ML19309F697

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Forwards Response to Infractions Noted in IE Insp Rept 50-341/80-02 on 800121-23 & 0211-12.Corrective Actions: Calculations Verified by Edison Design Engineering & Changes Are Being Made in Procedure Manual Addressing Design Mods
ML19309F697
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 04/22/1980
From: Hines E
DETROIT EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
EF2-48-580, NUDOCS 8004300382
Download: ML19309F697 (10)


Text

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  • Edward Hines ASS 5!a"af owas, V'Cf P'@$idt9f ssur ance Deholt 3331 4 9 ; Beave' Goaa M 3?iT4?/6/ "

April 22, 1980 EF2-48,580 Mr. James G. Keppler, Director U. S. Nuclear Regulatory Commission Region lli 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Keppler:

Subject:

Noncompliance at Enrico Fermi Unit 2 Construction Site This letter responds to the infractions contained in your IE Report 50-341/80-02 resulting from the construction activities inspection conducted by Messrs. G. A. Phillip, l. T. Yin and C. M. Erb on January 21-23 and February 11-12, 1980. We requested and were granted a waiver to extend the response period.

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 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.

In our review of the subject inspection report, we found two specific instances where we cannot agree with your reported findings or conclusions, namely:

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1. We feel that the first sentence of Section I on Page 5 which reads:

"Through interviews with the individuals, the discrepancies identified by ABC News were, for the most part, confirmed", is in error. The discrepancies indicated in the attached letter, provided as Exhibit A to your report, were for the most part unsubstantiated and unconfirmed.

Only in the area dealing with two (2) cases of doctored resumes were the allegations confirmed. The majority of the items alleged in Exhibit A were not confirmed.

2. The first sentence in the last paragraph of Section I on Page 5 is in error. This sentence states: "The failure to establish personnel qualification requirements for a design engineering function is in noncompliance with 10 CFR 50, Appendix B, Criterion ill, Design Control".

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l Mr. James G. Keppler EF2-48,580 April 22, 1980 Page 2 This is not a requirement of Criterion ill of 10 CFR 50, Appendix B,

" Design Control". Criterion lll requires that measures be established to assure that applicable regulatory requirements are correctly translated into specifications, drawings, procedures, and instructions.

It does not require an established personnel qualification program.

-The required assurance that personnel could perform the work adequately was obtained as described in the third paragraph of Section I on Page 5 of your report.

We trust this letter satisfactorily answers the concerns raised in your eport. We shall be glad to discuss any further concerns you may have.

Very truly yours, LVAf &

HAW:mb Enclosure cc: Mr. G. Florelli, Chief Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission Region til 799 Roosevelt Road 1 Glen Ellyn, IL 60137 )

Skr. Victor Stello, Jr., Director ,

Office of Inspection and Enforcement i Division of Reactor inspection Programs U. S. Nuclear Regulatory Commission 1 Washington, D. C. 20555 k

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

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l Response to NRC Report No. 50-341/80-02 1

Docket No. 50-341 License No. CPPR-87 Inspection at: Fermi II Site, Monroe, Michigan Inspection conducted: January 21-23 and February 11-12, 1980.

Prepared by: , .  !

9.A. Walker (

Supervisor, Construction '

Ouality Assurance l Approved by: Ib T.A. Alessi Director, Project Ouality Assurance Detroit Edison Company l

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Response to NRC Report #50-341/80-02 Page One Statement of Infraction 80-02-01 Appendix A:

Infraction: Contrary to the above, the control of small bore piping suspension design was considered to be inadequate in that:

a. The work performed by Wismer and Becker during 1977 and 1978 was accomplished without approved procedures.
b. Insufficient guidance was provided by the DECO Engi-neering Department in their standardized chart and table type design methods.
c. Acceptance review was not conducted by the DECO Engineering Department on a systematic basis.
d. Personnel qualification, certification, indoctrina-l tion, and training requirements had not been esta-blished for the DI Small Bore design group.

In addition, numerous installation deficiencies were identified that are an indication of this lack of design control.

SECTION II Finding No. la The calculations performed by Wismer and Becker personnel from October 1977, to December 1978, were considered to be questionable since for-ral procedures and acceptance criteria had not been established for l the activities performed. The inspector stated that all work involved l

should be reviewed and approved in a timely manner by qualified engi-neers.

Response No. la Corrective Action Taken and Results Achieved Wismer and Becker performed small bore design work (including calcula-tions) during 1977 and 1978. Daniel International began performing small bore design in January of 1979. A Wismer and Becker small bore design procedure (WB-E-122) was issued for use May 15,1978. -Design was performed from October 1977 to May 1978 without a procedure rather than to December 1978 as indicated in the-inspection report.

Response to NRC Report #50-341/80-02 Page Two Corrective Action Taken and Results Achieved (cont'd)

The Pipe Routing and Support Location (-1) drawings, the Analytical

(-3) drawings and the Small Piping Design Standard Work Sheets, which were produced while the Small Bore Design Group was under the direc-tion of Wismer and Becker, were reviewed and approved by Edison Design Engineering; as are those presently being produced by the group under Daniel Administration. These reviews are to confirm the adequacy of the piping configuration, piping material selection and pipe support spacing, location and orientation. All of the above documents will be re-reviewed by Edison Design Engineering as these documents are up-dated to the "as-built" condition and submitted for engineering appro-val. Due to the extensive nature of these reviews, no further need for corrective action is perceived.

Detailed pipe support design sketches, and their respective back-up structural calculations produced by Fismer and Becker or Daniel have not been reviewed by Edison De. sign Engineering. The methods by which these reviews will be conducted are disucssed below in the response to Findinn No. Ib.

Corrective Action to be Taken to Avoid Further Noncompliance Wismer and Becker is no longer responsible for small bore piping design. The Small Bore Design Group, who is presently perfonning small bore piping design, has procedures approved and in use and pre-sently reports to Edison Field Engineering.

Date t},an Fi11 Connliance l'ill te Achieved The re-revier of the Pipe Routing and Support Location drawings is an on-going activity which will be completed as the installation of the respective piping systems is complete. The review of the detailed pipe support design sketches will be as described in the response to Finding No. Ic.

Finding No. Ib t Field Design Change Request (DCR) No. SB-0315A was written on May 30, l 1979, and approved on June 26, 1979, to provide the design basis for j small bore piping configuration and suspension. A review of this DCR l revealed a number of program and technical deficiencies:

l l The DCR was initiated by a Daniel field engineer and contained engineering design requirements which should have been incorpor-ated into DECO Specification No. 3071-31, " Pipe Erection", Revi-sion B, dated April 1979. This DCR was approved by the DEC0 field engineer. The inspector stated that the approval and  ;

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Response to NRC Report #50-341/80-02 Page Three Finding No. lb (cont'd) issuance of a design specification including installation toler-ance, can only be performed by the DECO Design Engineering Depart-ment, as is specified in their established project and QA manual procedures.

Requirements for restraint structural assembly and shear lug design for 2h", 3", and 4" small bore piping were not included in the specification or the DCR: however, the DI Small Bore Work Group was performing piping design and calculations in these areas.

Corrective Action Taken and Results Achieved Changes are being made to the Project Procedure Manual to address this problem.

Corrective Action to be Taken to Avoid Further Noncompliance The Fermi 2 Project Procedures Manual will be revised to require that changes to all criteria type requirements stated in Fermi 2 specifica-tions can only be approved by the Director-Project Design or his Assis-tant who has the Director's signature authority. The use of the pr,R/

DCN procedures to allow such changes to be effected, will still be per-mitted, but in such cases, approval of the appropriate DCR or DCN will be by the Director-Project Design or his Assistant. The Project Proce-dures Manual will continue to allow non-criteria type changes to Pro-ject Specifications to be approved by the Edison Director-Field Engi-neering or his delegate, who has his signature authority. 1 DCR SB-0315 will be expanded to show the requirements and load ratings for pipe lugs on piping in the 2h" through 4" size range. The DCR will i also be expanded to include references to recognized test books, design j aids and industry standards that are designated to provide guidance in the performance of structural calculations which are prepared to demon-strate the adequacy of the pipe support designs.

Date When Full Compliance Will be Achieved The Project Procedure Manual will be revised by May 2, 1980.

DCR SB-0315 will be revised by May 16, 1980.

Finding No. Ic DI Construction Procedure, No. AP-IV-05, "Small Bore Piping and Pipe

Response to NRC Report #50-341/80-02 Page Four Finding No. Ic (cont'd)

Support". Revision 0, dated April 11, 1979, stated in part, that

" Edison approved all design documentation generated for the construc-tion of small bore piping...", but in reality only the hanger isometric drawings and analytical isometric sketches were being reviewed by DECO design engineers. There was no fomal system to ensure these drawings and sketches were evaluated by the responsible personnel. The restraint installation detail drawings and calculation had not been reviewed by DEC0 engineers.

Corrective Action Taken and Results Achieved A log has been prepared by the Small Bore Design Group listing the drawing numbers of all ASME III, Class 2 and 3, Seismic Class I piping drawings 2" and under in size, which have been or will be prepared by the Small Bore Design Group. In addition, the log will list those drawings in the 2h" through 4" size range mich have been assigned to the Small Bore Design Group by Edison Design Engineering. In addition to the drawing number, the log will be expanded to show the following information.

1. Date submitted to Edison Field Engineering for approval.
2. Date Edison Design Engineering approval or comments are received.
3. Date Edison Design Engineering comments are reconciled and appro-val is granted by Edison Field Engineering (where appropriate).
4. Date(s) that minor field changes are submitted to Edison Field Engineering for approval via DCR's; and the date(s) those appro-vals are provided (where appropriate).
5. Date when the final "As-Built" drawings are submitted for Edison Design Engineering approval.
6. Date when Edison Design Engineering approval or comments on the "As-Built" drawings are received.
7. Date when Edison Design Engineering comments on the "As-Built" drawings are reconciled and final approval is provided by Edison Field Engineering.

l All of the above is applicable to the pipe routing and hanger location drawing (-1) for piping 2" and under in size; the hanger location draw-l ing (-2) for piping 2h" through 4" in size; the analytical drawing (-3) i and the analytical work sheets for all piping 4" in size and smaller, l which are prepared to demonstrate compliance with the Small Bore Design l standard. '

Corrective Action to be Taken to Avoid Further Noncompliance Edison Design Engineering will prepare an internal written procedure 1

Response to NRC Report #50-341/80-02 Page Five

[orrective o Action to be Taken to Avoid Further Noncompliance (cont'd) indicating which design groups are responsible for review of specific drawings, and what each group reviews on those drawings.

A program will be instituted to provide for an Engineering revi*ew of a statistically significant number of the detailed support design sketches and their back-up structural calculations. These reviews will be conducted by personnel from Edison's Design Engineering organ-ization who are skilled in pipe support and/or structural design; or similarly skilled personnel provided by Edison's Engineering Consul-tants. All reviews will be conducted in accordance with written cri-teria prepared by Edison Design Engineering and will be appropriately documented. The reviews will cover design work done under both Wismer and Becker and Daniel Administration.

Date When Compliance is Expected to be Achieved

1. The expanded drawing log will be available on site by May 16, 1980.
2. The design reviews by Edison Design Engineering are already in effect; and will be continued through the balance of the con-

, struction program.

The procedure will be available by April 25, 1980.

The hanger sketch and calculation review criteria will be available by May 16,1980. The sketch and calculation reviews will be initiated by June 2, 1980. No firm completion date can be predicted since this is a function of the Plant Construction schedule.

Finding No. 1d The DI Construction Procedure AP-IV-05, Revision 0, stated in part, that "The function of the Small Bore work group is to produce and revise drawings for the construction of 2" and under piping and pipe supports." DCR No. 5B-0315A extended the "2" and under" limit to a "4" and under" limit. In discussions with the DECO engineer, it was determined that the Small Bore work group can only handle the 4" and under piping with the less severe design conditions. However, the specific conditions were not specified in any document.

Response No. 1d Corrective Action Taken and Results Achieved The Small Piping Design _ Standard, augmented by special supplemental thermal expansion design tables prepared by Edison Design Engineering can be used to design all_ ASME III, Class 2 and 3 Piping Systems of 4" nominal pipe size or smaller: provided the Design Pressure does not f

o .

Response to NRC Report #50-341/80-02 Page Six Corrective Action Taken and Results Achieved (cont'd) exceed 1750 psig and the Design Temperature does not exceed 575 F. The Standard can also be used to solve special piping design problems, such as the seismic qualification of non safety-related piping systems which are routed through safety related areas. Practically, the Standard has only been applied to selected piping systems in the 2h" through 4" size range, since design of piping systems in these size ranges is normally more effectively accomplished using traditional computerized analysis techniques.

Those piping systems in the 2 " through 4" size range which have been assigned to the Small Bore Design Group on site have been identified in a memorandum from Edison Design Engireering to the Edison Chief Field Design Engineer.

Corrective Action to be Taken to Avoid Further Noncompliance If further assignments are made, the memorandum referenced above will be appropriately revised and reissued.

Date When Full Compliance Will be Achieved The action described above has been completed. .

l Finding No. le Since the DI Small Bore work group is a part of the design engineering I function; personnel qualification, certification, indoctrination, and training requirements should be established by the DECO Design Engin-eering Department. In addition, the implementation of such require-ments should be enforced by the DECO Design and QA Departments. These l requirements were not visible during the inspection. I Response No. le Corrective Action Taken and Results Achieved Action is presently being taken in this area. See Corrective Action to be Taken to Avoid Further Noncompliance.

Corrective Action to be Taken to Avoid Further Noncompliance l Minimum job qualification standards for personnel working in the Small Bore Design Group on site are being fonnulated and issued by Edison.

These standards will be considered in the initial selection of candi-dates for employment in the Small Bore Design Group. The decision to

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Response to NRC Report #50-341/80-02 Page Seven Corrective Action to be Taken to Avoid Further Noncompliance (cont'd) retain a person after initial assignment, will cuntinue to be princi-  ;

pally governed by the results of the detailed checking of his work 1 assignments. 1 In addition, a formal seminar addressing the important parameters / l activities which must be considered during the conduct of the Small Bore Piping Design, will be prepared and presented by Edison Project Engineering to the incumbent members of the Small Bore Design Group.-

This presentation will be video-taped to allow presentation to new employees, or to be used as a part of a continuing on-the-job training program.

Date When Full Compliance Will be Achieved The job qualification standards will be published by May 2, 1980.

The seminar will be presented in June, 1980.

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