ML19309C479
| ML19309C479 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 02/28/1980 |
| From: | Hines E DETROIT EDISON CO. |
| To: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19309C476 | List: |
| References | |
| EF2-47-370, NUDOCS 8004080649 | |
| Download: ML19309C479 (8) | |
Text
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g Edward Hmes o
a..
g Ecison A
February 28, 1980
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EF2 47.370 9Ecor t ct c and Engineering b 1.' M Cb4 L AA [ Add-Support Branch U.S. fluclear Regulatory Ccrrission
$Q@ G M $ d ICC Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
lioncompliance at Enrico Fermi Unit II Ccnstruction Site.
Dear Mr. Fiorelli:
This letter rescends to the infractions contained in your IE Report 50-341/79-25 resulting from the construction activities inspection conducted by Messrs. F.J.
Jablonski, E.H. Lee, and C.M. Erb on December 18-21, 1979.
The cited infractions mentioned in ycur report are discussed in this reply, as rocuired by Section 2.201 of the NRC's " Rules of Dractice", Part 2, Title 10, Code of Federal Regulations.
The unresolved items are being acted upon. We will be prepared to report in detail on our progress and corrective action on those items to your inspectors on their next visit.
The enclosed response is arranged to the sequence of items cited in the body of your report. The finding and section numbers are referenced.
We trust this letter satisfactorily answers the concerns raised in your report.
We shall be glad to discuss any further concerns you may have.
Sincerely yours, MN7t EH/ HAW /pn Enclosure 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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e THE DETROIT EDISON COMPANY-OUALITY ASSURANCE DEPARTMENT ENRICO FERMI 2 PROJECT i
Response to NRC Report No. 50-341/79-25 Docket !!o. 50-341 License No. CPPR-87 Inspection at:
Fermi II Site, fionroe, flichigan Insnection conducted:
December 18-21, 1979 Prepared by:
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R.A. Walker Supervisor, OA Auotts and Surveillances Approved by:
d T.A. Alessi Director, Project Quality Assurance-i Detroit Edison Company
Response to NRC Report #50-341/79-25 Page One Statement of Infraction 79-25-01
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Appendix A:
Item 1 Infrhction:
Contrary to the above, you failed to stop mechanical installation work in accordance with subparagraph 4.2.1.6 of Section No.1 of the Hismer and Becker Ouality Assurance and Centrol Manual even though construction supervision did not assure that work operatiors did not proceed past mandatory hold points as specified in subpara-graph 3.3 of Section X of the above manual.
Corrective Action Taken and Results Achieved Wismer and Becker Serial Letter 2184-J, dated July 26, 1979, was iniciated out-lining the corrective action to be taken for by-passed hold points 9hich includ-ed the possibility of dismissal if hold points were by-passed.
Sttp Work was not initiated by Wismer and Becker's Project Ouality fianager because the Project Quality Manager felt that implementation of these proposed corrective actions and ccrritments from management enforcina this policy would be effective and provide a satisfactory resolution to the problem.
In the future, if a by-passed hold point is found the Pismer and Becker (W&B)
Project Quality tianager will notify the W&B Project Executive Manager imediate-ly and verbally report the circumstances involved, including cause. This will be followed with a written report including notification of stop work against the installation, if applicable.
If two or more hold points are by-passed with-in thirty (30) days, the P&B Project Quality Manager will review the circum-stances involved and detennine if a stop work order applying to all OA Level I travelers is appropriate.
If the situation warrents, an extensive stop work o
order will be issued affecting all work involving 0A I Travelers.
Phen a stop work order is applied, P&R Management personnel will be required to advise the Project Ouality Manager in writing of the corrective action taken, or planned prior to resuming work activities or the affected traveler (s).
Corrective Action to be Taken to Avoid Further Noncomoliance A procedure (UB-0-118) has been initiated, which provides specific guidelines for issuing a stop work order. The conditions discussed previously will be addressed in the procedure.
Implementation of this procedure will prevent work from continuing without adequate corrective action if by-passing of hold points occurs in the future.
Date When Full Compliance Pill be Achieved Procedure WB-0-Il8 is expected to be approved by 4/1/80. The policy discussed
Response to fiRC Report 750-341[79-25 Page Tvc Date lihen Full Conoliance Will be Achieved (cont'd) above has been inclemented.
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Response to NRC Report #50-3al/79-25 Page Three State ent of Infraction 79-25-02 Appendix A:
Iten 2 Infraction:
Contrary to the above, during the past year over 40 instances had been identified where mechanical installation inspection hold points were by-passed; you failed to determine the cause anc take corrective action to preclude repetition.
Corrective Action Taken and the ResultMQieved During surveillances cerfor ed in July of 1979 travelers were found in construc-tion areas with hold points by-passed. This was after several Deviation Disposi-tion Requests (DDR's) had been issued over a period of time documenting the same probl em.
This prompted Edison /Dar.iel Manaaerer.: te r = = en i mediate response from Wismer and Becker (P&B) Managerent. stating the corrective action they would take to resolve this recurring problem. Hismer and Becker responded (Letter Serial No. 2184-J) stating action they would take to correct this situation with major emphasis on training craft supervisory personnel. This training was done to assure the supervisors were aware of the importance of stopping work and allowing inspections to be performed.
During the training sessions it was stressed that any supervisory personnel identified as being responsible for by-passing hold points would be subject to disciplinary action includina dismissal.
Daily reviews of operational process travelers and WPCS's were conducted by Edi-son QA, starting in August and continuing until January, 1980. The purpose of the reviews was to monitor the traveler documents and determine if corrective actions taken were effective. As these reviews progressed it was found that the occurances of by-passed hold points reduced considerably from previous months.
On January 15, 1980, the results of an analysis of by-passed hold points were issued by W&B OA personnel. The purpose of this analysis was to determine if corrective action was effective in reducing the by-passing of hold points. The analysis consisted of reviewing all DDR's, identifying by-passed hold points and determining through review of the affected documents the date the hold point was by-passed and what the hold point was. The conclusion that was derived from this analysis was that hold point violations had decreased by approximately 70". since implementation of corrective action in July,1979.
Recorrendations were generated as a result of the analysis and were addressed to the W&B project Executive Manager. The major recommendation was that hold points be placed on the document required to be at the work location. This recommenda-tion was made because it was determined that the greatest number of hold points by-passed were for closure cleanliness inspections. These hold points were placed on the operation process traveler (this may cover installation of several pipe spools and associated welds) instead of the weld process control sheet (WPCS) which also contains hold points relative to inspections of the particular
Resoonse to NRC Report #50-341/79-25 Page Four Ccerective Action Taken and the Results Achieved (cont'dl weld. The UPCS is required to be at the weld joint where as the tra'veler is not.
The 'W&B Project Executive Manager is reviewing the recommendations with the Pro-
- ject Engineer, Project Superintendent, and Ouality Manacer. The hold points need to be placed on the traveler document that is at the work location.
This will require a change in the PPCS format or additional copies of the operational-pro-cess traveler for placement at each weld joint.
The craft supervisory personnel are fully aware of the hold point requirements.
With the additional effort to assure the traveler document containing the hold j
points are at the work area, the cause of the problem should be eliminated.
Date Vhen Full Compliance Will be Achieved Full Compliance will be achieved by 3/7/80.
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Response to NRC Report #50-341/79-25 Page Five State-ent of Infraction 79-25-03 Appendix A:
Item 3 i
Infraction: Contrary to tne above, your acent, on October 9,-1979, was elimi-nated from imposing mandatcry inspection hold points even though during the past year your rechanical contractor was identified by quality personnel as having a very high weld reject rate and other chronic problems related to mechanical installations.
Corrective Action Taken and the Results Achieved Hold points established by Daniel GC on O&B travelers provide a means of moni-toring W&B inspecttrs performance relative to the activity or item being inspec-ted.
These are in addition to hold points established at the same point ty W&B inspectors and in several cases, the Insurance Agencies Inspectors.
Previously, the Caniel hold points were not established in accordance with any specified guide'ines or frequency.
Instead, they were identified during the review of traveler packages as they were initiated. There were no provisions for main-taining status of the number of hold points established on individual travelers.
Inspections being conducted by Daniel OC at these hold points indicated that W&B Inspectors were performing satisfactorily. For this reason, Daniel eliminated hold points they had established.
This action occurred at a time when several DDR's had been recently issued because of by-passed hold points. This problem was not caused by inspection personnel and does not reflect on their perfor-mance. Craft supervision is responsible for notifying OC personnel that an item is ready for inspection and not to proceed until that insoection is performed.
This was not being done. Additionally, it should be noted that the date the DDR's were initiated does not necessarily reflect the same time period that the hold points were by-passed.
Edison DA had expressed concern that this was not an advisable time to eliminate existing hold points since this action could be viewed as a method of minimizing the problem of by-passing hold points. A firm determination that previous corrective actions to eliminate by-cassing of hold points had not been made at the time the hold points were deleted.
Detroit Edison has directed Daniel to review and evaluate Daniel surveillance reports and DDR's related to W&B operations and re-establish hold points where necessary. As a result of this review and unacceptable surveillance findings, hold points were re-established on five piping systems.
Corrective Action to be Taken to Avoid Further Noncompliance The Site Project Quality Engineering group will establish a quality trend analy-sis program which will be used to determine the need for hold points. A quality assurance Engineer will be responsible for reviewing the trend report and deter-mining if conditions require establishment of hold points to provide further
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~ Response to NRC Report #50-341/79-25 Page Six Corrective Action to be Taken to Avoid Further Ncncemoliance (cont'd) coverage of a particular activity or activities. When hold points are establish-ed on W&B traveler documents, they will be logged on a form to maintain status
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and Drovide information as to the type of hold points and the system that is applies to.
Implenentation of this trend analysis procran will provide data for determining when and where customer hold points are needed.
This should elimi-nate any future circumstance where owner / agent hold points are deleted.
Date Vhen Full Comoliance Will be Achieved The quality trend analysis program will be completed and implemented by liay 15, 1980. All other actions are complete at this time.
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