ML20027B959
| ML20027B959 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/22/1982 |
| From: | Kintner L Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8210120026 | |
| Download: ML20027B959 (7) | |
Text
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N SEP 2 21982 Docket No.: 50-341 APPLICANT: Detroit Edison Company FACILITY:
Femi 2
SUBJECT:
SU'4tARY OF JULY 15, 1982 MEETING REGARDING FERMI 2 QUALITY ASSURANCE The purpose of the meeting was to hear and discuss Detroit Edison Company's means for assurance that Fermi 2 is designed and built in accordance with safety requirements and to detemine whether additional assurance is needed in light of recent design and construction deficiencies found at serveral plants.
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Y The applicant gave an overview of the Detroit Edison Company (DECO) organization and its management of the design and construction of Femi 2.
DECO has 10 operating fossil-fueled generating plants with 43 units. DECO designed and constructed most of these units. In recent years, however, Deco has been phasing out its engineering and construction division - relying on architect engineering and construction firas to design and build its generating units.
DECO was a major contributor of manpower and money in the design, construction, operation and decoanissioning of Ferni 1, a 60-lfde demonstration fast breeder nuclear plant.
DECO is the architect-engineer for Femi 2.
Sargent and Lundy was used to design several nuclear related structures and systems (e.g. seismic design of Category I piping.) The nuclear stean supply systea was designed by General Electric with construction drawings produced by DECO. Top ~ officers of DECO who authorize resources for Femi 2 have nuclear and engineering experience from the engineering and managenent of conventional Deco plants and Femi 1.
In addition, many of the aangers of the Ferni 2 nuclear plant construction and operation organizations within DECO have long experience from other plant operations of the conpany, including Femi 1.
Engineers who have worked in the design of Femi 2 are being transfered to the Femi 2 startup aad operating organization to effectively use their knowledge of design of Ferni 2 in its operation.
Construction of Femi 2 was managed at the site by Ralph M. Parsons Conpany until November 1974, when Daniel Construction Company was retained for site construction managenent. Construction was stopped between 1974 and 1977 because of decreased demand for power and reduced funds for construction. During this
. interval, the site construction nanagenent transition was made from Parsons to Daniel.
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. SEP 2 21982 Detroit Edison manages engineering and construction using estabibbed procedures.
Interfaces between engineering and construction and between design contractors are audited periodically.
In 1979, a nanagement analysis consultant was hired to recotxtend improvements. The quality assurance progran wis established in 1969 and has been found to meet the Coamission's regulatior.s in Appendix B to 10 CFR S0.
One innovative aspect of the QA progran is the provision for construction and operations personnel to express their concerns regarding safety and to hear how their concerns are resolved. tiany concerns are resolved by explaining the established quality control procedures but sone are resolved by correcting deficient work.
In response to a staff question, applicant said that newly-hired craftnen are instructed about special aspects of nuclear plants by means of orientation films and by personal instruction of foremen.
Senior and niddle nanagers are strongly involved in decisions affecting their responsibilities and in the quality assurance program. The DECO board of directors discusses Ferai 2 quality assurance at its meetings. The vice president in charge of engineering and construction and the vice president in charge of nuclear operations are inforned in staff neetings each nanth about quality assurance natters (e.g. 50.55(e) reports, inspection reports, problems at Fen 11 2 and other plants.) The nanager of quality assurance reports directly to the president of DECO and is responsible for correspo1dence with the NRC regarding the identification and correction of deficiencies. DECO nanagement participates in the INP0 Oversight Committee and in the Licensing Review Group, estaolished to resolve generic concerns with the flRC.
Quality Assurance The director of Ferai 2 quality assurance currently has 127 people in his organization, including 54 for finish construction and maintenance, 28 for construction, 26 for operating, 5 for procurewnt, and 5 for engineering. These people assure quality in design and construction through:
requiring quality assurance programs for architect engineers, vendors and contractors; design audits; procedura reviews; inspections, and; concurrence of systen completion and testing. As an indication of the effort involved in on-site quality assurance activities, froa the start of construction through February 1982 there have oeen 122 audits and 4,465 inspections. Off-site quality assurance activities include 226 vendor audits,18 architect-engineer audits,1,485 source inspections and 22 audits of Detroit Edison project engineering. There have been 39 construction stop-work orders initiated by the DECO quality assurance organization and 45 reports of design or construction deficiencies as defined in 10 CFR 50.55(e).
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' The staff questioned applicant about the assurance of quality during the early phases of_ design and construction.- In response to this and other questions, applicant provided the following information:
The Detroit Edison quality assurance organization was established in 1969 and it has audited contractors quality assurance prograns since 1971. The principal contractors in the early phases (prior to 1974) were General Electric and Sargent and Lundy. Each of these contrhetors had established quality assurance programs at an early phase of design and construction and have quality assurance topical reports approved by the NRC. The contractors who do not have NRC - approved quality assurance topical reports have been audited -
by DECO. In design auditing teams, engineers having experience applicable to the work being audited were part of the audit team.
When IE Bulletin 79-14. "Seisaic Analyses for As-Built Safety-Related Piping Systen", July 2,1979, was issued, the pipe hangars on Femi 2 had not yet been installed. Therefore, the hangar design was revised to meet the bulletin criteria. The as-built piping hangars are f
reanalyzed to confina that the installed piping hangars meet design
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requiremnts and, if necessary, modifications are made.
-l Engineering The DECO engineering organization for the Fermi 2 project currently includes 225 personnel at Troy Michigan, and 192 personnel at Fermi 2 plant. In addition, the Femi 2 project currently uses approxinately 500 engineers in contractor organizations. Prior to 1974, DECO perforned its own engineering. Since that time, DECO has subcontracted nost of the engineering work and has established I
an organization to control the work of many subcontractors. Design control includes: design verification reviews and checking; vendor document and drawing reviews; design change controls, and; testing. A design change package has been established in,which Shannes to all affected conponents are identified.
All as-built drawings are required to be modified within 90 days of a field change.
The Fermi 2 engineering organization has conducted several design reviews and verification programs. One of the principal reviews was made by the DECO Safety Review Task Force which was formed April 10,_1979 to investigate safety, related cooling and auxiliary systems in light of the Three Mile Island 2 accident.
It was composed of. 21 members, including 10 system engineers, representatives from operations, design, project and licensing, and from consultants (Sol Levy Inc., GE, NUTECH, Stone and Webester, and Sargent and Lundy.) The task force met 48 times in one year to consider the potential for abnormal or accidental radiation releases due to equipment failure and operational errors and to recomend improvecents in design or procedures. As a result aoout 100 recomendations were made to increase safety aargins or operations flexibility - 47 of which OFFICs)
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SEP 2 21982 were coaparable to NnC TM1 Action Plan itens for design or procedure changes.
Significant recommendations were:
redesign the safety relief valve electrical feeds, position indication and pneumatic source; inert the primary containment; upgrade the control air system, and; purchase a simulator for training.
In addition, 36 other design reviews and 5 major verification prograns were cowleted.
Independent design reviews were made for:
radsaste systens; heating, ventilating and air conditioning; fire protection analysis; fuel design; torus hydrodynamic load analysis, and; primary containment analysis.
Conclusion The staff said it appeared applicant's canagement had ample nucicar and engineering experience and took a keen interest in the building and operation of Fermi 2.
However, there appeared to be a large potential for errors in co,1nunicating requirenents and specifications because of changes in personnel and contractors sinca construction began in 1969 and the large nunber of subcontractors used in the latter stages of design. Staff requested applicant to consider the performance of an indepenoent review or audit for a systen that involves a large number of interfaces between design and construction organizations. The audit should concentrate on assurance that perfornance and safety requirenents (e.g. in the Fermi 2 FSAP.) were correctly built into the systen and operating procedures.
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The review shauld cover all disciplines involved in the design and construction (such as electrical, operations, and human fa': tors) and should not concentrate on mechanical design and code aspects (such as pipe and snubber design.) An independent review can be perforned by the applicant's organization, provided the reviewing personnel are sufficiently independent of the people who were responsible for the design and construction of the selected systen.
The applicant said it will consider the performance of another indepeadent design review. The review of the core spray system which has already been initiated, nay fulfill the above-stated requrements. Applicant said it would advise the staff of its plans through the NRC licensing project manager.
Subsequent to the meeting, the applicant provided a sumary of its review of the core spray system design (Letter fro.a H. Tauber to L. Kintner, dated July 26, 1982). Staff is currently considering this review and alternative reviews which will fulfill the objective of providing satisfactory assurance that design and construction is in accordance with safety requirements. Applicant will be advised of staff's decision by a separate letter.
Original. Signed By Le ctc; L. Kintner L. L. Kintner, Pro.iect !!anager Licensing Branch No.1 Division of. Licensing s
Enclosures:
As stated
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- c Mr. Harry Tauber Vice President Engineering & Construction Detroit Edison Company 2000 Second Avenue Detroit, Michigan.48226 cc
Mr. Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N. W.
Washington, D. C.
20036 Peter A. Marquardt, Esq.
Co-Counsel The Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226
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Mr. William J. Fahrner Project Manager - Fermi 2 The Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226
- Mr. Larry E. Schuerman Detroit Edison Company 3331 West Big Beaver Road Troy, Michigan 48084 David E. Howell, Esq.
3239 Woodward Avenue Berkley, Michigan 48072 Mr. Bruce Little
.t U. S. Nuclear Regulatory Commission
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Resident Inspector's Office 6450 W. Dixie Highway Newport, Michigan 48166 Dr. Wayne Jens
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Detroit Edison Company 2000 Second Avenue
. Detroit, Michigan 48226 Mr. James G. Keppler Nuclear Regulatory Commission i
Region III 799 Roosevelt Road l
Glen Ellyn, Illinois 60137 l
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Participants at July 15, 1982 Meeting with Detroit Edison Company NRC H. R. Denton
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A. Bert Davis D. G. Eisenhut R. Vollmer J. Knight R. Tedesco B. J. Youngblood L. L. Kintner
' Detroit Eoison Company C. M. Heidel H. Tauber W. Jens R. Vance T. Alessi W. Fahrner D. Wells L. Schuerman
- W. Colbert J. Nunley
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SUMMARY
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