ML19310A767
| ML19310A767 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/03/1980 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Uchrinseko K AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8006230093 | |
| Download: ML19310A767 (2) | |
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UNITED STATES f,
NUCLEAR REGULATORY COMMISSION y 3 <- (/.
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5 Y.ASHINoToN 3. C. 20555 g
JUN 3 1980 Mr. and Mrs. Karl M. Uchrinscko 613 H. Garfield Ecwarcsville, I'.
62025
Dear Mr. anc Mrs. U:
hrinscko:
This refers to your March 23, 1980 letter to Representative Paul Findley concerning a recent Nuclear Regulatory Comission investigation at the Fermi Nuclear Power Station construction site.
This investigation was prcmpted by certain AEC television allegations, which were recently discussed on the television program 20/20, that unqualified technical personnel have been e pioyee as designers and technicians at the Fermi construction site.
The Nuclear Regulatory Commission's (NRC) investigation into this matter discicsed that certain Detroit Edison Company activities failed to comply with the NRC's requirements that eff(ctive controls governing small bore pipilig suspension c'esign should have been in effect.
The details of this nonccmpliance by Cett:it Edison are discussed in an enclosure to this letter. With regard tc your specifi: concern with personnel qualifications at the Fermi site, the NF.C investigati:n has determined, that in general the qualifications of these people were ade:;uate to perform their required design function. What was four.d tc be of concern in this regard however, was the fact that Detroit Edision had not established personnel qualification requirements for these design posi icns, nor had the utility performed a proper review of the final design prod.ct.
The uttiity has been subsequently issued a Notice of Violation which requires appropriate ccr ective action and steps to prevent a recurrence.
The enclosed uti'.ity res:onse to this NRC citation is now being reviewed and evaluated by the ins;ection staff to determine the acceptability of Detroit Edi3cn's croposed acticns.
The specific corrective measures will be subsequently ver'ff ec du-ing a fature NRC inspection.
l THls DOCUMENT CONTAINS POOR QUAUTY PAGES
- I 80062300 Q
r Mr. - and Mrs. Karl M. Uchrinscko We appreciate having the opportunity to respond to your concerns and sincerely hope that you are now convinced that the problems found at the Fermi site as a result of the ABC television investigation have been fully identified and will be corrected.
Sincerely Director Office of Inspection and Enforcement
Enclosures:
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1.
- Investigation Report No.
50-341/80-02 2.
Utility's Response to Citation cc:
Representative Melvin Price Representative Paul Findley Representative Morris Udall Senator Adlai Stevenson Senator Charles Percy Senator Jennings Randolph 9
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s W#.I1 E00 Ibcket No. 50-341 The Detroit Edison Company Attn: Mr. Edserd Hines Assistant Vice President and Manager Quality Assurance 2000 Second Avenue Detroit, Michigan 43226 Gentlemen:
This refers to the investigation conducted by1 Messrs'."G. A. Phillip? '
t I. Tc Yin and C. Mr Erb of this office on~,lanu~ary 21-23 a6d February 11-12,.m.
1980, of activities at the Enrico Fermi 2 Muclear Power _ Plant _ authorized--- as-- _
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by MRC LicenWNo. CPPR-8 Land to the discussion of our findings with youT ~ - ~ ~-
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--.l and others at the, casc1Hf5n of'the-investigatTon. ~;~: = -
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This investigation was deducted-to determine the substance of a
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i tion that the qualifications of, and the work performed by, personnel in the site small bore pipe support design group were inadequate. The enclosed cr~ of our investigation report identifies the areas examined during this investigation. Within these areas, the investigation consisted of a selective examination of records and procedures; observations and inter-views with personnel.
During this 15estigation, certain of your act ities appeared 'to"be 'in s
noncompliance with MRC requirements, as described.in the enclosed Appendix
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This notice is sent to you pursuant to the pewisions of Section 2.201 -
ef the NRC's " Rules of Practice," Part 2, Title 10. Code of Federst Regulations. Section 2.201 requires you to semit to this office within thirty days of your receipt of this notice a written statament or explana-tion in reply, including for each item of noncompliancer 11) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncospliance; and (3) the date when full compliance will be achieved.
In addition, your response should include the actior.s you plan to take to verify that the semil diameter piping already designed and/or installed meets appropriate design specifications.
In accordance with Section 2.790 of the stCfs-* Rules af Practice,' Part 2..
Title 10, Code of Federal Regulations, a copy ~of this letter, the enclo -
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sures, and your response to this letter will be placed in the MtC's P.tli:
glop ?
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The Detreit Edison Cenpany -
Document Roca, except as fbilows.
If the enclosures contain information that you or your contractors believe to be proprietary, you est apply in writing to this office, within twenty days of your receipt of this letter, to withhold such information from public disclosure. The applica-tion must include a full statement of the reasons for which the taformation is considered proprietary, and should be prepared so tMt proprietary in-formation identified in the application is contained in an enclosure to the application.
We will gladly discuss any que:tions yee have concerning this investiga-tion.
j i
sincerely, i
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' James E. Keppler
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,.. D1 rector
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Enclosures:
- #7 " ~~ ' " "
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1.
Appendix A, Motice of violation 2.
IE Investigation Report No. 50/341/80-02 cc w/ enc 1; p
Reproduction Unit NRC 20b PDR local PDR
. NSIC
"~____.
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TIC Ronald Callen, Michigan Public Service Cc::tission Eugene B. Thenas, Jr.,
Attorney l
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4 Accendix A NOTICE OF VIOLATION The Detroit Edison Company Docket No. 50-341 Based on the investigation conducted on January 21-23 and February 11-12, 1980, it appears that certain of your activities were in noncompliance with NRC requirements, as noted below.
This is an infraction.
10 CFR 50, Appendix B, Criterion III states, in part, that " Measures shall be established to assure that applicable regulatory requirements and the design basis... are correctly translated into specifications, drawings, procedures, and instructions."
The Enrico Fermi 2 FSAR, Section A17.1.3 states, in part, that " Edison has established and implemented procedures which delineate the design process from initiation through final approval and release, and deter-mine that design activities have been and are carried out in a planned
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and controlled manner, and that plant design adequacy is verified and documented."
Centrary to the above, the control of small bor_e.pjping suspension design was considered to be inadequate in that:.
a.
The work performed by Wismer & Becker during 1977 and 1978 was accomplished without approved procedures.
b.
Insufficient guidance was provided by the DECO Enginecring Depart-ment 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, indoctrination, and training requirements had not been established for the DI Small Bore design group.
In addition, numerous installation deficiencies were identified that are an indication of this lack of design control.
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i U.S. NUCLEAR REGUI.ATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 50-341/80-02 Docket No. 50-341 License No. CPPR-87 Licensee:
Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 1
Facility Name: Enrico Fermi 2 Dates of Investigation:
January 21-23 and February 11-12, 1980 Investigation At: Monroe,-MI
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G. A. Phillip/
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I./T. Yin Date
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0.90 $kh 3/7/R C. M. Erb Dat( /
Reviewed by:
3/'0!O C. E. Norelius Date Assistant to the Director
..TC 3 [7// d D. H. Danielsen Date Chief, Engineering Support Section II Investiration Suzcarv:
Investigation on January 21-23 and February 11-12, 1980, (Recort No. 50-341/80-02).
Areas of Investiga-doc:
In response to an allegation that g rsonagg % v' the on-site pipe support des (79 4 @ M Q'~'" T M ! M *3f %,D b -
viewed pertinent procedures
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F" components and interviewed p investigation hors by three-DUPLICATE DOCUMENT v.en1*ei The in>estigat,cn Entire. document.previously quire =ents had ne: :een esta desig -ret:t and the':: :r01 entered into s stem under:
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adequate. Cte ite: cf n:n:c-A:pendi: 3, Criterien I!I, E Q
ite=s were als: iden:ified.
No. of Pages:
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November 28, 1979 Mr. Harold Thornberg Division of Reactor Construction Nuclear Regulatory Commission 4350 East-West Highway Bethesda, Maryland r
Dear Mr. Thornberg:
During our research for the 20/20 segment, "N u c le ar cons t ruc tion",
we have found the following:
- 1. A fundamental la ck of qualifica tions in th e on site design engineering groups at the Fermi II plant particularly in the pipe support area. This includes doctored resumes, an apparent nepotistic situation and.a general lack-of eeperience amongst designers, checkers and supervisors.
- 2. The use of a contract engineering firm, QUAU-TECH, to supply
'" qualified" personnel. Quan-te ch.h t.s -a p oo r reputation in the field and has admit ted to a failure to sdequately check the backrounds of employees.~
- 3. A nationwide problem with engineering pe rs onne l who are recent
.= migrants or resident aliens who have great difficulty executing their work due to language and co==unication problems. This has been reported to us by engineers who have worked at numerous sites around the Unite d States.
- 4. Fear amongst workers and engineers on site to raise questions about the quality of work and proceedures due to retaliation by employers.
- 5. Specific informa tion concerning va rie ty of welds and genersi a
velding conditions ( cle an lin e s s, etc.) at the Fer=i 11 plant, e.g.
the doctoring of s tainles s steel velds in the control cable pipes and supports. Field Weld #8. etc.
- 6. The use of under and unqualified personnel at Duke Power's Charlotte,!
North Carolina f a cilit.ie s in the pipe support and seismic stress design e r... n ering a reas as well as allegedly subs tandard enrineers supplied by Still another agency, NUCLEAR POUER SERVICIS.
- 7. The lack of any set standards.in the industry for. design engineers
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a r. d the qualifications for these positions.
The above informatica has been accu =ulated by checking resumes we had 1
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Mr. Harold Thornberg November 28,.1979 page 2 l
i in our possession, interviews with engineers, construction workers and individuals working or affiliated with contract engineering agencies.
We appreciate your coopera tion in investigating these matters.
P
. nearely.
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a ye Myatt Lowell Bergman
'Produ.er Producer V
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cc: James C.
Keppler
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Exhibit A Page 2 of 2 o
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"I l'ay 13,1980 m..
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EF2-48,997 Mr. Jares G. Kepoler, Director U.S. ::uclear Regulatory Commission Regicn III 799 Roosevelt Road Glen Ellyn, _ Illinois 60137
Subject:
f:encemoliance at Enrico Fermi Unit 2 Construction Site.
Cear,Mr. Keppler:
This letter responds to the infractions contained in your IE Report 50-341/80-02 resulting frem the construction activities inspection c:nducted by t'essrs. G. A. Phillip, I.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 ceriod.
The cited infraction mentioned in your report is discussed in this reply as required by Section 2.201 of the flRC'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 enciesed res;cnse is arrangeo to the secuence of items cited in the b:dy of., cur report.
The findina and section numbers are refer-e r.c ed.
'*e trust this letter satisfactorily answers the concerns raised in ycur re: ort.
!'e shall be glad to discuss any further concerns you ray i,1ve.
Very truly yours,
( !! u.~~rt*t-c,f*/ m 11,
EY!H'd.'/pn Erc', osure cc:
"r. G. Ficrelli, Chief
~ actor C nstruction ar.d Engineer.ing Support Branch e
U.S. ::u: lear 'egulatory Ccmmission
-Eeci:nIII'.].~kcad
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9.^30 Se'.'e s 1
cc:
U. S. Nuclear Reaulatorv Commission
.:len -llyn, 4 ilinois 60137 g333;3g.en, D. c 20555
". 'lict,r Stello, Jr., Director c/c Jim G:ynn
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- e Of : s e: tion and Enforcement Eas:-wes Tc.ve rs
- i.isi:r Of ?.n : or Inspection Programs
'350 East-west Hig.say U. 5. *.u:Isar Regulatory Commission Ee:,esda,.M0
,:as-in; :nc D.C.
20555 A'
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THE DETROIT EDISON COMPANY OUALITY ASSURANCE DEPARTMENT ENRIC0' FERMI 2 PROJECT Response to NRC Report No. 50-341/80-02
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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:
ar~
H.A. Walker Supervisor, Construction Ouality Assurance Approved by:
Ib T.A. Alessi Director, Project Ouality Assurance Detroit Edison Company l
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i Resc6r.se tc 'NRC Report 750-341/20-02 Page One Staterent 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:
The work performed by Wismer and Becker during 1977 a.
and 1978 was accomplished without approved procedures, b.
Insufficient guidance was crovided by the DECO Engi-neering Department in their standardized chart and table type design methods.
Acceptance review was not conducted by the DECO c.
Engineering Department on a systematic basis.
d.
Personnel qualification. certification, indoctrina-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.
t SECTION II l
Findine No. la l
The calculations perfomed by Wismer and Becker personnel from October 1977, to Decer.ber 1978, were considered to be questionable since for-nal: procedures and acceptance criteria had not been established for the activities performed.
The inspector statef that all work involved should be reviewed and approved in a timely manner by qualified engi-neers.
Respense No. la Corrective Action Taken and Results Achieved Wismer and Becker parformed small bore design work (including calcula-tions) during 1977 and 1978.
Daniel Interne.tional began performing
- small bore design in January cf 1979.
A Wismer and Becker small bore design procecure (UB-E-122) was issued for use May 15, 1978.. Design was
- perfcrmed.from Cctober 1977 te May 1978 withcut a procedure rather than to'Cece.?ber 1975 as indicated in the ins ecticn report.
Response to NP.C Report #50-341/80-02 Page Two Corrective Action Taken and Results Achieved (cont'd)
The Pipe Routing and Support Location (-1) drawirigs', 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 prar.ently 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 subinitted 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 Design 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 Noncomoliance Wismer and Becker is no longer responsible for small bore piping design. The Small Bore Design Group, who is presently performing small bore piping design, has procedures approved and in use and pre-sently reports to Edison Field Engineering.
Date 9n Full Connliance t'ill Fe Achieveri The re-revieva 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.
Findinc No. Ib Field Design Change Request (DCR) No. SB-0315A was written on May 30, 1979, and approved on June 26, 1979, to provide tne design basis for small bore pioing configuration and suscensien. A review of this DCR revealed a number of program and technical deficiencies:
L The DCR was initiated by a Daniel fiele engineer and contained l
engineering design requirements which shculd have been incorpor-l ated into DECO Specification No. 3071-31, ":i:e Erection". Revi-sicn 3, dated April 1979.
This DC7 -as a;;;reved oy the DECO field en;ineer. The inspector statac tha; the a::roval anc t.
Rescor.se :: NE: :ecort #50-3/.1/80-C2 Page Tr.ree Findinc Nc. 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 2b", 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.
Ccrrective Action Taken and Results Achieved
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Changes are being nade to the Project Procedure Manual to address this probled.
Corrective Action to be Taken to Avoid Further Noncomoliance 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 DCR/
DCN procedures.to allow such changes to be effected, will still be per-c.itted, but in such cases, approval of the cypropriate DCR or DCN will The Project Proce-be by the Director-Project Design or his Assistant.
cures Manual will continue to allow non-criteria tyoe changes to Pro-ject Specifications to be approved by the Edison Director-Field Engi-neering or his delegate, who has his signature authcrity.
will be expanded to show the requirements and load ratings DCR 55-0315 The DCR will for pipe lugs on piping in the 2h" through 4" size range.
aise be expanded to incluce references to recogniced test books, design aids and industry standards that are designated to provide guidance in the perforrance of structural calculations which are prepared to demon-strate the adequacy of the pipe support cosigns.
Date VFen Full Comoliance Mill be Achieved c eject Procedure Manual will be revised by May 2,1980.
Tne r
DOP. 55-0315 will be revised by May 16, 1980.
Findi c Mc. 1:
- I Ocrstruction Procetri, Fr A?-IV-05, "Small Bore Piping and Fire D.
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[*1:0nsetoNRCReport 750-341/80-02 rage.-cur Findine 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 femal 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 DECO engineers.
Corrective Action Taken and Results Achieved A log has been prepared by the Small Bore Design Grouo listing the drawing numbers of all ASME III, Class 2 and 3, Seis=le Class I piping drawings, 2" and under in size, which have been or will be prepared by the S=all Bore Design Group.
In addition, the log will list those drawings in the 2 " through 4" size range which have been assigned to the Small Bore Cesign Group by Edison Design Engineering.
In addition to the drawing number, the log will be expanded to show the following inforration.
1.
Date submitted to Edison Field Engineering for approval.
2.
Cate Edison Design Engineering approval or comments are received.
3.
Date Edison Design Engineering comments are reconciled and appro-vai 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).
S.
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.
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-ing (-2) for piping 2h" through 4" in size; the analytical drawing (-3) and the analytical work sheets for all ; icing 4" in size and smaller, which are prepared to demonstrate compliance with the Small Bore Design standard.
.Ce-rective Action to be Taken t: Av id % -ther Nencomoliance Etistn Design Engineering will pre;:are an inte nal written procedure r
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Response to NRC Report 750-341/80-02 Page Five Corrective 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 review of a statistically significant number of the detailed support design sketches and their back-en structural calculations.
These reviews will be conducted by personnel from Edison's Design Engineering organ-ization who are skilled in pipe suoport and/or structural design; similarly skilled personnel provided by Edison's Engineerin~g Consul-or tants. - All reviews will be conducted in accordance with written cri-teria prepared by Edison Design Engineering and will be accropriately documented.
The reviews will cover design work done under both Wismer and Becker and Daniel Administration.
tate When Comoliance is Exoected to be Achieved-1.
The expanded drawing log will be availabie_on site by May 16, 1980.
l 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 avgilable 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. ld The DI Construction Pro:edure AP-IV-05, Revision 0, stated in cart, tnat "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 Ho. 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.
Resconse No. Id.
Corrective A: tion Taken and Results Achieved M S:.all Pising Design Standard, augmented by soecial supplemen.31 i
tnamal expansion cesign taoies pre:ared by Edisen Design Er.gir.eering i.
ca 'ce used to design all ASPE'111, Cisss 2 and 3 Picing Systees of 4" r:r-tral _ pipe si:e or smaHer:
p evidet the Cesign Pressure cces n:.
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Response to NRC Report *50-341/80-02 Page Six s
i Corrective Action Taken and Results Achieved (cont'd) exceed 1750 esig 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 2 " through 4" size range, since design of piping systems in these size ranges is normally more effectively accomplished using traditional computerized analysis 1
techniques.
Those piping systems in the 2h" 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 Engineering to the Edison Chief Field Design Engineer.
Corrective Action to be Taken to Avoid Further Honcomoliance If further assignments are made, the memorandum referenced above will be appropriately revised and reissued.
Date When Full Comoliance Will be Achieved The action described abqve has been completed.
Findina No. le Since the DI Small Bore work group is a part of the design engineering 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 requirements were not visible during the inspection.
Resoonse 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 Noncomoliance Minimum jcb qualification standards for persennel working in the Small Ecre Design Group on site are bein; formulated and issued by Edison.
These standards wi~.? 't considerec in the initial selection of candi-dates fer employment i the Small Ecre tesign Group.
The decision to e
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Eesponse to N.0 Report #50-341/E0-02 Fage Seven Corrective Action to be Taken to Avoid Further Honcomoliance (cont'd) retain a person after initial assignment, will continue to be princi-pally goverr.ed by the results of the detailed checking of his work assign, ents.
In addition, a femal seminar addressing the important parameters /
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 Comoliance Will be. Achieved -T--" -' '.*-
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The job qualification star.dards will be~publiiiihed3ydiaF2,"-1980.(( _ _
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The seminar will be presented in-Gune~,1980F
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