the procedures noted above.

Corrective Action Taken to Avoid Fu-ther Noncompliance The implementation of the Corrective Action Plans released by Edison, Daniel, and W8B are being closely monitored and controlled by Management to assure the plan is being followed and the feedback from the field is monitored for prompt corrective action.

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Corrective Action Taken to Avoid Further Noncompliance (cont'd)

a. Separate inspections have been included in the W&B Procedure WB-C-114 to assure early identification of problems by Q.C. during the Support Installation and provides a method for tracking the open items and de-ficiencies for closure prior to final acceptance inspection.
b. A monthly trend analysis by the W&B Project Quality Manager based on the data obtained from Hanger Installation checklists and/or associ-ated DDR's will establish additional management visibility needed to identify persistent trends and isolate specific causes for corrective action resolutions.

c.

Wismer and Becker Q.C. shall conduct surveillances in addition to 100 percent inspection as an overview to verify adequate compliance with bnplementing procedures.

d. A weekly status meeting is being held with Edison Management to review problem areas and status of released work packages to constantly moni-tor the progress and to provide timely corrective action.
e. Joint audits by Daniel and Edison Q.A., along with daily surveillances in the field by Daniel Q.C. will be accomplished during this period to verify compliance with procedural and design requirements and to assure adequate corrective action is accomplished,
f. Daniel Engineering will review hanger tracking status and field in-stallations to assure that procedures and engineering criteria are being followed and the required information is provided from Edison to the field prior to release of the work packages. In addition, Daniel Engineering will monitor the Edison design effort and communi-cate changes to installed or fabricated supports to Wismer and Becker.

They will advise Edison of any design or $nstallation problems with each new support revision. They will advise Edison management of any adverse trends relating to improper support design.

g. Continual management review of the quality indicators noted above will prevent continuation of work if the corrective action plan committments for controlled conditions are not satisfactorily implemented.

Date When Full Compliance Will Be Achieved An evaluation of the effectiveness of the Corrective Action Plan, a review of the results of Trend Analysis, Audits, Surveillances, and Status Reports will be completed over the next two months to establish a management con-fidence level for field implementation and compliance with the Corrective Action Plan.

Full compliance is anticipated by June 29, 1979.

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