ML20028B423

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Forwards Amended Response to NRC 820823 Ltr Re Violations Noted in IE Insp Rept 50-341/82-10.Corrective Actions:Qa Program Assessment,Planned by Mgt Analysis Corp,Started in Oct 1982
ML20028B423
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 11/11/1982
From: Alessi T, Trahey G, Wells D
DETROIT EDISON CO.
To: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20028B412 List:
References
EF2-60-777, NUDOCS 8211300371
Download: ML20028B423 (11)


Text

Donald A. Wells Manager Qua' ty Assuraxe f 1313: 237 % 57 2000 Second Avenue 31 3-November 11, 1982 EF2-60,777 f

Mr. C. E. Norelius, Director Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Norelius:

Subject:

Noncompliance at Enrico Fermi Unit 2 Construction Site - IE Report 50-341/82-10 Enclosed are amended responses to seven (7) items described in your IE Report 50-341/82-10.

Specifically, items 82-10-01, 82-10-04, 82-10-05, 82-10-09, 82-10-15, 82-10-17 and 82-10-20 have been amended for clarifi-cation. The need for clarification was identified in meetings with NRC I & E Resident Inspectors at the Fermi 2 Site the week of November 1, 1982.

The amended responses are arranged in the sequence of items cited in your report. Finding and section numbers are referenced l for convience.

f Please let us know if we can be of further assistance in this matter.

Very truly yours, j

GMT:mb cc: Mr. Richard DeYoung, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission

. Washington, DC 20555 Mr. Bruce Little, Senior Resident Inspector U. S. Nuclear Regulatory Commission 6450 North Dixie Highway

_ Newport, MI 48166 NOV.1 5 062

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0211300371 821153 gDRADOCK 05000341 i PDR

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TIIE DETROIT EDISON COMPANY QUALITY ASSURANCE DEPARTMENT ENRICO FERMI 2 PROJECT Amended Response to NRC Report No. 50-341/82-10 (Item Nos. 01, 04, 05, 09, 15, 17, and 20)

Docket No. 50-341 License No. CPR-87 Inspection at: Fermi 2 Site, Monroe, Michigan Inspection Conducted: June 21 - July 2, 1982 Prepared By: ,$[ & /

G.' M.' Trahey, A sistant Director Project Qualit Assurance Approved By: [C/4/

T. A. Alessi, Director Project Quality Assurance

i l Response to NRC Inspection Report No. 50-341/82-10 (Amended 11/82) (82-10-01)

) Statement of Open Item, 82-10-01,Section II, Item B-2 Contrary to proposed change 46 FR 34595 which modifies 10CFR50.34, 50.54 and

50.55, Chapter 17 of the FSAR was not updated, and submitted to the NRC. The QA Program and Fermi organization underwent a major revision in March, 1980,
without such change being described in an amendment to the FSAR Chapter 17.1.

Action Taken or Planned Following discussion of the stated open item with the NRR Quality Assurance

Branch Chief, Detroit Edison has concluded that it would be appropriate to amend Chapter 17.1 for the Fermi 2 FSAR and submit it to the QA Branch Chief of NRR for review.

A draf t of the amended Chapter will be forwarded to Edison's SAR update con-tractor by December 1, 1982. The amended Chapter is expected to be available for NRR review in January, 1983.

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Response to NRC Inspection Report No. 50-341/82-10 (Amended 11/82) (82-10-04)

Patement of Noncompliance, 82-10-04,Section II, Item D-1 Contrary to 10CFR50, Appendix B, Criterion II and Enrico Fermi 2 Quality Assurance Manual, Section 19.0.3, a review of the overall Fermi QA Program has not been per-formed. A procedure to control this activity was not in place, nor had such a review been scheduled or performed since the beginning of the Fermi Project.

Corrective Action Taken and Results Achieved A contract has been awarded to Management Analysis Corporation to perform a Fermi 2 QA program assessuent.

It should also be uoted that practices such as: (1) reporting audit reports to Edison management, and (2) periodic meetings regarding QA program status with Edison management provide a basis for corporate level assessment of the program. In addi-tion, other management assessments of varying scope have been performed in the past.

For example: (1) Daniel International corporate officials reviewed various aspects of the program in 1974. (2) In 1977, Theodore Barry and Associates was selected by the Michigan Public Service Commission to perform an assessment of the managing of the company which included the Fermi 2 project management and QA. (3) Management Analysis Corporation performed a total project assessment of Fermi late in 1979.

QA was part of the review. This asseesment resulted in a recommendation to restructure the QA/QC organizations, which Edison has since accomplished. These assessments may not have fulfilled the requirement stated in the citation completely; however, we are of the opinion that they, collectively, were instrumental in the steps taken to improve the Fermi 2 QA program since the beginning of the project.

Corrective Action Taken to Avoid Further Noncompliance A procedure addressing responsibility, scope and frequency of the QA program status and adequacy assessments will be incorporated into the Project QA Procedures Manual by February, 1983. In addition, an action item has been inputed to a com-puterized tracking system to assure that future periodic program assessments are performed as required.

Date When Full Compliance Will Be Achieved The planned program assessment was started in October, 1982.

Response to NRC Inspection Peport No. 50-341/82-10 (Amended 11/82) (82-10-05)

Statement of Noncompliance, 82-10-05,Section II, Item D-2 Contrary to 10CFR50, Appendix B, Criterion XVIII and the Enrico Fermi 2 Quality Assurance Manual, Section 19, no audits were scheduled or conducted of the Fermi Site audit program or the Troy Architect-Engineer audit pro-gram. Audits in these areas of the QA Program have not been done since the Fermi Project began.

Corrective Action Taken and Results Achieved The Construction QA (responsible for the on-site audit program) and Design QA Troy (responsible for internal design and Architect-Engineer audit program) sections of Project Quality Assurance (PQA), were audited by independent PQA staff in August and October, 1982, respectively. Based on the results of the audits, plans have been formulated for improvement / refinement of the site and design audit programs.

It should be noted that, while the site and design audit programs were not audited in the period March, 1980 through July, 1982; an action audit program did exict prior to March, 1980. In the pre-March, 1980 period, the site audit function was performed by Daniel, and was, in turn, audited by rdison QA.

Corrective Action Taken to Avoid Further Noncompliance The audit program at Fermi 2 has been reviewed to assure that all elements of the Project Quality Assurance organization are included in auditing plans and schedules.

4 Date When Full Compliance Will Be Achieved Full compliance has been achieved.

Response to NRC Inspection Report No. 50-341/82-10 (Amended 11/82) (82-10-09)

Statement of Noncompliance, 82-10-09,Section II, Item F-1 Contrary to the requirements of 10CFR50, Appendix B, Criterion V, and the Enrico Fermi 2 Quality Assurance Manual, Section 9.0.1, Wismer and Becker's Procedure WB-Q-il3, Rev. 5, assigns responsibilities and provides admini-strative direction, but does not provide appropriate quantitative or quali-tative acceptance criteria with regard to how surveillances are to be con-ducted or what the scope of the surveillance program is to be.

1 l Corrective Action Taken and Results Achieved The scope of Wismer and Becker's Procedure WB-Q-ll3 was revised to adequately describe what is covered by surveillances and surveillance reports, and the j methods by which surveillances are to be conducted.

In our interpretation of the statement of noncompliance, it appears that the Inspector intended that the Contractor's general procedure on surveillances should include " appropriate quantitative or qualitative acceptance criteria".

It is our opinion that a general surveillance procedure should address the activities to be subject to surveillance and methodology for conducting sur-1 veillance. Specific acceptance criteria should appropriately be established in surveillance plans or checklists associated with the activities being i surveilled. The two, in combination, constitute the surveillance program

" procedures". We believe that the definition of the program currently in place

at Wismer and Becker is in compliance.

Corrective Action Taken to Avoid Further Noncompliance Quality Control personnel and personnel in charge of approving and processing surveillance reports have been instructed, through formal training, as to i

the requirements of the approved, revised procedure. In addition, contrac-tor's surveillance reports are routinely reviewec by Project QA for adequacy.

Date When Full Ccmpliance Will be Achieved Full compliance has been achieved.

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Response to NRC Inspection Report No. 50-341/82-10 (Amended i1/82) (82-10-15)

Statement of Open Item, 82-10-15,Section IV, Item D Interviews'were conducted with selected quality control, quality assurance, engineering and management personnel. Wismer and Becker Quality Control Inspectors perceived a lack of management support for QA activities. Speci-fic concerns expressed by the Wismer and Becker inspectors included:

1. Wismer and Becker QA manager was not independent of influence by the Wismer and Becker Construction Superintendent.
2. Wismer and Becker QC supervision was not supportive; feedback to in-spectors regarding concerns was not adequate.

Items I and 2 are considered to be open. A written response by the licensee is required for Items 1 and 2.

Action Taken and Results Achieved As Edison was made aware of information provided by NRC personnel regarding trends identified in the interviews, a series of problem solving meetings in-volving Edison Fermi 2 Project Management and Wismer and Becker Site and Cor-porate Management were conducted regarding the concerns expressed in the i iterviews . As a result of this effort, the following actions were taken and results achieved:

The cause of the problems was determined by Wismer and Becker to be poor com-

' munication between Wismer and Becker's Project Quality Manager (PQM) and QC staff personnel; lack of adequate explanation for "use-as-is" type disposi-

! tions on DDRs, Surveillance Reports, etc; and poor working conditions for QC, I and inef fectiveness of Wismer and Becker's PQM in handling the problems.

Wismer and Becker's PQM started conducting weekly staff meetings personally j

with all department personnel on July 7, 1982.

Wismer and Becker's PQM started reviewing all DDRs and explaining "use-as-is" dispositions to the originator on June 25, 1982.

Training sessions are being conducted to explain Code and Specification re-quirements to all supervisors. It is felt that a better understanding of codes and specifications will aid the supervisors in handling concerns of their people.

Supervisor Seminars for Wismer and Becker Quality Department supervisors were restarted on August 5, 1982. These were being conducted monthly, but were stopped in the spring. These seminars have provided good " rap sessions" be-tween the PQM and supervisors. '

l Two new supervisors have been assigned to QC to assist in problem solving and supervision of the QC department.

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Response to NRC Inspection Report No. 50-341/82-10 (Amended 11/82) (82-10-15)

Wismer and Becker's Corporate Quality Assurance and Control Manager made a visit to the Enrico Fermi 2 site the week of July 26, 1962, and interviewed fifteen (15) of Wismer and Becker's first line QC inspectors representing all disciplines. The purpose of this survey was to assure that Wismer and Becker's QC personnel were not being intimidated, and that they have the necessary authority and organizational freedom to identify quality problems, initiate, recommend, or provide solutions and to verify implementation of solutions. In the course of conversation with the inspection personnel, the following ques-tions were either directly addressed to the individm;l or the answers were arrived at by informal discussion with the individual.

YES NO

l. Do you feel that your supervisor gives you the needed support and backup in your job? 15 0
2. Are your concerns answered to your satisfaction? 15 0
3. Do you feel that communications between you and your supervisor could be improved? 10 5
4. Have you ever been pressured to accept sub-standard work? 0 15
5. Are you satisfied with your job? 15 0
6. Do you feel you have the freedom to document or voice any j problem areas or discrepancies which you uncover? 15 0
7. Do you feel that W&B QC has ample authority to achieve a quality product? 15 0
8. Do you feel that your QA/QC Manager is intimidated or pressured by Project Management? 0 15
9. Do you feel that our Customer, Detroit Edison, has the needed assurance that Wismer and Becker is doing a quality job? 15 0
10. What suggestions could you give to improve communications and relations between inspectors and their supervision? (Suggestions are documented in Wismer and Becker's Report)

It is noteworthy that the results of this survey were positive in all respects with the exception of cceaunications and feedback. In regard to question number three (3), the majority of inspection personnel were of the opinion that the recently instituted staff meetings and job walks conducted by Wis-mer and Becker's PQM will help a great deal to achieve better communications.

In regard to question number eight (8), the majority felt that the pressures to get the job done were normal, and not necessarily different from any other job site.

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Response to NRC Inspection Report No. 50-341/82-10 (Amended 11/82) (82-10-15)

The comments received from the inspectors were arranged to preclude identity of the individual, but listed totally in order that each comment may be

' evaluated'by the Project Quality Manager and acted upon as necessary.

A follow-up review was performed by the Corporate QA Manager of Wismer and Becker during the week of October 4, 1982. This further substantiates the positive results of the July survey.

In addition, personnel from Project Quality Assurance (PQA) have conducted informal surveys of Wismer & Becker QC personnel to monitor the effectiveness of the action taken by Wismer & Becker Management and have reported orally to the Supervisor of Constrction QA and Assistant Director, PQA. Results to date have been favorable.

Since this matter is of major importance, informal surveys by PQA will con-tinue until Wismer and Becker completes their work scope at Fermi 2, and de-mobilizes.

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Response to NRC Inspection Report No. 50-341/82-10 (Amended 11/82) (82-10-17)

, 1 l Statement of Open Item, 82-10-17,Section V, Item A-4a Softeners to protect the cable from the cable tray metal edge were not in place on Cable Trays IC-137, IC-038, IC-047 and IC-035. Paragraph 5.20.11.4 of Detroit Edison Company (Deco) Specification 3071-33 requires the instal-lation of metal edge protector "cairepco" or equal approved by DECO, where cables leaving or entering cable trays are in contact with or may contact the edge of the tray channel flange. The cable jacket may be used as a softener at tray rungs and around bends in the tray, and should be properly secured by ty-wrap or tape as necessary. The contractor developed Procedure 4.3.0, titled " Inspection of Installed Cable and Associated Raceway" to reinspect the installed cables. The reinspection was in progress at the time of this assessment. Paragraph 3.4.0 of Procedure 4.3.0 requires verificatio1 that ,

cable softeners or other protection is in place. QC Checklist 40 is used -

to document adverse findings.

l Action Taken and Results Achieved Contractor QC Management has reviewed Checklist number 40, Procedure 4.3.0 and associated documents and have concluded that they provide an adequate basis for inspection and recordkeeping.

As noted in the Statement of the Open Item, trays are in the process,of being inspected. It is expected that the inspection will be completed and' identified deficiencies dispositioned by January 10, 1983. In addition, trays that have not been inspected within six (6) months of turnover to Edison will be " walked down" prior to turnover.

In addition, QC cable pulling procedure 4.3.3 has been revised to clarify acceptance criteria and recording requirements.

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Reeponse to NRC Inspection Report No. 50-341/82-10 (Amended 11/82) (82-10-20)

,' r Statement of Noncompliance, 82-10-20,Section V. Item B-4 Item 1.3 on the checklist requires verification that the tray is anchored down...

The inspector informed the licensee that failure to inspect or document the inspection of these welds in an item of noncompliance with the requirements of

-10CFR50, Appendix B, Criterion X.

Corrective Action Taken and Results Achieved To determine if the welds previously installed are adequate for Enrico Fermi 2, a

" Cable Tray Hold Down Weld" testing' program was developed and implemented. A total

, of one thousand eight hundred eighty nine (1,889) welds were inspected and cate-gorized. One hund:ed thirty seven (137) categorized welds were examined under static loads selec ted by Edison Engineering to simulate seismic loading. An analysis of the test results by Project Quality Assurance indicated an acceptable confidence icvel. Engineering review of both the testing plan and the statistical analysis has concluded that welds made prior to July, 1982, are structurally acceptable.

Reference:

Fermi 2 Letters EF2-59,559; F2S82-4820, and F2S82-4274.

In addition to the weld testing program, 9etroit Edison Engineering issued a design revision for the amount of weld required to' attach cable trays to a seismic support.

.a1 new welds must meet the minimum dimensions of 1/8" size by 1/2" length. Engineer-ing Standard STD-EB-ll7.57 is discontinued and standards STD-EB-117.86 and STD-EB-117.87 provide attainable weld dimensions. Design Change Notice DCN-7564 clarifies the physical characteristics of the weld by incorporating the American Welding Society's Dl.1 criteria.

In conjunction with the above actions, a stop work action was initiated on July 2, 1982, for installation of safety related (QA Level I) cable tray and tray supports 5

pending an extensive review of QC procedures and work instructions by PQA and the electrical contractor. QC procedures 4.3.1 (cable tray), 4.7.4 (welding) and Work l' Instruction 000-03-001 were revised to reflect design changes, clarify acceptance criteria and improve adequacy and traceability of inspection records.

Corrective Action Taken to Avoid Further Noncompliance The action taken to date, and close scrutiny by PQA should prevent recurrence of this problem.

Date When Full Compliance Will Be Achieved Full compliance was achieved September 28, 1982, when the stop work action was lifted.

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