ML19318B575
| ML19318B575 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/17/1980 |
| From: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Callen R MICHIGAN, STATE OF |
| References | |
| NUDOCS 8006270082 | |
| Download: ML19318B575 (9) | |
See also: IR 05000341/1980002
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PJUN 1 71980
Docket No. 50-341
Michigan Public Service Commission
ATTN:
Mr. Ronald Callen
Law Building
Lansing, MI 48913
Gentlemen:
Subj ect: Detroit Edison's Response to NRC Inspection
Report No. 50-341/80-02
Due to an error the attachment to Detroit Edison's response to NRC
Inspection Report No. 50-341/80-02 was not included.
We are sorry for any inconvenience caused you.
Sincerely,
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Gaston Fiorelli, Chief
Reactor Construction and
Engineering Support Branch
Attachment: As stated.
cc w/ attach:
Central Files
Reproduction Unit NRC 20b
Local PDR
Eugene B. Thomas, Jr.,
Attcrney
8006270082
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THE DETROIT EDISON COMPANY
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QUALITY ASSURANCE DEPARTMENT
ENRICO FERMI 2 PROJECT
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Response to NRC Report No. 50-341/80-02
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:
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fl. A. Walker
Supervisor, Construction
Ouality Assurance
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Approved by:
T.A. Alessi
Director, Project Quality
Assurance
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Detroit Edison Company
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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
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and 1978 was accomplished without approved procedures.
b.
Insufficient guidance was provided by the DEC0 Engi-
neering Department in their standardized chart and
table type design methods.
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c.
Acceptance review was not conducted by the DECO
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
co.ntrol.
SECTION II
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Finding No. la
The calculations perforced by Wismer and Becker personnel from October
1977, to December 1978, were considered to be questionable since for-
mal procedures and acceptance criteria had not been established for
the activities performed. The inspector stated that all work involved
should be reviewed and approved in a timely manner by qualified engi-
neers.
Response No. la
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Corrective Action Taken and Results Achieved
Wismer and Becker performed small bore det*gn work (including calcula-
tions) during 1977 and 1978.
Daniel Intem.ational began performing
small bore design in January of 1979. A Hismer and Becker small bore
design procedure (llB-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.
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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 Pecker, were reviewed and approved by Edison Design
Engineering; as i' those presently being produced by the group under
Daniel Administri'
These reviews are to confirm the adequacy of
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the piping confi,
,, piping material selection and pipe support
spacing, locatior.
- a-tation. All of the above documents will be
re-reviewed by Edise
1 Engineering as these documents are up-
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dated to the "as-built" condition and submitted for engineering appro-
val.
Due to the extensive nature of these reiiews, no further need
for corrective action is perceived.
Detailed pipe support design sketches, and their respective back-up
structural calculations produced by Wismer 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
Findino No. lb.
Corrective Actio,n 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 performing
small bore piping design, has procedures approved and in use and pre-
sently reports to Edison Field Engineering.
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Date l' fn Full Connliance "ill te Achieved
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The re-reviev 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 skatches will be as described in the response to
Finding No. ic.
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Findina No. lb
Field Design Change Request (DCR) No. SB-0315A was written on May 30,
1979, and approved on June 26, 1979, to provide the design basis for
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small bore piping configuration and suspension.
A review of this DCR
revealed a number of program and technical deficiencies:
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The DCR was initiated by a Daniel field engineer and contained
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engineering design requirements which should have been incorpor-
ated into DECO Specification No. 3071-31, " Pipe Erection", Revi-
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sion B, d:+ ed Apri'.1979. This DCR was approved by the DECO
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)
issuc. ice 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
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design for 2b",
3", and 4" small bore piping were not included in
the specification or the DCR:
however, the DI Small Bore Work
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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 pacifica-
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-
mitted but in such cases, approval of the appropriate DCR or DCN knll
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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-
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neering or his delegate, who has his signature authority.
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
also be expanded to include references to recognized test books, design
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.
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Finding No. ic
DI Construction Procedure, No. AP-IV-05, "Small Bore Piping and Pipe
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Response to NRC Report #50-341/80-02
Page Four
Finding No. lc (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 DEC0
design engineers. There was no formal 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 24" through 4" size range which 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 cocments are reconciled and appro-
val is granted by Edison Field Englaeering (where appropriate).
4.
Date(s) that minor field changes are submitted to Edison Field
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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.
All of the above is applicable to the pipe routing and hanger locatica
drawing (-1) for piping 2" and under in sizt; the hanger location draw-
ing (-2) for piping 25" through 4" in size; the analytical drawing (-3)
and the analytical work sheets for all piping 4" in size and smaller,
which are prepared to demonstrate compliance with the Small Bore Design
standard,
Corrective Action to be Taken to Avoid Further Ncncompliance
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Edison Design Engineering will prepare an internal written procedure
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Response to NRC Report #50-341/80-02
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-up structural calculations.
These reviews
will be conducted by personnel from Edison's Design Engineering organ-
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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.
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The hanger sketch and calculation review criteria will be available by
May 16,1980. The sketch and calculation reviews will be initiatcd by
June 2, 1980.
No firm completion date can be predicted since this is
a function of the Plant Constructic a schedule.
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Finding No. ld
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 DEC0 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, tha
specific conditions were not specified in any document.
Response No. ld
Corrective Action Taken and Results Achieved
The Small ' Piping Design Standard, augmented by special supplemental
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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
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Response to NRC Report #50-341/80-02
Page Six
CorrectiveActionTakenandResultsAchieved(cont'dl
exc.;ed 1750 psig and the Design Temperature does not exceed 575 F.
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Steadard 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 2b" through 4" size
range, since design of piping systems in these size ranges is normally
more effectively accomplished using traditional computerized analysis
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techniques.
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Those piping systems in the 2h" through 4" size range which have been
assigned to the Small Bcre 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 Noncompliance
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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.
Finding No. le
Since the DI Small Bore work group is a part of the design engineering
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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
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requirements were not visible during the inspection.
Ress 1se 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.
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Corrective Action to be Taken to Avoid Further Noncompliance
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Minimum job qualification standards for personnel working in the Small
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Bore Design Group on site are being formulated and issued by Edison.
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These standards will be considered in the initial selection of candi-
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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 continue to be princi-
pally governed by the results of the detailed checking of his work
assignments.
In addition, a formal 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
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Engineering to the incumbent members of the Small Bore Design Group.
This presentation will be video-taped to allow presentation to new
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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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