ML19305B428
| ML19305B428 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/21/1980 |
| From: | Erb C, Knop R, Lee E K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19305B422 | List: |
| References | |
| 50-341-79-25, NUDOCS 8003190641 | |
| Download: ML19305B428 (12) | |
See also: IR 05000341/1979025
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No.
50-341/79-25
Docket No.
50-341
License No. CPPR-87
Licensee: Detroit Edison Company
2000 Second Avenue
Detroit, MI 48226
Facility Name: Enrico Fermi Nuclear Station, Unit 2
Inspection Conducted: December 18-21, 1979
by GlGve5&
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Inspectors:
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Approved By:
R. C. Knop, Chief
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Projects Section 1
Inspection Summary
Inspection on December 18-21, 1979 (Report No. 50-341/79-25)
Areas Inspected: Follow-up of previously identified noncompliances/
unresolved items; independent inspection; mechanical work activities.
The inspection involved 84 inspector-hours onsite by three NRC inspectors.
Results: Of the areas inspected, three items of noncompliance were
identified.
(Infractions - failure to stop work, take corrective action,
and establish hold points.Section I, Paragraphs 1 and 2)
80031906g
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DETAILS
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Persons Contacted
Detroit Edison Company
- T. Alessi, QA Director
- R. Barr, Project QA Director
- W. Everett, Project Superintendent
- W. Fahrner, Project Manager
- E. Hines, Assistant Vice President QA
- W. Jens, Vice President Nuclear Operations
- A. Walker, Site Project QA Engineer
Daniel InternrLional Corporation
- M. Albertin, Assistant Project Manager
- J. Blixt, QC Manager
- J. Bolt, QA Manager
- K. Dempsy, Assistant Construction Manager
M. Guest, Document Control Supervisor
- D. Siefert, Project Manager
D. Wise, Procedure Coordinator
Wismer & Becker
D. Jantosik, Training Coordinator
- C, Keller, QA Manager
W. Wright, Personnel Manager
- E. Young, Project Executive Manager
- Denotes those attending the exit interview.
Licensee Action on Previous Inspection Findings
(Closed) Noncompliance (341/79-13-03): Control of measuring and test
equipment. Checked radiographic laboratory and found lead numbers in
place and proper material identification. Calibration film tablets for
densitometer average checked at Wismer & Becker and NES. Determined new
film density tablets have been secured for each group. Corrective action
was in accordance with DECO's letter to NRC dated July 12, 1979.
(0 pen) Noncompliance (341/79-13-04): Control of special processes.
Radiographic shooting sketches nave been made of various source-film set
ups and reader sheets will now indicate the set up used. Lead identifica-
tion numbers were discussed in item 341/79-13-03 above. Bent penetrameter
and shim procedure was not reviewed.
Functional or Program Areas Inspected
Areas inspected are discussed in Sections I, II, and III of this report.
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Section I
.
Prepared by
F. J. Jablonski
Reviewed by
R. C. Knop, Chief
Projects Section 1
,
1.
Corrective Action - Stop Work
Reviewed all W&B Deviation Disposition Requests (DDR's) in the
Daniel series 2301-3871 for a period between December 1978-1979. It
appeared for the most part that the DDR's reflected problems which
should have been identified by implementation of W&B's QA-QC inspec-
tion program. For example, attributes included on weld process to
control sheets (WPCS), technique sheets, specifications, and proce-
dures were used as the basis for identifying deviations. ,
Deviations were numerous and included for example:
a.
Defects on vendor supplied materials
b.
Surface defects such as are strikes, punch marks, hack saw
cuts, etc.
c.
Mishandling of components, damage to weld end preps
d.
Weld rod control
e.
By passing of hold points
By passing of hold points is considered the most serious deviation.
(See Paragraph 2 below). The review of DDR's indicated greater than
40 instances where hold points had been by-passed. There did not
appear to be any decreasing trend over the period of review.
Similar findings were made by the licensee's agent during an audit
performed in January, 1979. Corrective action was delineated in W&B
letter 2184J dated July 26, 1979. Even though threat of dismissal
for violation of hold points was included, corrective action has not
been effective in preventing recurrence of the deviations. (No
dismissals have occurred). Further, in a W&B memorandum dated
November 19, '979 to the W&B Project Executive Manager, the W&B
Project Quality Manager rescinded letter 2184J as a means of pro-
viding corrective action and recurrence control.
NOTE: The vast majority of the above DDR's implied or stated directly
the need for training as_the means of corrective action to prevent
recurrence. A review was made of W&B training records, lesson plans,
test forms, etc. Personnel being trained and the type of training
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appeared to be commensurate with ongoing activities,
i.e.,
lack of
.
training does not appear to be the underlying cause of the chronic
abuse of bypassing hold points.
During the period described above, the licensee failed to stop work
for by passing hold points in accordance with established procedures
of the site mechanical' contractor. This matter is in noncompliance
with 10 CFR 50 Appendix B, Criterion V as described in Appendix A of
this report. (341/79-25-01)
Also during the same period, the licensee failed to determine the
causes of conditions adverse to quality and take prompt corrective
action to preclude repetition. This matter is in noncompliance with
10 CFR 50 Appendix B, Criterion XVI as described in Appendix A of
this report.
(341/79-25-02)
2.
Hold Points
W&B had been identified previously be DECO's agent as having program
problems with timely corrective action. The problems are summarized
in Daniel letter to W&B dated July 13, 1979 *No. DIC9-2684. Two
"show cause" letters dated September 18, 1978 and February 1, 1979
have been issued. (Attachment I to the above document) Adverse
trends initially reported in June 1978 included several instances of
missed hold points as well as numerous generic welding deficiencies.
(Attachment 2 to the above document) A summary of program deficien-
cies included violation of hold points identified during Edison QA
surveillance and W&B/DIC QC activities, and analysis of weld problems
and rejection. (Attachment 3 to the above document)
A DECO site QA file titled, " Hold Point Problems" documents corres-
pondence between the period July 10, 1979 to November 2, 1979 regard-
ing their concern about the removal of Daniel mandatory QC inspection
hold points from W&B welding travellers. (An inspection hold point
is an arbitrary place reached in the installation process which is
not by passed unless witnessed and approved by an inspector. Examples
of welding installation hold points include fit up, pre and post
weld heat temperature, visual inspection, nondestructive testing,
etc.) As of October 9, 1979, Daniel QC, Edison's agent (designated
representative) was eliminated from imposing mandatory QC hold
points from weld process control sheets and I-6 (weld repair) forms.
First line inspection and verification activities have reverted to
W&B, an organization that has been ineffective, in correcting the
adverse trends (Between October 9, 1979 and November 10, 1979 there
were 12 DDR's which identified violations of mandatory hold points).
The inspectors stated his concern that the missed hold points meant
that the required inspections of attributes were not doen at the
required time and that this chronic condition has existed for a long
,
time. Deletion of mandatory hold points by the applicant's agent in
the midst of adverse trends is in noncompliance with 10 CFR 50,
Criterion X as described in Appendix A of this report. (341/79-25-03)
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3.
Surveillance
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Daniel procedure No. AP-IV-12 describes responsibilities and actions
to be taken relative to review, approval, and designation of contrac-
tor mandatory hold points. The procedure is not implemented unless
surveillance by Daniel QC indicates a need. Needs ar established by
noting adverse trends.
Definitions of surveillance and trend were not provided in any
established procedure; terms are discussed below.
Surveillance usually means to progressively monitor by randomly
.
witnessing and inspecting items and work operations before,
during, or af ter in-process construction.
Trend usually means the general course or prevailing tendency.
.
To effectively monitor a designated task or activity and determine a
trend, it seems necessary for responsible QC personnel to be present
in a work area observing specific attributes over a predetermined
time. Surveillance, i.e. random witnessing, cannot alone be effec-
tive in determining trends.
Definitive sample sizes and acceptance criteria must be established
which are based on recognized standard practices. Repeated failure
to follow procedures, implement corrective action, or have complete
disregard for documentation requirements are examples of trends
adverse to quality and which must be corrected.
For surveillance to be considered a viable method of inspection, it
is apparent the licensee needs a procedure defining sample size and
acceptance criteria for attributes included on process control
travelers which document mechanical installation. Further, an adverse
trend must be defined based on the surveillance activities and then
mandatory hold points imposed.
Due to time restraints, this matter was not completed, therefore it
is unresolved. (341/79-25-04)
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Section II
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Prepared by E. W. K. Lee
Reviewed by D. H. Danielson, Chief
Engineering Support Section 2
1.
Reactor Coolant Pressure Boundary Piping - Observation of Work and
Work Activities
The inspector observed fitting up and alignment of Residual Heat Removal
System Weld No. E11-2299-2W01 on Isometric drawing No. 6M721-2299.
It
was determined that procedure requirraents were met and good construction
practices were adhered to.
No items of noncompliance or deviations were identified.
2.
Safety Related Piping - Observation of Welding Activities
The inspector observed the following welding activities:
a.
Reactor Core Isolation Cooling System weld No. E51-3174-11WF2 on
isometric drawing No. 6M721-3174-1.
b.
Residual Heat Removal System welds No. E11-3178-3WFT and
No. E11-3178-3WF4 on isometric drawing No. 6M721-3178-1;
No. E11-3154-11WO on isometric drawing No. GM721-3154-1;
No. E11-3185-5WF1 on isometric drawing No. 6M721-3185-1;
and No. E11-3173-0W17 on isometric drawing No. 6M721-3173-1.
c.
High Pressure Coolant Injection System welds No. E41-3162-9WF1
on isometric drawing No. 6M721-3162-1; No. E41-3172-1WF2 on
isometric drawing No. 6M721-3172-1; and No. E41-3162-10WF1 on
isometric drawing No. 6M721-3162-10A.
d.
Core Spray System weld No. E21-3149-2W7 on isometric drawing
No. 6M721-3149-1.
It was determined that (1) work was conducted in accordance with
traveller; (2) proper welding materials were used; (3) welding procedure
requirements were met; (4) work area was free of weld rod-stubs, and
(5) physical appearance was acceptable.
No items of noncompliance or deviations were identified.
3.
Safety Related Piping - Observation of Work and WorkActivities
~
The inspector observed weld end preparation of Residual Heat Removal
System Weld No. E11-3160-1WO on isometric drawing No. 6M721-3160-1.
-It was determined that work performance met the applicable requirements
and good construction practices were adhered to.
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No items of noncompliance or deviations were identific'.
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4.
Safety Related Piping - Observation of NDE Work Activities
The inspector observed liquid penetrant examination of Residual Heat
Removal System welds No. E11-3184-0W10 and No. E11-3184-10W on iso-
metric drawing No. 6M721-3184-1.
It was determined that:
(1) procedure requirements were met, (2)
personnel were properly qualified and (3) indications were identified
on both welds by the examiner and welds were re-examined after surface
conditioning.
No items of noncompliance or deviations were identified.
5.
Safety Related Piping - Weld Heat Treatment
a.
Review of Procedure
The inspector reviewed W&B Procedure No. WB-C-118, Revision 2,
" Methods of Control and Monitoring of Preheat and Interpass
Temperatures".
It was determined that the procedure is acceptable,
b.
Observation of Werk
While observing welding activities for items stated in paragraph 2
of this report, the inspector determined that preheat met the pro-
cedure requirements.
No items of noncompliance or deviations were identified.
6.
Safety Related Piping - Special Welding Applications
The inspector observed the following repair work activities:
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a.
Weld repair of Residual Heat Removal System Weld No. E11-3173-1WO
on isometric drawing No. 6M721-3173-1 and Core Spray System weld
No. E21-3144-02W5-C2-R1.
b.
Grinding defects of Reactor Core Isolation Cooling System weld
No. E51-3176-7WF4-R2 on isometric drawing No. 6M721-3176-1.
It was determined that (1) work was conducted in accordance with
traveller; (2) proper materials were used and (3) procedure
requirements were met.
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No items of noncompliance or deviations were identified.
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7.
Safety Related Piping - Welding Qualifications
The inspector reviewed the following documents:
W&B Procedure No. WB-E-118, Revision 6, including Interim Change
a.
Serial No. 95, " Welder and Brazer Qualification",
b.
Qualification record of eleven welders who performed welding on
welds stated in paragraphs 2 and 6 of this report.
It was determined that the above documents met the requirements of
,
No items of noncompliance or deviations were identified.
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Section III
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Prepared by C. M. Erb
Reviewed by D
H. Danielson, Chief
Engineering Support Section 2
1.
Control, Hanger Installation
a.
Control of drawings and procedures by the licensee and contractors
was checked by picking several drawing numbers being used in the
plant and matching the revision with the latest revicion in document
control. The following drawing numbers and procedures were checked
out.
Plant
System
Document Control
6M721-3172-1 Rev. H
-H
6M721-3172-2 Rev. E
-E
6M721-4161 Rev. D
-D
SS-721-2995 Rev. B
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-B
- E11-2327-G04 Rev. B
-A
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6WT-E41-7783 Rev. 0
-0
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6VT-E41-7783 Rev. 0
-0
All the above drawings were in order except for the marked * one,
where the latest' drawing apparently had been issued to the field
before being programmed into the computer.
b.
The latest index of procedures were checked against those in use
with the following results:
Interim
Index Procedure No.
Title
Changes (ICP)
Rev. No.
WB-A-108 Rev. O
Identification
No. 130
0
& Control
Material & Parts
WB-C-120 Rev. O
General Trans-
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portation Pro-
cedure
- WB-Q-102 Rev. 5
Liquid Penetrant Rev. 6 on
9
Examination
3/79
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- WB-Q-103 Rev. 5
Visual Weld Ex-
No's 60, 107,
10
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amination
113, 93
- WB-Q-108 Rev. 4
Magnetic Particle 105, 49
8
Examination
WB-Q-109 Rev. 3
Ultrasonic Ex-
3
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amination
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WPS-7002 Rev. 12
Structural SMAW
132
12
Welding
The above procedures are initiated by Wismer & Becker Co., approved
by Daniel and by General Electric where NSS systems are involved.
To make a revision an ICP is initiated by W&B and goes to Daniel
for comment. This ICP is given a revision number and several ad-
ditions of ICP's without reissue of the procedure may be done.
You will note on 3 procedures * above the revision in the index
list is 4 or 5 numbers less than the actual number of ICP's.
This is considered to be an unresolved item, No. 341/79-25-05 because
of the difficulty in following the system and determining exact
status of changes with contractors such as GECo.
No items of noncompliance or deviations were identified.
2.
Calibration of Equipment
A check of the program for calibration of equipment used by W&B is
given below. A tag showing last date of calibration and due date for
another was found on W&B equipment which was kept in a locked stores
area.
Equipment
Time Interval
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pressure gauges
6 mo. more often if required
by Engineering
contact thermometer
yearly
- oxygen analyzer
yearly
- torque wrenches
yearly
dial indicators
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- tong tester - Amps
yearly
- dial depth gauges
yearly
voltmeter - ammeter
yearly
magnetic particle
6 mo.
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Those items marked with an asterisk would appear to have an overlong
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period between calibrations, particularly where loaned out to many
different operators.
In the past, offsite calibration has been per-
formed by Toledo Testing, but this function will be performed in the
future by the DECO instrument Testing Laboratory. DECO use Ashcroft
dead weight testers for pressure gauges and have standards traceable
to NBS standards in other areas.
3.
Specification Deviations Valves
Three deviations on Powell Valves equipped with Limitorque operators
were examined.
In each case, a Deviation Disposition Request (DDR)
was issued and a diaposition to restore the part and a corrective
action to prevent recurrence stated.
DDR 2817, Valve No. V8-2141, Category "A", Install DCR-P0851
Disposition: Disposition valve operator into upward position
Corrective Action: Emphasize importance of following written
instructions at foremans meeting
DDR 2966, Valve No. V8-2160, Category A, Install 3071-31 Rev. A
Disposition: Rotate motor to comply 3071-31, Rev. A, Revised motor
Corrective Action:
Field coordination problem, train personnel
DDR M2975, Valve No. 4061-1, Category A, Install DCR 0678
Disposition: Rotate valve motor to proper position, See DCR 0678
attached.
Corrective Action: Do not install valve operator or limitorque in
downward position. Review field supervision.
The above cases illustrate a situation, where limitorques are being
incorrectly installed and the corrective action of more training is
ineffective.
No items of noncompliance or deviations were identified.
Unresolved Items
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Unresolved items are matters about which more information is re-
quired in order to ascertain whether they are acceptable items,
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items of noncompliance, or deviations.
Unresolved items disclosed
during the inspection are discussed in Section I, Paragraph 3, and
Section-III, Paragraph 1.
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Exit Interview
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The inspectors met with site staff representatives (denoted in the
Persons Contacted Paragraph) at the conclusion of the inspection.
The inspectors summarized the scope and findings of the inspection.
In addition, the inspectors discussed the eight previous times that
Criterion XVI, corrective action, had been violated at this site and
the high turn over rate of Wismer & Becker work force. The licensee
acknowledged the findings.
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