ML19350E639

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IE Insp Rept 50-341/81-04 on 810421-24.Noncompliance Noted: Use of inter-ofc Memo in Lieu of Approved Procedures for safety-related Work Implementation
ML19350E639
Person / Time
Site: Fermi 
Issue date: 05/22/1981
From: Danielson D, Yin I
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19350E634 List:
References
50-341-81-04, 50-341-81-4, NUDOCS 8106230386
Download: ML19350E639 (6)


See also: IR 05000341/1981004

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U.S. NUCLEAR REGULATORY COMMISSION

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0FFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-341/81-04

Docket No. 50-341

License No. CPPR-87

Licensee: The Detrof.t Edison Company

2000 Second Avenue

Detroit, MI 48226

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Facility Name: Enrico Fermi 2

Inspection At: Enrico Fermi Site, Monroe, MI

Inspection Conducted: April 21-14, 1981

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Inspector:

I. T. Yin

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Approved By:

Danielson, Chief

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Materials and Processes Section

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Inspection Summary

Inspection on April 21-14, 1981 (Report No. 50-341/81-34)

Areas Inspected: Pipe support and restraint installation inspection,

review of procedures, and records; followup on previously identified

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inspection-findings. The inspection involved 20 inspector-hours onsite

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by one NRC inspector.

Results: Of the areas inspected, one apparent violation was identified.

(Use of inter-office memorandum in lieu of apprcvei procedures for safety

related work implementation - Paragraph 2.)

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DETAILS

Persons Contacted

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Detroit Edison Company (Deco)

  • W. J. FaFener, Manager, EF-2
  • T. A. Ale.si, Director, Project QA
  • D. Spiers, Director, Field Engineering
  • J. H. Casiglia, Supervising Engineer
  • L.'Bertani,. Chief Field Design Engineer
  • S. H. Noetzel, Assistant Project Manager

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  • J. A. Cartmill, Assistant Project Superintendent
  • C. R. Bacon, Assistant Director, Field Engineering
  • D. A. Wells, Manager, QA
  • J. J. Gessner, Assistant Director, PQA
  • H. A. Walker, Supervisor, Construction QA

. *W. A. Boelder, Assistant Project Manager

  • G. Carter, QA Engineer
  • R. Adler, Engineering Workleader
  • A. J. Grates, Engineering Assurance
  • E. A. Ncwton, Plant QA Engineer

R. Kennedy, Field Engineer

Daniel International Corporation (DI)

  • J. C. Ard, Construction Manager
  • B. N. Dennehy, Project QA Supervisor

Stone and Webster Engineering Corporation (S&W)

  • J. McSheffrey, Senior Engineering Mechanics Engineer

J. J. Oliver, Jr., Principal Pipe Support Engineer

Townsend and Bottum, Inc. (T&B)

B. G. Ashby, QC Supervisor

USNRC:RIII

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  • P. M. Byron, Resident Inspector
  • Denotes those attending the exit meeting on April 24, 1981.

Licensee Action on Previously Identified Items

(Closed) Unresolved Item (341/73-03-01):

In review of licensee followup

of IE Circular No. 76-05, it was noted that there was an apparent lack of

licensee review of the response to NRC for significant position changes

such as use of mechanical snubbers in i.eu of hydraulic snubbers. The

inspector reviewed the DECO Project Pracedures Manual, Part I - Policies

and Responsibilities, Section 8.0 Project Engineering, Revision 8, dated

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August 1, 1977. Attachment A, Project System Engineer Responsibilities

and Duties, states " Assure Commitments made to the NRC and other regula-

tory-bodies concerning design or operational criteria of assigned systems

are met."

The inspector had no adverse coements and was assured that.the

licensee will inform Region III of any significant changes to the responses

to IE Bulletins and Circulars.

(Open) Unresolved Item (341/79-03-04): Review of S&W hanger calculations.

The inspector reviewed S&W Cal;ulations:

(1) Z-E11-045, Revision 1, dated

July 28, 1980, for snubber assembly No. E11-3035-G25, and (2) 2-P44-035,

Revision 0, dated May 2, 1980, for spring hanger assembly No. P44-3345-G26,

and had no adverse comment. However, calculations for the design of seismic

guide assembly No. P44-3345-G24, including the baseplate bolt pattera

. revisions, were not available for review at the site. The inspector was

informed that calculations were being prepared at the S&W Cherry Hill office.

(Closed) Unresolved Item (341/79-16-02): GE review of ITT-Grinnel hanger

calculations and the design of recirculation loop pump hangers. The

inspector reviewed the DECO Audit Report of GE, Nuclear Energy Projects

Division, performed on June 11 to 13,1979, and the audit item closeout

letter, EF2-49,932, dated February 5,1981, from DECO Director, Project

QA to GE Project Manager, EF2 Project, and considered the licensee audit

and the followup on the open items to be adequate.

(Closed) Unresolved Item (341/80-02-02): Design Change Requests (DCRs)

involving specification and criteria revisions that had not been approved

by DECO Desiga Engineering Department. The inspector reviewed DECO

Project Procedures Manual, Part II - Procedures, Appenddx B - Engineering.

Section B.3.0 - Configuration Control, Revision 24, dated September 22,

1980, and considered the licensee's actions to be adequate.

(Closed) Unresolved Item (341/80-02-03):

Control of DCRs/DCNs for DECO

Specification 3071-31. The inspector reviewed DECO correspondence

EF2-52,157, dated April 23, 1981, where it stated that there were 36

open DCRs/DCNs, among which 23 involved generic design changes and were

approved by the Director of Project Design. The inspector stated that he

had no further questions at this time.

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(0 pen) Unresolved Item (341/80-16-01): Lack oi clarifiestion of design

and installation work interfaces, operation, surveillance, and audit re-

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sponsibilities. The inspector reviewed the site correspondence F2S80-2349,

dated December 24, 1980, which contained a document entitled, " Flow Process

of a Pipe Support (QAI)", and considered it to be unacceptable. The li-

censee committed to provide the inspector more detailed program descriptions

for his review during a future site visit.

Functional or Program Areas Inspected

1.

Licensee Implementation of IE Bulletin 79-14

The inspector reviewed the licensee letter, EF2-50,637, dated

October 30, 1979, to Region III. The proposed actions were

considered adequate for:

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Ik" and larger lines to the' outer isolation valves constructed

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to ASME III, ANSI B.31.7 Class I, and analyzed to ASME III,

Subsection NB-3000 requirements.

Seismic Class I lines designed to ASME III Class 2 and 3 or

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ANSI B.31.1 requirements.

The following DECO Project Procedures Manual, Part II Procedures

were reviewed by the inspector and were considered to provide

efficient measures to ensure construction meets the design intent:

Section 3, Procedure 3.28, " Design Specifications," Revision 0,

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dated April 28, 1981.

Section 3, Procedere 3.7, " Stress Reports," Revision 0, dated

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April 28, 1981.

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Section 3, Procedure 3.23, "As-Built Drawings," Draft, dated

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March 17, 1981.

The field inspection requirements of Class I piping systems were

documented in Edison Field Engineering Work Procedure FE-WP-2,

" Class I As-Built Grcup Procedure For Stress Report Reconciliations",

Revision 0, dated July 28, 1980.

No items of noncompliance or deviations were identified during the

program review. The inspector concluded that the licensee's provisions

for implementation of IE Bulletin No. 79-14 requirements were adequate.

2.

Followup of Licensee 10 CFR 50.55(e) Item -

On February 20, 1981, DECO verbally reported to Region III that QC

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personnel for one cf the site contractors noted a crew from another

site contractor working on a pipe support'which had been QC inspected

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and accepted previously. Among the 75 affected supports,12 were

determined not to have been re-installed per design requirements.

An interim report per 10 CFR 50.55(e) was forwarded to Region III on

March 20, 1981 (CECO Document No. EF2-49,948), describing the problem.

In review of the licensee's measures to resolve the problem, the

inspector noted the following D1 memorandums were issued in lieu of

controlled work procedures:

DI Construction Management memorandum, DI C81-1543, issued from

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the Project Manager, " Method of Disassembling and Re-assembling

of Pipe, Conduit, and Cable Tray Supports," dated April 2,1981.

b.

DI_ Construction Management memorandum, DI C81-0965, issued from

Piping / Mechanical Manager, " Method of Disassembling and Re-

assembling Pipe Supports," dated February 25, 1981.

DI Construction Management memorandum, LI C81-0284, issued from

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Piping / Mechanical Manager, " Pipe Support Interfacing with Piping /

Mechanical Installation."

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The use of inter-office memorandums in lieu of approved work procedures

or instructions bypasses document control requirements, . including

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issuance, review", approval, and distribution to the designated work

locations. This is an apparent item of noncompliance identified 'in

Appendix A (341/81-04-01).

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3.

Observation of Work and Review c f Records

Typ large air operated valves with heavy eccentric ma s (V9-200!

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and V9-2006) were observed in systems 3" G11-6M72/-3658-1 and 3"

G11-6M721-3659-1 above the torus. The inspector questioned whether

or not the seismic effects of the eccentric . valve weights had been

taken into consideration in the stress analysis.

In. review of DECO

Calculation No. 832, "Drywell Penetrations X-18 and X-19. Floor and'

Equipment Drain Discharge Piping Stress Calculation," dated

' January 30, 1980, it was found that maximum primary stresses for

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OBE and SSE were both within the ASME Code Section III Class 2,

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1.2 S and 1.8 S all wables. Modeling of the systems was also

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consiBered to be correct.

b.

. Total gap of 3/16" in one direction was measured at Seismic

Restraint No. E11-2183-G11 on the RHR Service Water Return

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System in the RHR Building. The inspector reviewed DECO

DCR No. P-5757, dated November 14, 1980 19 placing Appendix G

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of DECO Specification 3071-31, Revision C, and considered the

3/16" :learance was within the design acceptable tolerance.

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During subsequent discussions with the DECO design engineering

staff on May 14, 1981, it was determined that the total maximum

gap in any one direction inside the box frame type seismic re-

straint'should be limited to'3/32" per S&L criteria and 5/32"

per S&W criteria. The licensee committed to revise the affected

DCR and' specification, and re-inspect all related gap measurements.

This is an unresolved item (34!/81-04-02).

Unm7en bearing surface between the riser shear lugs and the pipe

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clamp was observed at Hanger No. E11-2179-G12 on RHR Complex

Service Water Supply System in the RHR Building. The DECO design

engineer determined that point supports after local yielding to

achieve load stability were considered acceptable. However, the

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licensee committed to check if there were shear' lugs that were not

in contact with pipe clamps. This is an unresolved item

(341/81-04-03).

d.

A pair of rigid struts were observed being installed approximately

16' apart. The Mark Number was identified as E11-2179-G18. The

inspector discussed with the TECO design engineer on 13y 14,1981,

relative to the design requirements of the assembly including the

loss of motion due to spaces between the inner ball bushings and

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the retaining outer raceways within the ball joint units. The

licensee stated that they had discussed this with S&L engineers

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and that this and another hanger, Mark No. E11-2180-G18 will b .

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modified. This is an unresolved item (341/81-04-04).

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Unresolved Items

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Unresolved items are matters about which more information is required

in order to ascertain whetlher they are acceptable items, items of non .

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compliance, or deviations. Three unresolved items disclosed during the

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inspection are discussed in Paragraphs 3.b., 3.c., and 3.d.

Exit Interview

The inspector met with ' site staff representatives (denoted under Persons

contacted) at the conclusion of the inspection on April 24, 1981. The

inspector summart ed the purpose and findings of the inspection. The

licensee acknowledged the findings reported herein. Additional findings

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were discussed with the licensee's design staff on May 14, 1981, during

a telephone conference.

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