ML19320B575

Responds to NRC 800324 Ltr Re Violations Noted in IE Insp Rept 50-341/79-25.Corrective Actions:Controlling Procedure to Notify QC Personnel of Needed Pipe Weld Repair Has Been Revised

ML19320B575
Person / Time
Site:	Fermi
Issue date:	06/09/1980
From:	Hines E DETROIT EDISON CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19320B570	List: ML19320B575
References
EF2-49, EF2-49-000, NUDOCS 8007140481
Download: ML19320B575 (5)

Text

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Q .ut I, A s M Detroit June 9, 1980 EF2-49,000 Edison =uu . e a, 1" , . n .,

Mr. G. Fiorelli, Chief Reactor Construction and Engineering Support Branch U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn. Illinois 60137

Subject:

Supplemental Response to Inspection Report No. 50-341/79-25.

Dear Mr. Fiorelli:

This letter contains the additional information concerning actions taken on the Fermi IT Project to control conditions adverse to quality as requested in your letter dated March 24, 1980. The attachment to this letter provides a summarized history of actions taken relative to activities identified in your Inspection Reports as being in noncom-pliance with 10CFR50 Appendix B, Criterion XVI, " Corrective Action".

There are four basic procedures which have been developed for use on the Fermi II Project to provide instructions for identifying causes of problems and/or obtaining corrective action to prevent recurrence of significant conditions adverse to quality. These procedures have been generated and revised when determined necessary to improve and assure adequate corrective action. Following is a description of the proce-dures, or portions of the procedures, which pertain to this subject:

Deviation Disposition Request (DDR), Procedure No. AP-VII-02. In 1.

general, this procedure describes the methods used to identify, document, control, disposition, provide corrective action, notify affected personnel and close out deviations. More specifically, the procedure requires the Contractor / Daniel Engineer responsible for dispositioning the deviation to determine the cause of the nonconformance. A statement is to be provided on the DDR form reflecting the cause and dese 'bing the action to be taken to pre-vent or minimize recurrence of similar types of nonconformances.

In the event preventive type corrective action is not applicable, it is to be so noted on the f orm with a statement of justifica-tion. The Contractor / Daniel QC Manager is responsible to assure that the corrective action statement is appropriate and that implementation of the action is capable of being verified. Prior to closing a DDR, the Quality representative verifying completion of the disposition is responsible to assure that the corrective action has been accomplished or is in progress. Supporting docu-mentation for implementation of corrective action is to be referenced or attached to the form.

JUN 2 01980 140 g

p Mr. G. Ficralli Juna 9, 1980 Page Two EF2-49,000 v

2. Corrective Action, Procedure No. AP-VII-08. This precedure des-cribes the method used to identify and report observed or poten-tial conditions adverse to quality. It provides for determining the cause and obtaining positive corrective action to preclude or minimize future occurrences. Qu.Mey problems identified during surveillance, inspection, or by r uiew of 4DR's are reported on a Corrective Action Report form (the )rocedure requires review of DDR's to determine existence of general quality trends). The reports are sent to the responsible personnel for action. Copies of the reports are distributed, as a minimum, to the Daniel Pro-ject Manager, Detroit Edison Project Superintendent, QA Manager, and responsible Discipline Manager. Quality personnel are required to verify adequate action has been taken to correct the adverse condition prior to closing.

3. Project Audit Response, Procedure No. AP-II-07. This procedure provides a standard format for response to Project Audit Finding Reports. It includes monitoring of open status by an individual (Project Audit Coordinator) who reports to the Daniel Project Manager. If responses are not submitted within the time pre-scribed, the Project Audit Coordinator notifies the responsible Daniel Discipline Manager and Daniel Project Manager of the delin-quent response for resolution.

4. Stop/ Start Work Authority, Procedure No. AP-II-04. This procedure identifies the Project Personnel who have authority to issue stop work orders and describes the method to be used to implement this action. Stop work action is provided if the controls discussed previously are insufficient in obtaining adequate corrective action.

5. Reorganization of Site Quality Organization. The site quality organizations of Edison and Daniel have been combined to provide a more effective organization. This additional effectiveness will be reflected in corrective action as well as other areas associattd with quality.

All actions taken to provide effective corrective action are closely l monitored and additional changes are made as needed. l We trust this letter addresses the additional concerns indicated in your letter of March 24, 1980. We will be glad t .11scuss any further

. concerns you may have.

Very truly yours,

f. L %f.W j i

EH/ HAW /pn Attachment J 4

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Junn 9, 1980 Mr. G.' Fir.rsili.

Page-Three EF2-49,000 cc: .Mr. Victor Stello, Jr., Director Office of Inspection and Enforcement Division of Reactor Inspection Programs U.S. Nuclear Regulatory Commission Washington D.C. 20555 Mr. Bruce Little, Resident Inspecter Office of Inspection and Enforcement Enrico Fermi 2 Construction Site Newport, Michigan 48161 i

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e-Attachment to Letter EF2-49,000 HISTORY OF ACTIONS TAKEN TO CONTROL ACTIVITIES ADVERSE TO QUALITY FOR THE FERMI 2 MECHANICAL CONTRACTOR

1. NRC Reference 50-341/78-08, Appendix A, Item 2.

Description - Unacceptable pipe weld configuration prior to start of welding; arc s' rikes in weld groove.

Cause - QC Inspector did not make accurate measurements at time of fit-up inspection.

Corrective Action - Go/no-go gauges were issued to QC personnel for use during fit-up inspection.

2. NRC Reference 50-341/78-11, Appendix A.

Description - Contractor personnel failed to promptly identify, report and take corrective action relative to pipe weld repair.

Cause - QA/QC Program deficiency which lead to repairs of the weld root without QC inspection after excavation.

Corrective Action - Revised controlling procedure to provide noti-fication to QC personnel of this type of repair allowing for inspection to be performed.

3. NRC Reference 50-341/78-14, Appendix A.

Description - Deficiencies relative to pipe hanger installation had not been corrected from bby to August, 1978, and no plan for corrective action to prevent recurrence was evident.

Cause - Deficiencies were recorded on pipe hanger inspection reports instead of Deviation Disposition Request (DDR). The deficiencies were not brought to management's attention.

Corrective Action - T'.e installation procedure was revised. A Trending Program was established for pipe hangers to detect adverse trends. A stop work order was issued to provide for additional training to personnel involved in pipe hanger installation.

4. NRC Reference 50-341/78-16, Appendix A.

Description - Contractor personnel failed to promptly identify report and take corrective action relative to pipe weld repair.

Cause - Welder's. inability to identify the configuration of weld joint as being in noncompliance with procedural requirements after grinding out an area of porosity.

Attachment to Letter EF2-49,000

, Page Two Corrective Action - Work was stopped and welders were given exten-sive training relative to weld procedures, weld repair, and actions to be taken when weld parameters are exceeded.

5. NRC Keference 50-341/79-07, Appendix A.

Description - Pipe hanger installation deficiencies were not promptly corrected; similar installation deficiencies con-tinued to occur.

Cause - Pipe hangers continued to be installed with low priority for correcting previously identified discrepancies.

Corrective Action - Work was stopped. A corrective action plan was established which included: (1) establishment of a maxi-mum time limit for inspection of hangers; (2) reporting monthly trend reports to Management personnel; (3) increased surveillance of installation activities; (4) auditing hanger installation activities.

6. NRC Reference 50-341/79-16, Appendix A.

Description - In the area of pipe hangers several problems were identified in various areas including design, fabrication, work instructions, traveler package content, inspection, and release of additional hangers beyond what was permitted by a stop work order.

Cause - Lack of thorough implementation of previous corrective measures (Reference 79-07).

Corrective Action - Several steps were taken to provide improved control in the pipe hanger area. These included: (1) con-trolled release of pipe hangers; (2) improved trend analysis program for pipe hanger installation; (3) clarification of work instructions for use by craft personnel; (4) further clarification of the hanger installation procedure; (5) addi-tional training for personnel involved in hanger installation activities; (6) increased source inspection of fabricated pipe support.

7. NRC Reference 50-341/79-25, Appendix A Item 2.

Desc'iption - In several instances hold points were by-passed on installation travelers and reported on DDR's. ~ Hold points continued to be by-passed.

Cause - Craft personnel were unaware of the existance of the hold points that were by-passed.

Corrective Action - Several training sessions were held for cri.ft personnel and additional effort has been directed to issuing the documents containing hold points to the work area.

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