ML20028B437

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Responds to NRC Ltr Re Violations Noted in IE Insp Rept 50-341/82-10.Corrective Actions:Action Item Will Be Placed on Computerized Tracking Sys to Assure That Future Periodic QA Manual Reviews Performed
ML20028B437
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 10/22/1982
From: Alessi T, Ferencz D, Wells D
DETROIT EDISON CO.
To: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20028B412 List:
References
EF2-60504, NUDOCS 8211300383
Download: ML20028B437 (28)


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e Donald A. Wells veaprow n A m en, 13 t h 23 7 M t Edison EEEE5==

October 22, 1982 EF2-60504 i

Mr. C.E. Norelius, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory Ccumission l

Region III 4

799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

tbncompliance at Enrico Fermi Unit 2 Construction Site - IE Report 50-341/82-10

Dear Mr. Norelius:

This letter responds to the items of noncompliance and open items described in your IE Report 50-341/82-10. This assessment of Enrico Fermi Unit 2 Site Construction activities was performed by the Construction Assessment Team of NRC Region III on June 21 - July 2, 1982, at the site.

Items of nonempliance are discussed in this reply, as required by Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations. In addition, responses to open items identified by the Con-3 struction Assessment Team are included.

The enclosed response is arranged in sequence of itms cited in the body of your report. The finding and section numbers are referenced. ,

We trust this letter satisfactorily answers the concerns raised in your report. We will be glad to discuss any further concerns you may have.

Very truly yours, DAW /DF/pn cc: Mr. Richard DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Cmmission Washington, D.C. 20555 Mr. Bruce Little, Senior Resident Inspector U.S. Nuclear Regulatory Ccmmission 6450 North Dixie Highway Newport, Michigan 48166 i

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'IIIE DEIROIT EDISON COMPMW QUALITY ASSURMEE DEPtWIMDIT ENRICO FERMI 2 PROJa.T Pesponse to NRC Report No. 50-341/82-10 Docket No. 50-341 License No. CPPR-87 Inspection at: Fermi 2 Site, Monroe, Michigan Inspection Conducted: June 21-July 2,1982 Noted By: h II/&/>76;;L D. Ferencz, Ac 19 Supervisor Construction lity Assurance Approved By: /

T.A. Alessi, Director Project Quality Assuranw

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

Statement of Open Item, 82-10-01,Section II, Item B-2 Contrary to proposed change 46 FR 34595 which rcodifies 10CFR50.34, 50.54 and 50.55, Chapter 17 of the FSAR was not updated, and subnitted to the NRC. The OA 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.

Corrective Action Taken and Results Achieved Chapter 17.1 is not required as part of the FSAR. Although it was subnitted in 1974, it was not reviewed by the OA Branch of NRR. In fact, the branch chief specifically stated that it should not have been included as part of the FSAR. Therefore, as far as NRR is concerned, Chapter 17.1 has no status, and it has not been our intention to revise it unless so required by NRR.

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1 Response to NRC Inspection Report No. 50-341/82-10 (82-10-02)

Statment of Nonempliance, 82-10-02,Section II, Iten B-3 In March, 1980, the Fermi Quality Assurance functions were reorganized integrat-ing the Detroit Edison and Daniel International site personnel into one organ-

, ization. The Quality Assurance manual dated April 27, 1977, and revised Dec-mber 5, 1978, was not revised prior to the reorganization. The manual revi-sion was subsequently cmpleted and approved on June 28, 1982, 27 months after the reorganization. The implementing procedures had been revised to reflect the changes, however, that is a reversal of basic OA philosophy with regard to

document priorities. This is considered to be an iten of nonempliance with Criterion II of 10CFR50, Appendix B.

Corrective Action Taken and Results Achieved

'Ihe Manual revision has been completed. It is now issued and distributed to i all assigned manual holders.

Corrective Action Taken to Avoid Further Noncmpliance The Edison OA Manual, Section 1.3.4 states, in part, "The OA Manual is.. .

subject to periodic review by the POA Director, at least once per year."

An action item will be placed on a cmputerized tracking system to assure that future periodic OA Manual reviews are perforned.

Date When Full Cmpliance Wil_1 be Achieved Full ccupliance has been achieved. This its is ready for NRC review. Docu-mentation and other information is available at the Enrico Fermi 2 site.

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o Response to NRC Inspection Report No. 50-341/82-10 (82-10-03)

Statment of Open Itm, 82-10-03,Section II, Item B-4 The Enrico Fermi 2 Quality Assurance Manual, Section 2 states, "'1he Project Quality Assurance Director (PDAD) who reports on project-related matters to the Project Manager, is administrative 1y responsible to the Director of the Quality Assurance Departnent and obtains direction frm him on OA policy mat-ters." This appears to have been stated incorrectly, and is not the actual practice at Fermi. This statment needs clarification to assure organiza-tional freedm to fully rneet Cirterion I of 10CFR50, Appendix B. This is con-sidered to be an open item. A written response is requested frm Detroit Felison on this item.

Corrective Action Taken and Results Achieved The Enrico Fermi 2 Quality Assurance Manual, Section 2.1.2.5 has been revised (Revision 6) and now states:

"The PDA Director reports administrative 1y to the Manager - Quality Assurance, but on project-related matters, he reports to the Manager of the Project...

with the Assistant PDA Director, he provides administrative and technical direction to POA." It should be noted that after reorganizing in 1980, the Director of the OA Department also assumed the position of Director of Project OA.

Date When Full Carpliance Will_ be Achieved Full carpliance has been achieved. This item is ready for NRC review, and the information is available in the Quality Assurance Manual, OAP-2, Revi-sion 6.

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Respcose to NRC Inspection Report No. 50-341/82-10 (82-10-04)

Statement of Nancmpliance, 82-10-04,Section II, Item D-1 Contrary to 10CFR50, Appendix B, Criterion II and Enrico Fermi 2 Quality Assuranw Manual, Section 19.0.3, a review of the overall Fermi DA Program has not been performed. A procedure to control this activity was not in place, nor had such a review been scheduled or perforned 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 On program assessment.

It should be noted that practices such as (1) audit reports to alison man-agenent and (2) periodic meetings with managenent, including the alison president provide feedback regarding OA program status. Also, program assessment reviews have indeed been perforced in the past: (1) Daniel International corporate officials reviewed various aspects of the program in 1974. (2) In 1977, Theodore Berry and Associates was selected by the Michigan Public Service Ccmnission to perform an assessment of the marnging of the cmpany which included the Fermi 2 project Iranagement and DA. (3)

Managenent Analysis Corporation perforned a total project assessment of Fermi late in 1979. 0A was part of the review. This assessnent resulted in a recomerxlation to restructure the OA/DC organizations, which Edison has since accmplished.

Corrective Action Taken to Avoid Further Noncmpliance An action item will be placed on a cmputerized tracking system to assure that future periodic program assessnents are performed.

Date When Full Cmpliance Will be Achieve _d The planned program assessnent will-begin in October,1982.

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I Response to NRC Inspection Report No. 50-341/82-10 (82-10-05) i Statenent of Nonccrrpliance, 82-10-05, Secticm II, Item D-2 l Contrary to 10CFR50, Appendix B, Criterion XVIII and the Enrico Fermi 2

Quality Assurance Manual, Section 19, no audits were scheduled or conducted l of the Fermi Site audit program or the Troy Architect-Engineer atxlit program.

Audits in these areas of the OA Program have not been done since the Fermi Project began.  !

Corrective Action Taken and Results Achieved l Construction OA and Design OA - Troy sections were audited by Project GA staff in August and October, 1982, respectively. It should be noted that prior to March,1980, Daniel OA organization conducted the site audit pro-gram and Edison OA, in turn, audited Daniel OA.

Corrective Action Taken to Avoid Further Nonccupliance Future atxlit schedules will include all elenents of the Fermi 2 Quality Assur-ance organizations.

Date When Full Ccr:pliance Will Be Achieved Full ccupliance has been achieved.

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, Response to NRC Inspection Report No. 50-341/82-10 (82-10-06) 4 Statement of Nonempliance, 82-10-06,Section II, Item D-4 i

Contrary to the requiremnts of 10CFR50, Appendix B, Criterion V; and the Enrico Fermi 2 Ouality Assurance Manual, OAP No. 9, Project Quality Assur-

anoe Procedure 9.112, Revision 0, did not include a requirenent per Regula-l tory Guide 1.146 (which endorses ANSI N45.2.23-1978) that Icad Auditors be administered an examination prior to certification. In addition, a Icad Auditor certification was issued without the backup documentation on fjle

, at the site.

l Corrective Action Taken ard Results Achieved  :

Project Quality Assurance Procedure 9.112 is being revised to meet the j requirenents of ANSI N45.2.23-1978. The qualificaticn/ certification files

! for personnel who function as Icad Auditors are being reviewed to assure that objective evidence is available to substantiate certifications. To date, no major problems have been identified concerning the qualifications i of personnel who have perforned as Icad Auditors for the Fermi 2 project.

Corrective Action Taken to Avoid Further Noncmpliance Inplenentation of the revised procedure will provide the basis for cmpli- .

ance with regulatory requirenents.  !

Date When Full Cmpliance Will be Achieved The revised procedure is expected to be approved and issued, and Icad Audi-  :

tor qualification /wrtification files will be updated per this revision by Demmber 20, 1982.

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Response to NRC Inspection Report No. 50-341/82-10 (82-10-07)

Statement of Open Item, 82-10-07, Section IT, Item E Project Quality Assurance Procedure 9.347, Trend Analysis System, Rev. O, was found to be weak with regard to the assignment of tine constraints on analyz-ing data or issuing reports to trigger corrective action. Also, Nonconfor-mance Reports (NCR's) are not covered by the procedure. Section 3.0 refers to trending only "onsite contractors" and does not include Edison activities.

Corrective Action Taken and Results Achieved Project Quality Assurance Procedure 9.347 is being revised to include assign-nent of time constraints on analyzing data and issuing reports for corrective action. It will also include coverage of nonconformance reports (alison activities).

Corrective Action Taken to Avoid Further Nonempliance Revision of Procedure 9.347 and its implenentation is expected to prevent recurrence.

Date When Full Canplianm Will be Achieved Revision to Procedure 9.347 is expected to be emplete by December 6,1982.

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Response to NRC Inspection Report No. 50-341/82-10 (82-10-08)

Statement of Nonccupliance, 82-10-08,Section II, Item E-3 Contrary to 10CFR50, Appendix B, criterion XVI and the Enrico Fermi 2 Qual-ity Assuranm Manual, Sectica 17, nutcrous Deviation Disposition Requests (DDRs), audit firxlings, and surveillance findings have not been disposi-tioned on a tinely basis. Therefore, corrective actions have not been pra pt.

Corrective Action Taken and Results Achieved POA is ccnducting a study which will establish tin time limits for closing quality related items such as DDRs, Nonconformance Reports (NCRs), Audit Findings and Surveillances.

A program for management of items by exception (items exceeding the estab-lished limits) will be incorporated into PDA procedures and implemented following appropriate training.

Corrective Action Taken to Avoid Further Noncccpliance The open item tracking and follow-up (managenent) program will be reviewed and evaluated nonthly by Project OA management for effectively reducing the number and duraticn of open itans exceeding established limits.

Date When Full Ccnpliance Will be Achieved Expected date of full compliance is December,1982.

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

Statenent of Nonecupliance, 82-10-09,Section II, Item F-1 Ccntrary to the requirenents of 10CFR50, Appendix B, Criterion V, and the Enrico Fermi 2 Quality Assurance Manual, Section 9.0.1, Wisner and Decker's Procedure WB-O-113, 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.

Corrective Action Taken and Results Achieved

The scope of Wismer and Becker's Procedure WB-O-113 was revised to ade-quately describe what is covered by surveillances and surveillance reports, and the nethcds by which surveillances are to be conducted. It is inappro-priate to include any form of acceptance criteria in the' surveillance proce-dure, because criteria for an activity being surveyed are included in written instructions associated with activity.

Corrective Actica Taken to Avoid Further Nonccupliance a

4 Quality Centrol personnel and personnel in charge of approving and process-l ing surveillance reports have been instructed, through formal training, as tc

! the requirenents of the approved, revised procedure. In addition, contrac-tor's surveillance reports are routinely reviewed by Project OA for adequacy.

Date When Full Cccoliance Will be Achieved Full conpliance has been achieved.

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

Statenent of Nonempliance, 82-10-10,Section II, Item F-2 Contrary to the requirements of 10CFR50, Appendix B, Criterion XV and the Enrico Fermi 2 Quality Assurance Manual, Section 16.1.5, during a review of surveillance reports, the inspector found five cases in which a site con-tractor, Wisner and Becker, improperly reported nonconformances affecting plant hardware on surveillance reports rather than on DDRs, thereby avoid-ing the required licensee engineering review of the nonconformance.

Corrective Action Taken and Results Achieved Wismer and Becker has revised their surveillance reporting procedure to ,

clarify the criteria for use of surveillance and DDR reports for identified i

.nonconformances. The revised procedure has been reviewed and approved by Project DA. Surveillance reports issued prior to the procedure revision are being reviewed for ccupliance to the revised procedure. Instances of miaMplication of the surveillance report will be corrected by ' issuing a DDR to cover the associated nonconforr.nnae.

Corrective Action Taken to Avoid Further Noncmpliance A. WB-O-113, Rev. 5, was revised, and Rev. 7 was approved on October 5, 1982. This procedure now adequately describes items which are to be reported on surveillance reports.

B. Quality Control personnel and personnel in charge of approving arxl pro-cessing surveillance reports have been instructed through formal train-

.ing as to the requirements of the revised and approved procedure.

Date When Full Cmpliance Will be Achieved Full empliance should be achieved by November 10, 1982.

Response to NRC Inspecticn Report No. 50-341/82-10 (82-10-11)

Statement of Nonempliance, 82-10-11,Section II,' Item G Contrary to' 10CFR50, Appendix B, Criterion II and the Enrico Fermi 2 Qual-ity Assuran Manual, Section 1.4.7 and Section 1.5.4, the Reactor Build-ing, Dry-wll, Auxiliary Building, and the general site areas outside build-ings weru littered with garbage, scrap lumber, rags and other debris. Two unattended containers of a flamable liquid were also observed in the Dry-well and Reactor Building. Pipe caps were noted to be missing on sme instrunent racks.

Corrective Action Taken and Results Achieved

1. A Site Administrative Pro dure, AP-V-16 " Project Housekeeping" was approved on October 8,1982, to improve routine housekeeping activities, and to establish responsibility for inplementing the requirenents of the procedure.
2. Weekly housekeeping neetings are being held by the Edison Project Super-intendent to discuss progress and identify any problem areas. These neetings are attended by representatives frcm all contractors involved in a major work effort.
3. All buildings and areas outside buildings have been cleaned and are being maintained daily.
4. Project GA is incorporating housekeeping into its surveillan proce-dures. Construction, maintenance and operations activities will be included in the scope of this effort.

Corrective Action Taken to Avoid Further Nonemplian Further noncmpliance will be avoided by implementation of Procedure AP-V-

~16; the concerted project wide effort to inprove nethods md practices; and the Project OA surveillance program.

Date Nhen Full Capliance Will be Achieved The action described above has been partially inplenented. Full implenenta-tion is expected by December 6, 1982.

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Response to NRC Inspection Report No. 50-341/82-10 (82-10-12)

Sta6mnt of Nonecmpliance, 82-10-12,Section III, Iten A-id Contrary to 10CFR50, Appendix B, criterion V and Enrico Fermi II Quality Assurance Manual, Section 9.0.1, Detroit B31 son Project Procedures 3.20, 3.21, and 3.22 ccntain significant mistakes and inconsistencies, including incorrect referen s, and incorrect title, and incorrect instructions.

Corrective Action Taken and Results Achieved Project Quality Assurance performed a review of the subject procedures June 23, 1982. As a result of this review, Quality Surveillance Findings S-062482-1, 2, and 3 were issued describing the following discrepancies:

A. Incorrect title.

B. Lack of definition to Type I and II DCNs, DCRs, and ENRs.

C. Incorrect references.

D. Typographical errors.

On July 2,1982, the Detroit Edison Project Procedure Manual Coordinator formally responded to the subject findings with satisfactory results. Prcy-cedures 3.20, 3.21, and 3.22 have been revised to reference project proce-dures " Appendix B" which defines Type I and Type II DCNs, DCRs, and FMRs.

Revision also includes correction of incorrect title and apparent typogra-phical errors, i.e.: the term DCR was used in lieu of FMR. Based upon acceptable review of Project Procedures 3.20, Rev. 4, 3.21, Rev. 4, and 3.22, Rev. 3, Quality Surveillance Firrlings S-062482-1, 2, and 3 were closed August 3,1982.

Corrective Acticn Taken to Avoid Further Nonccmpliance Responsible personnel have been in.structed to assure that all references

,in narrative documents are specifically and accurately worded. The Project Procedure Manual coordinator has been instructed to carefully proofread procedures prior to formal review. In addition, the Construction Quality Assurance Secticn has been added to the review cycle for all new drafts and

revisicns of quality related project procedures in an effort to minimize the frequency and magnitude of errors.

Date hten Full Ccapliance Will be Achieved Full ccmpliance has been achieved.

{ Response to NRC Inspection Report No. 50-341/82-10 (82-10-13)

Statment of Nonempliance, 82-10-13,Section III, It s A-3 Contrary to 10CFR50, Appendix B, Criterion III, design control measures cm-mensurate with the original design wc2.e not provided for design changes. One ENR (#S3940), for the installation of a site fabrication cable support rack on top of cabinet Hil-P613 did not indicate that possible changes in the seismic qualifications of the cabinet with the rack installed had been con-sidered. The ENR also failed to include quality assurance requirments for the rack fabrication and installation. Several ENR's had been issued to replace pump motor connection boxes with larger connection boxes. There was no evidence that the installation of larger boxes received a review to con-sider the affect on seismic qualifications.

Corrective Action Taken and Results Achieved

1. Change papers identified in the finding will be sent to Troy Engineering Center for review and approval per mmo EF2-59507.
2. Mmo EF2-58763 Supplement 1 has been issued to assure a proper and sys-tmatic approach to approval of seismic effects on Class IE equignent.

All termination box and cable support changes not already reviewed will be subnitted for review.

Corrective Action Taken to Avoid Further Nonempliance Field Engineering Work Procedure (FEWP)Section I, Para.1.10, was revised September 28, 1982, to establish a procedure for each engineering discipline to review design changes for seismic effects.

i Date When Full Compliance Will be Achieved i

1. Review of all termination box and cable support changes not already review-ed are expected to be reviewed by October 15, 1982.
2. All other required acticos have been empleted.

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Response to NRC Inspection Report No. 50-341/82-10 (82-10-14)

Statement of Open Item, 82-10-14,Section IV, Itan C The L.K. Ca* stock O.C. Inspectors qualification records were reviewed for can-pliance to ANSI N45.2.6-1973 standards as referenced in Detroit Edison to NRR Letter EF2-55344 dated November 18, 1981. The following discrepancies were found:

Number of Contractor Discrepancy Occurrences LKC Visual exam ntissing 1 LKC No basis for certification 1 LKC Activities for which certified not indicated 3 LKC Certification not dated 2 LKC Certification not documented 1 During the assessment, the licensee was advised of the above qualification records which contained discrepancies, and directed LKC to review and update their entire DC personnel flies. The licensee has scheduled an audit of LKC OC personnel training and qualifications. This is an open iten which requires a response by the licensee.

Corrective Action Taken and Results Achieved The QC Manager of L.K. Constock reviewed all OC Inspector's records on July 27, 1982, and found that the DC personnel records that were missing were con-tained in other files in his office.

Fran his review of the forty-eight (48) files, he found the following:

1. Thirty-One (31) records were carplete.
2. Fifteen (15) required six month reviews, which help to determine pay raises.
3. Two (2) inspectors required eye tests, which were given inmediately.

Corrective Action Taken to Avoid Further Nonca@liance All OC personnel records will be reviewed for accuracy every six (6) nonths.

Date When Full Ca mliance Will be Achieved Full carpliance was achieved by July 27, 1982.

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

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

1. Wismer and Becker OC manager was not independent of influence by the Wis-mer and Becker Construction Superintendent.
2. Wismer and Becker OC supervision was not supportive; feedback to inspec-tors regarding concerns was not adequate.

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

Corrective Action Taken and Results Achieved The cause of the problems was determined by Wismer and Becker to be poor ccra-munication between Wismer and Becker's Project Quality Manager (PCM) and OC staff personnel; lack of adequate explanation for "use-as-is" type disposi-tions on DDRs, Surveillance Reports, etc; and poor working conditions for OC, and ineffectiveness of Wismer and Becker's PCM in handling the problems.

Wismer and Becker's PCM started conducting weekly staff meetings personally with all department personnel on July 7,1982.

Wismer and Becker's PCM 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 requirments 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 Sminars for Wismer and Becker Quality Department supervisors were restarte don August 5, 1982. These were being conducted monthly, but were stopped in the spring. These seminars have provided good " rap sessions" between the PCM and supervisors.

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

Wismer and Becker's Corporate Quality Assurance and Control Manager made a visit to the Enrico Fermi 2 site the week of July 26, 1982, and interviewed fifteen (15) of Wismer and Becker's first line OC inspectors representing all disciplines. The purpose of this survey was to assure that Wismer and Becker's DC personnel were not being intimidated, and that they have the necessary authority and organizational freedczn to identify quality prob 1ms, initiate, recomend, or provide solutions and to verify implementation of solutions. In

Response to NRC Inspection Report No. 50-341/82-10 (82-10-15) the course of conversation with the inspection personnel, the following ques-tions were either directly addressed to the individual or the answers were arrived at by infonnal discussion with the individual.

YES NO

1. 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 comunications between you and your supervisor could be introved? 10 5
4. Have you ever been pressured to accept sub-standard work? 0 15 Are you satisfied with your job? 15 0 5.
6. Do you feel you have the freedan to document or voice any problan areas or discrepancies which you uncover? 15 0
7. Do you feel that W&B OC has ample authority to achieve a quality product? 15 0
8. Do you feel that your DA/OC Manager is intimidated or pressured by Project Managenent? 0 15
9. Do you feel that our Custuner, 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 ccmnunications 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 comunications and feedback. In regard to question num-bar three (3), the majority of inspection personnel were of the opinion that the recently instituted staff meetings and job walks conducted by Hismer and Becker's PCM will help a great deal to achieve better comunications.

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

The cannents received frun the inspectors were arranged to preclude identity of the individual, but listed totally in order that each ccmrent may be evaluated by the Project Quality Manager and acted upon as necessary.

A follow-up review was perfonned by the Corporate OA Manager of Wismer and Becker during the week of October 4, 1982. This further substantiates the posi-tive results of the July survey.

Corrective Action Taken to Avoid Further Ibncanpliance The corrective action taken and results achieved, noted above should provide an

Response to NRC Inspection Report No. 50-341/82-10 (82-10-15) i adequate corrective action to alleviate this concern.

Date hhen Full Carpliance Will be Achieved Due to the nature of this Open Itan, it will be on-going. For the record, though, full compliance is considered to have been achieved.

9 Response to NRC Inspection Report No. 50-341/82-10 (82-10-16)

Statement of Open Itan, 82-10-16,Section IV, Item D

1. Quality control Inspectors, in general, believed that procedures and check-lists were adequate--containing ay topriate guidelines and specifications.

An exception to this was in the area of electrical conduit and supports.

The L.K. Ccrastock inspectors stated that, in that area, sane procedures contain conflicting specifications. Resolving the conflicts are tiJne con-suming and frustrating to the inspectors.

2. Opinions expressed by Wismer and Becker inspectors relative to the adequacy of interfaces were notif y different fran those expressed by DC inspectors in other contractor organizations. Wismer and Becker OC inspectors stated that they do not feel free to contact DECO organizations with OC concerns.
3. In addition, they stated that engineering and technical support within Wis-mer and Becker was frequently not adequate and not provided in a timely manner.

Corrective Action Taken and Results Achieved Itan 1. L.K. Comstock's OC Procedures 4.3.6 and 4.3.7 have been revised to clarify the acceptance criteria, and the appropriate OC personnel have been trained on the new revisions.

Itans 2 and 3. Corrective Action Taken and Results Achieved are stated in the response to Item 82-10-15.

Corrective Action Taken to Avoid Further Noncanpliance Item 1. The revised procedures make the acceptance criteria unarrbiguous, and should alleviate the concerns expressed by Canstock personnel.

Itans 2 and 3. See Response to Item 82-10-15.

DO When Full Canpliance Will be Achieved Full compliance has been achieved.

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

Statanent of Open Itm, 82-10-17,Section V, Item A-4a Softeners to protect the cable frun the cable tray metal ed9 were not in place on Cable Trays IC-137, 1C-038, IC-047 and IC-035. Paragraph 5.20.11.4 of Detroit Edison Cmpany (DECO) Specification 3071-33 requires the installa-tion of metal edge protector "calrepco" or equal approved by DECO, where cables leaving or entering cabic 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 Cabic 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 verification that cable softeners or other protection is in place. OC Checklist 40 is used to document adverse findings.

Corrective Action Taken and Results Achieved The adequacy of the checklist No. 40 was reviewed by the L.K. Canstock (IEC) 0.C. Supervisor, and it was felt to be adequate when used in conjunction with the procedure and referenced documentation.

Corrective Action Taken to Avoid Further Noncompliance The trays are scheduled to be re-inspected prior to January 10, 1983. Any tray that has not been inspected within 6 months of being turned over will be walked down prior to turnover.

Date When Full Cmpliance Will be Achieveo No corrective action was required. For the purpose of documentation, the date of this response is considered appropriate.

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Response to NRC Inspection Report No. 50-341/82-10 (82-10-18)

Statement of Open Item, 82-10-18,Section V, Item A-5 The Quality Control inspectors and their supervisor were not knowledgeable with regard to the acceptance criteria in the DC procedures governing the DC inspection checklists. The L.K. Cmstock QC Supervisor stated that an indoc-trination refresher course will be given to the OC staff. This is considered to be an open item. A response by the licensee is requested.

Corrective Action Taken and Results Achieved As a result of the Construction Assessment Team visit, fifteen (15) OC proce-dures have been re-written, and the DC personnel responsible for the areas covered by the revised procedures have been trained in those revised proce-dures. (All inspectors were not trained to all procedures.)

Corrective Action Taken to Avoid Further Noncompliance When a design change document is received the OC Manager /his designee routes the data to all the supervisors who in turn assure that the responsible inspec-tors are aware of any/all changes. Additionally, although it isn't required or documented, any inspector who has not worked in a specific area for a rea-sonable length of time is re-indoctrinated to the latest requir ments.

Date When Full Cmpliance Will be Achieved The above action has been implemented and is on-going. For the purpose of cmp 11ance, the date of this response is considered to be appropriate.

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Response to NRC Inspection Report Ib. 50-341/82-10 (82-10-19)

Statment of Nonempliance, 82-10-19,Section V, Item A-6 Contrary to 10CFR50, Appendix B, Criterion II and the Enrico Fermi II Quality Assurance Manual, Section 1.4.7 and Section 1.5.4, cmbustible material such as paper, construction material such as mpty cable reel, and other debris was observed in cable trays OC-031 and OC-731 in the first floor of the Reactor Building, and in cable trays 2C-066 in the second floor of the Reactor Build-ing.

_ Corrective Action Taken and Results Achieved

1. A Daniel Administrative Procedure, AP-V-16 " Project Housekeeping" was approved on October 8,1982, to establish routine housekeeping activities, and the responsible positions for implmenting the requirements of the procedure.
2. Weekly housekeeping meetings have been held by the Edison Project Superin-tendent to discuss progress and identify any problem areas. Those meetings are attended by representatives frtxn all contractors involved in a major work effort.
3. All cable trays were inspected and cleaned as required. Beginning Septem-ber 27, 1982, L.K. Cmstock O.C. personnel have performed weekly inspec-tions of all cable trays.

Corrective Action Taken to Avoid Further Ibncmpliance Further noncmpliance will be avoided by implementation of Procedure AP-V-16.

Date When Full Cmpliance Will be Achieved Full cmpliance with Procedure AP-V-16 will be achieved by December 1,1982

Response to NRC Inspection Report No. 50-341/82-10 (82-10-20)

Statement of Noncmpliance, 82-10-20,Section V, Its B-4 Its 1.3 on the checklist requires verification that the tray is anchored down...The inspector infonned the licensee that failure to inspect or document the inspection of these welds is an item of noncompliance with the require-monts of 10CFR50, Appendix B, Criterion X.

Corrective Action Taken and Results Achieved To detennine if the welds previously installed are adequate for Enrico Fenni 2 a " Cable Tray Hold Down Weld" testing program was developed. A total of One thousand eight hundred and eighty-nine (1,889) welds were inspected and cata-gorized. One hundred and thirty-seven (137) catagorized welds were examined under a load test. An analysis of the plans statistical results by Project Quality Assurance revealed acceptable confidence levels in the plan. Engineer-ing review of both the testing plan and the statistical analysis has concluded that these welds (made prior to July,1982) are structurally acceptable.

Ref: Ictters EF2-59559, F2S82-4820, F2S82-4274 Corrective Action Taken to Avoid Further Noncmpliance Detroit Edison Engineering issued a design revision for the amount of weld required to attach cable trays to a seismic support. All new welds must meet the minimum dimensions of 1/8" size by 1/2" length. Engineering Standard STD-EB-ll7.57 is discontinued and standards STD-EB-ll7.86, STD-EB-117.87 pro-vide attainable weld dimensions. Design Change Notice DCN-7564 clarifies the physical characteristics of the weld by incorporating the American Welding Society's D1.1 criteria.

Date When Full Cmpliance Will be Achieved Full ocanpliance should be achieved September 20, 1982.

Response to IEC Inspection Report No. 50-341/82-10 (82-10-21)

Statement of Open Itm, 82-10-21,Section V, Item B-4 A unique identification number was not assigned to each of the hangers of the same style...The DII'o Project Manager, in a letter dated July 2,1982, direct-ed the Construction Project Manager to develop a procedure to supplement existing procedures to provide evidence of inspection coverage on fabrication and installation. -Pending review of the revised procedure, this is considered an open item.

Corrective Action Taken and Results Achieved Unique hanger numbers are assigned to each inspected cable tray support by the electrical construction contractor, L.K. C mstock. All new installation work reflects this identification. Records generated prior to the incorporation of individual hangers in 1980, werc considered acceptable by the administrative control of seismic support fabrication. To achieve better record retrievabi-lity the contractor will provide an index for each cable tray, identifying the hanger cmponent inspections. A retrofit records program will assign specific hanger numbers to these multiple inspection records to assist in their prmpt retrieval.

Corrective Action Taken to Avoid Further Noncompliance The Cable Tray design now includes identification for each hanger. Inspection records will be traceable to specific hangers through a system being incor .

porated into contractor and POA procedures.

Date When Full Cmpliance Will be Achieved Implementation of the program has been initiated, and will continue through cmpletion of installation and inspection of all cable tray.

Response to NRC Inspection Report Ib. 50-341/82-10 (82-10-22)

Statment of Nonocxt.pliance, 82-10-22,Section VI, Iton A-2A During examination of the Reactor Controls, Inc. weld rod issue station on June 28,1982, the inspector noted that fifty (50) 1/8 inch E7018 carbon steel electrodes were mixed in the No. 2 oven in the same cmpartment with E308L stainless steel electrodes. The inspector infonned the licensee that this was an Ltm of nonccxtpliance with the requirements of Criterion IX af 10CFR50, Appendix B, and with Reactor Controls, Inc. Procedure No. WP-121A, Rev. 2, which prohibits the storage of stainless steel electrodes in ovens or con-tainers with other classifications of electrodes.

Corrective Action Taken and Results Achieved The E7018 carbon steel electrodes were reoved frm the oven during the NPC visit.

It should be noted that no stainless steel weld rods were issued frm the Ib.

2 oven since Septerrber,1981. Also, a review by RCI was performed in June, 1982, prior to the NRC Construction Assessment Team visit, and at that time no carbon steel rods were found in the No. 2 oven.

Corrective Action Taken to Avoid Further ?bncmpliance

1. All personnel involved in the weld rod control have been retrained, in addition to the retraining, new tool rom men have been assigned for rod isnuance.
2. A rod oven surveillance sheet has been generated for the purpose of OC sign off for each oven.

In addition to the above steps being taken, Reactor Controls, Inc. has gene-rated a DDR W-8707, addressing the original nonccx:pliance.

Late When Full Cmpliance Will be Achieved The corrective action has been taken, and verified on Quality Surveillance Report #82433. This item is ready for NRC review, and the documentation and other information are available at the Enrico Fermi .2 site. .

Response to NRC Inspection Report No. 50-341/82-10 (82-10-23)

Staterrent of Nonccepliance, 82-10-23,Section VI, Itm A-2b P

During examination of Walbridge-Aldinger Cmpany fabrication shop weld rod issue station, and the iron worker's issue station in building No. 49, the f inspector noted that the thermcmeters used at these two stations to check the a holding ovens were not identified by tags or stickers, and that neither had a calibration record. The inspector was informed that neither thermmeter had '

been calibrated, and that neither was in the calibration program. This is an' its of nonccrip11ance with Criterion XII of 10CFR50, Appendix B.

Corrective Action Taken and Results Achieved On July 21, 1982, the Finish Construction / Maintenance QA (FC/M QA) Section of Project OA had two (2) thennmeter numbers, 183009 and 183010, calibrated in accordance with Project OA Procedure 9.150, Rev. 3, for use in verifying weld rod oven tmperatures.

After thermcmeters were calibrated, they were used to verify the temperatures of weld rod ovens No. 2 and No. 5. The ovens were found to be within the required range outlined in AWS Dl.1-75, Section 4.92.

On July 21, 1982, Walbridge-Aldinger C(upany (WAco) ordered three (3) Therno-meters for use in verifying weld rod oven temperatures. These were assigned numbers WA001, WA002, and WA003, and turned over to FC/M-QA on July 24, 1982, to be entered into the calibration program in accordance with POAP 9.150, Rev.

3. 'Ivo (2) thentcmeters, WA001 and WA002, were in turn issued on August 4, 1982, by K/M-OA to WAco at weld rod issue stations, building No. 49 - oven No. 5 and building No. 45 - oven No. 2, respectively in accordance with POAP 9.150, Rev. 3, and WCo Procedure hM-IV for use in verifying weld rod oven temperatures.

Calibration documentation appears on the Daniel M&TE issue record log, and the Fermi 2 metrology certificate of calibration. These documents are maintained by m/M-OA.

The action taken has satisfactorily resolved the deficiency.

Corrective Action Taken to Avoid Further Noncompliance It has been determined that the cause of the problem was due to the thermo-meters, used for ver3'; iti;o of weld rod oven temperatures, not being incor-porated into master 9 1. aation index, and a scope describing the types of instruments /too*a er was not issued to WACo for incorporation into WACo's ,

procedures as 14p o 3. k r POAP 9.150, Rev. 3.

WACo's procedures shall be revised to include requirements of M&TE used by WCo in performing safety related construction activities. ,

Date When Full Cmpliance Will be Achieved The corrective action has been taken and verified on Quality Surveillance Report #82437. This item is ready for NRC teview, and the documentation and other information are available at the Enrico Fermi 2 site.

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e Response to NRC Inspection Report No. 50-341/82-10 (82-10-24) 1y l

Statment of Nonempliance, 82-10-24, Appendix, Item 7b l Contrary to the requirments of 10CFR50, Appendix B, Criterion XV and the Enrico Femi 2 Ouality Assurance Manual, a corponent for the RPV head insula-

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, inspection by the Edison Purchasing Department, although a Deviation Disposi-
tion Request on the itm generated by Warren Service Center was not yet dis-positioned by Fdison Engineering. This cmponent was, in turn, received on 4 cite, and both the equignent and documentation were accepted based on the
3dison Purchasing Department inspection.

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Corrective Action Taken and Results Achieved The subject DDR (N6116-1) is now closed, and a copy has been incorporated in

'the documentation package. All reaining documentation for material received 1 frm Warren Service Center was reviewed per sits procedures to verify caa-pleteness.

Corrective Action Taken to Avoid Further Noncompliarice Site receiving inspection personnel were retrained on the need to verify that complete documentation is received before acceptance of the material on site.

Date When Full Cmpliance Will b Achieved Full compliance has been achieved.

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