ML20054K614

Forwards Amended Response to NRC Re Violations Noted in IE Insp Rept 50-341/82-01.Corrective Actions: Replacement Core Spray Sys Will Be Installed Prior to Fuel Load & Clean Room Established

ML20054K614
Person / Time
Site:	Fermi
Issue date:	06/07/1982
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
EF2-58073, NUDOCS 8207020378
Download: ML20054K614 (7)

Text

Donald A. Wells Manager Ot,atay As%fance (313} 237-% 57 2000 Second Avenue 31 3 June 7, 1982 EF2-58073 Mr.-R.L. Spessard, Director

. Division of Project and Resident Programs U.S. Nuclear Regulatory Ccumission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Reference:

Letter EF2-57465 Dated April 30, 1982 frcm Donald A.' Wells to R.L. Spessard

Subject:

Nonccrupliance at Enrico Fermi Unit 2 Construction Site

Dear Mr. Spessard:

This letter provides an amended response to the items of nonecmpliance described in your IE Report 50-341/82-01. This inspection of Enrico Fermi Unit 2 Site Construction activities was performed by the Site Resident Inspectors Messrs. B.H. Little and P.M. Byron of NRC Region III during the nonth of January,1982.

Based on discussions with the NRC Site Resident Inspectors and Project Quality Assurance Management, Detroit Edison has decided to revise the action taken on inspection items 2-b and 4. Although the entire report-is being re-subnitted, no other items or information has been changed.

We feel this revised response more accurately describes the actions taken.

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. We will be glad to discuss any further concerns you may have.

Very truly yours, DAW / HAW /cp J

cc: Mr. Richard DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Ccumission Washington, D.C. 20555 Mr. Bruce Little, Resident Inspector U.S. Nuclear Regulatory Ccxmtission 6450 North Dixie Highway Newport, Michigan 48166 8207020378 820624 >JUN 16 1982 PDR ADOCK 05000341 G PDR

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THE DEIROIT EDISON CCEPANY QUALITY ~ ASSURANCE DEPARIMENT i

f DRICO FERMI 2 PROJECT ,

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Amerrlod Response to NRC Report No. 50-341/82-01 1

Docket No. 50-341 License No. CPPR-87 l

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Inspection at: Fermi 2 Site, Monroe, Michigan l Inspection conciucted: January, 1982 i

Prepared By: [- L( % I ff.A. Walker, ' Supervisor '-

Construction OA

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J Approved By:

4 T.A. Alessi, Director ,

Project Quality Assurance i

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Page 2 of 6 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 Quality Assurance Manual, Section 17.1.3, inadequate corrective actions were taken with regard to the failure of the Core Spray System Expansion Bellcws during system hydrotest, in that actual pressure an:1 displacement conditions which contibuted to failure of the bellows were not factored into the evaluation of the failure, and were not documentcd 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 ccaponents in the core spray system and_ the flushing pressure was reduced for this system.

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

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

Corrective Action Taken to Avoid Further Nonccmpliance This incident has been discussed thoroughly with the management of the organi-zations involved and the necessity for inmediate docurrentation 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 performed 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 ccmpleted flushing operations were allowed to resume.

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

Page 3 of 6

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

Contrary to 10CFR50, Appendix B, Criterion V, and the Enrico Fermi 2 Quality Assurance Manual, Section 9.1.5, Reactor Controls (RCI) Pro-cedure A"-1, Revision 2, requirenents regarding access cleanliness control were not being implenented in the area of the reactor pressure vessel (RPV), in that a clean rocm 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 renoving or securing loose personal articles.

a Corrective Action Taken and the Results Achieved A clean rocm 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 perforned. After discovery of the problem personnel con-trolling access to the reactor pressure vessel were innediately reindoc-trinated in procedural requireaents. Cctrpliance to the procedure was verified by both Reactor Controls Quality Control and Project Quality Assurance.

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

Date Khen Full Ccrnpliance Will Be Achieved The Fermi 2 Project is now in ccarpliance with requirenonts in this area.

2. b. Statement of Violation 82-01, Appendix A (92-01-03) 1, 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 frcrn the control rod drive housing.

Corrective Action Taken and the Results Achieved i The machining chips in the CRD housing assemblies were removed where possibic by locating the chips by using a mirror and then removing the chips by using angle needle nose pliers, a wire hook or other suitable neans. This work has now been ccrupleted and is the nethod specified by l the nemorandum frcrn General Electric. After removal of the chips all affected surfaces of the CRD housing assemblies were re-inspected using the GE manufacturing drawing for acceptance or rejection of the assemblies.

Based on this criteria nine of the assemblies were rejected where ecmplete renoval of the chips could not be acccrrplished. These asserrblies are now being processed by the site Deviation Disposition Request (DDR) system.

Although the chip removal was not proceduralized in detail, the results are considered acceptable by Detroit Edison with the exception of the nine CRD housing assemblies which were rejected.

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Page 4 of 6 Corrective Action Taken to Avoid Further Noncmpliance This matter has been thoroughly discussed with the Contractor quality personnel. They are fully informed of tle requirement and need for

. procedures which adequately describe acceptance criteria for work on safety related equignent.

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

3. Statemei? 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 Log. This method of tracking unresolved items is required by the General Electric OA Program. All loose and easily renoved 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 frun which the chips could not be removed or which have a rough machined surface. This ODR 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 retroved fran 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 from entering the drive.

Page 5 of 6 Cormctive Action Taken to Avoid Further Nonempliances Procedural requirements for documenting nonconformances have been discussed with RCI and GE. These contractors have been instructed to take the steps necessary to ensure th.it the contractor organizations follow Project Proce-dures for controlling nonconforming material.

Date When Full Cmpliance Will Be Achieved The Fermi 2 Project is now in ccurpliance with requirenents in this area.

4. Notice of Violation 82-01, Appendix A (82-01-04)

Contrary to 10CFR50, Appendix B, Criterion XV and the Enrico Fermi 2 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 machining chips have been mmoved frm the control rod drive housing assemblics wnere possible and the housings have been re-inspected to manu-facturing requirements.

Corrective Action Taken to Avoid Further Nonempliance General Electric was notified of the problem and they have stated that the problem had been previously addressed. GE's letter of February 5,1982 states, "We have had previous occurrences snailar to the incident at Fermi.

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

Since the receipt of the CRD housing assemblies additional steps were taken to improve source inspection activities. These are as follows:

a. One Hundred percent source inspection is now required in problem areas instead of allowing Soulce Inspectors to sample.

b. Source inspection criteria has been clarified in problem areas to provide better inspection.

c. Problem areas are discussed with source inspectors to provide increased awareness in these areas.

This matter has been thoroughly discussed with the site contractor in this area to ensure that he understands the need for verifying that adequate inspections are cmpleted for ensuring conformance to requirements.

_Date When Full Compliance Will Be Achieved The Fermi 2 Project is now in ccrapliance in this area.

Page 6 of 6 The foregoing staterrents are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

f.g.#A H.A. Walker, Supervisor Construction Quality Assurance Subscribed and sworn to before ne this 8th day of June,1982 IM k ENNIF12 J KYKO k Notary Public, Monroe County, MI My Ccmmission Dpires Nov.26,1934