ML20054K608

Responds to NRC Re Violations Noted in IE Insp Rept 50-341/82-01.Corrective Actions:Replacement Core Bellows Will Be Installed Prior to Fuel Load & Clean Room to Entrance of Reactor Pressure Vessel Established

ML20054K608
Person / Time
Site:	Fermi
Issue date:	04/30/1982
From:	Wells D DETROIT EDISON CO.
To:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20054K602	List: IR 05000341/1982001 ML20054K608 ML20054K614
References
EF2-57465, NUDOCS 8207020372
Download: ML20054K608 (8)

Text

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. oy Donald A. Wells n,, .o.9 A. r<<

Detroit - -

Ecison in?#By" April 30, 1982 EF2-57465 Mr. R.L. Spessard, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Ccx: mission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Nonccxipliance at Enrico Fermi Unit 2 Construction Site

Dear Mr. Spessard:

This letter responds to the iterrs of nonecxrpliance described in your IE Report 50-341/82-01. This inspection of Enrico Fermi Unit 2 Site Con-struction activities was performed by the Site Resident Inspectors Messrs.

B.lf. Little and P.M. Byron of NRC Region III during the nonth of January, 1982.

Only the cited items of nonecripliance are discussed in this reply, as re-quired by Section 2.201 of the URC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.

The enclosed response is arranged in sequence of items 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. VM will be glad to discuss any furtirr concerns you may have.

Very truly yours,

/

Yi Y ).k W ' &

DAW /IIAW/cp cc: Mr. Richard DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Ccrmtission Washington, D.C. 20555 Mr. Bruce Little, Resident Inspector U.S. Nuclear Regulatory Ccxmtission 6450 North Dixie Highway Newport, Michigan 48166 8207020372 820624 PDR ADOCK 05000341 MAY 61982 O PDR l

Mr. R.L. Spessard April 30, 1982 Page 'Iko EF2-57465 bec: T.A. Alessi J.C. Ard, Jr.

C.R. Bacon W.A. Boelter W.F. Colbert W.J. Fahrner E.P. Griffing/E.II. Newton C.M. licicol W.li. Jens P.A. Marquardt/ Docket File (2)

S.lf. Noctzel J.W. Nunicy J.D. Ryan L.E. Schuerman

!!. Tauber G.M. Trahey R.A. Vance/L.E. Eix II.A. Walker A.E. Wegele Document Control NRC Follow-Up Book /NRC File Chron File

I THE DEIROIT EDISON C@iPANY  ;

QUALITY ASSURANCE DEW RIMENT ENRICO FERMI 2 PROJECT Response to NRC Report No. 50-341/82-01 i Docket No. 50-341 License No. CPPR-87 j Inspection at: Fermi 2 Site, Monroe, Michigan Inspection conducted: January, 1982 Prepared By: - < w 4f.A. Walker, Supervisor Construction DA Approved By: [ [44/

T.A. Alessi, Director

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Project Quality Assurance l ,

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Response to NRC Inspection Report # 50-341/82-01

1. Statement of Violation 82-01, Appendix A (82-01-06)

Contrary to 10CFR50, Appendix B, Criterion XVI and the Enrico Fermi Unit 2 Ouality Assurance Manual, Section 17.1.3, inadequate corrective actions were taken with regard to the failure of the Core Spray System Depansion Bellows during system hydrotest, in that actual pressure and displacement conditions which contributed to failure of the bellows were not factored into the evaluaticn of the failure, and were not documented and reported in accordance with the licensee's corrective action system.

Corrective Action Taken and the Results Achieved The failed Core Spray System Bellows were removed prior to initiation of a nonconformance report (NCR) . An NCR was issued and is being processed through the site NCR system.

The Core Spray System Bellows apparently failed due to over pressurization during a filling operation prior to flushing. Engineering has performed a re-evaluation of cmponents in the core spray system and the flushing pressure was Irviwvv1 for this system.

Engineering investigation also deterrtined that the expansion bellows were inadequately supported. The specific application and design for the bellows should have spacified the use of tie bars necessary to restrain the axial pressure and seismic load, only allowing movement in the lateral and vertical directions. However, the bellows were designed and delivered without tie-rods.

Engineering design presently requires replacing both expansion bellows with bellows that include tie-rods.

Corrective Action Taken to Avoid Further Nonempliance This incident has been discussed thoroughly with the management of the organi-zations involved and the necessity for innediate documentation of nonconformances has been emphasized. No additional incidents of removal of nonconforming items '

prior to initiation of NCRs and evaluation of failures have been noted.

A hold was placed on flushing operations and Engineering perforned a re-evalua-tion of cmponents in other systems being flushed at pressures in excess of the required hydrostatic test pressure. As this re-evaluation was completed flushing operations were allowed to resume.

Date When Full Ccapliance Will Be Achieved Engineering re-evaluation of system cmponents and investigation of the problem have been empleted. Replacement Core Spray System Bellows will be installed prior to fuel load. ,

2. a. Statement of Violation 82-01, Appendix A (82-01-01)

Contrary to 10CFR50, Appendix B, Criterion V, and the Enrico Fermi 2 Quality Assuran Manual, Section 9.1.5, Reactor Controls (RCI) Pro-oedure AC-1, Revision 2, requirements regarding access cleanliness control were not being inplenented in the area of the reactor pressure vessel (RPV), in that a clean rom had not been established for entry; material and tools were not being logged in and out of the RPV, and personnel were allowed to enter the RPV without Imoving or securing loose personal articles.

Corrective Action Taken and the Results Achieved A clean rom has now been established at the entrance to the reactor pressure vessel and the logging of tools and securing of personal items is now being performed. After discovery of the problem personnel con-trolling access to the reactor pressure vessel were inmediately reindoc-trinated in procedural requirements. Cm pliance to the procedure was verified by both Reactor Controls Quality Control and Project Quality Assurance.

Corrective Action Taken to Avoid Further Nonemplian s Personnel controlling access to the reactor vessel were inmediately re-indoctrinated in the requirements of RCI Procedure AC-1, Revision 2. The procedure (AC-1) was re-reviewed for cmpliance to General Electric and Project requirements and was updated for clarification.

Date When Full Cmpliance Will Be Achieved

'Ihe Fermi 2 Project is now in empliance with requirements in this area.

2. b. Statement of violation 82-01, Appendix A (82-01-03)

Contrary to 10CFR50, Appendix B, Criteria V, and the Enrico Fermi 2 Quality Assurance Manual, Section 9.1.5, Detroit Edison's subcontractor failed to provide documented instructions for an activity affecting quality, i.e.,

the removal of machining chips frm the control rod drive housing.

Corrective Action Taken and the Results Achieved The machining chips in the CRD housing assemblies were renoved by locating the chips using a mirror and then removing the chips by using angle needle nose pliers, a wire hook or other suitable means. This was the method specified by a menorandum frm General Electric. After removal of the chips the affected_ surfaces of the CRD bcusing assemblies were re-inspried using the GE manufacturing drawing for acceptance or rejection of the assemblies.

All CRD housing assemblies were inspected in this area. The entire operation is very simple and should not require a detailed documented procedure to i perform. Detroit Edison feels that to proceduralize to this level is imnrac-tical and beyond the intent of Criterion V of 10CFR50, Appendix B.

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Date hhen Full C m pliance Will Be Achieved The Fermi 2 Ptoject is now in cmpliance with requirements in this area.

4. Notice of Violation 82-01, Appendix A (82-01-04) i Contrary to 10CFR50, Appendix B, Criterion XV and the Enrico Fermi 2 l Quality Assurance Manual, Section 7.0.1 effective measures were not established to prevent the installation of nonconforming control rod drive housings (i.e., they contained machining chips) in the reactor vessel.

Corrective Action Taken and the Results Achieved The Control Rod Drive Housing assemblies were manufactured by General Electric at their Wilmington, North Carolina facility and received at the site in 1972. Aftermanufacturethepartswereefeanedprior to final inspection by innersion in an agitated hot (g80 F) alkaline solution followed by a hot deionized water rinse (180 F) . The parts were tilted at each operation to accelerate drainage frm the narrow opening (cap end) to the bottan end.

The parts were examined 100% visually for cleanliness following these clean-ing operations. (It should be noted that the machining chips were not loose and were located underneath the inside lip of the CRD housing assemblies where they were not visible without an inspection mirror.) >

< In addition to this, at the thne of manufacture a Detroit Edison source inspector performed a sampling inspection to assure that GE's inspections were being adequately performed.

Corrective Action Taken to Avoid Further Noncompliance General Electric was notified of the problem and they have stated that the

, problcra had been previously addressed. GE's letter of February 5, 1982 l states, "We have had previous occurences similar to the incident at Fonti.

There has not been any similar problems in the past few years and this is attributed to an increased awareness of cleanliness requirenents by inspector and shop cleaning personnel. To my knowledge, no cmplaints have been received since the added discipline was imposed".

Date hhen Full Cmplaince Will Be Achieved The Fermi 2 Project is now in canpliance in this area.

Corrective Action Taken to Avoid Further Nonccznpliance This matter has been thoroughly discussed with the Contractor quality personnel. They are fully informed of the requirement and need for procedures for work on safety related equignent.

Date When Full Ccrnpliance Will Be Achieved The Fermi 2 Project is now in cmpliance with requirements in this area.

3. Statement of violation 82-01 Appendix A (82-01-02)

Contrary to 10CFR50 Appendix B, Criterion XVI and the Enrico Fermi Unit 2 Quality Assurance Manual, Section 17.1.1, Detroit Edison's subcontractor Quality Control personnel failed to prmptly identify and report on machin-ing chips found in the control rod drive housings in accordance with the licensee's procedures.

Corrective Action Taken and the Results Achieved General Electric's NED quality inspector noted, reported and recorded the machining chips in his weekly report in week 17 of 1981. This item was then recorded in GE's Open Items Iog. 'Ihis method of tracking unresolved items is required by the General Electric OA Program. All loose and easily removed chips have been removed and the control rod drive (CRD) housings have been re-inspected. A Deviation Disposition Request (nonconformance report) has been written on nine CRD housing assemblies frtxn which the ch,ips could not be removed or which have a rough machined surface. This DDR is now being processed through the Project DDR system.

The machining chips were not considered a significant problem for the ,

following reasons:

1. The machining chips were not loose and probably would not have been dislodged in normal operations.

2. The machining chips did not interfere with the insertion and locking of the thermal sleeve during the thermal sleeve trial fit.

3. If the problem had not been noted and the chips were to be dislodged, the most likely time would be during flushing operations which would mean they would be removed frcm the system.

4. With the thermal sleeve installed, it is almost impossible for chips to reach the CRD.

5. Three filters are provided on the CRD to prevent foreign material frcm entering the drive.

Corrective Action Taken to Avoid Further Nonccnpliances Procedural requirements for documenting nonconformances have been discussed with RCI and GE. These contractors have been instructed to take the steps necessary '.o ensure that the contractor organizations follow Project Proce-dures for controlling nonconforming material.

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1 The foregoing statements are based on facts 4

and circumstances which are true and accurate ,

to the best.of my knowledge and belief.  !

.b i H.A. Walker, Supervisor.

Construction Quality Assurance .

i Subscribed and sworn to before me this l

29th day i of April, 1982 i

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( JENNIFIE KYKO 3 flotary Public, Monroe County, MI Mi Commission Expires Nov.26,1984  ;

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