ML20062E077
| ML20062E077 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 07/26/1982 |
| From: | Purple R Office of Nuclear Reactor Regulation |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| TASK-AS, TASK-BN-82-77 BN--82-77, BN-82-77, NUDOCS 8208060326 | |
| Download: ML20062E077 (6) | |
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- JUL 2 61982 Docket tio.: 50-341 tiEt:0RA!!DUtt FOR: Atomic Safety and Licensing Board for Ferni 2 FRON: Robert A. Purple, Deputy Director, Division of Licensing, t;RR
SUBJECT:
ItiFORt'.ATI0ll REGARDIf;G OUALITY ASSUPANCE DURItiG C0?!STRUCT10l! At:D EtERGEtiCY PREPARED!!ESS (Gil 82-77) In accordance with tiRR Office Letter tio.19 Fevision 1, the enclosed reports are sent for infomation. This infomation nay be relevant and naterial to contentions regarding quality assurance during construction and evacuation of a sna11 comunity near the plant during energencies. By our April 30, 1982 board notification (Pl! 02-43), we transmitted !!RC Inspection Report !!o. 50-341/92-01 which identified itens of non-compliance with the !!RC quality assurance criteria. Enclosure 1 provides Detroit Edison's responses for these non-conp1 f ince itens. The f(RC staff's evaluation of these responses will be provided in future inspection reports. Enclosure 2 provides revised radiological emergency response plans for Fermi 2, the State of fiichigan, f tonroe County, and llayne County. Inplementing procedures for the Femi 2 plan which provide detailed action descriptions are listed in Appendix 2 of the Femi 2 plan. These procedures were transnitted to the t!RC but are not included in this board notification because the energency action descrip-tions in the Femi 2 energency plan are sufficiently detailed. Enclosure 2 also provides a report entitled "Estinate of Evacuation Tines" that was transmitted to the NRC with the energency plans. Enclosure 2 is included only with copies sent to those on the OELD service list because the emergency plans are bulky and they have received the standard !!RC distribution. The !!RC staff's evaluation of these encreency response plans will be provided in Supplenent !!o. 3 to the Femi 2 Safety Evaluation Peport, scheduled to be issued in September 1982. The infomation transmitted in this board notification is unique to the Femi 2 plant. Sincerely, Mninal Of nod 8 by' Robert A Purplo Robert A. Purple, Deputy Director Division of Licensing , Office of Nuclear Reactor Regulation '
Enclosure:
As stated M q ,
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Docket !!o.: 50-341 // - f-liEl'ORAFDUf t FOR: Atonic Safety and Licensing Board for Fermi 2 ,ff' FR0!!: D. G. Eisenhut, Director, Division of Licensing, HRR s f
SUBJECT:
IhFORfiATION RECARDING CUALITY ASSURAf;CE DURING CONSTRUCTION AND E!!ERGENCY PREPAREDhESS (DN 82- ) N '
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In accordance with NRR Office Letter No.19 Revision 1 the enclosed reports are sent for infomation. Thisiinformation may be relevant and naterial to contentions 2 regarding quality assurance during construction and evacuation of a small comunity ' near the plant during emergencies. j By our April.30, 1982 board notifii:ation '(BN 82-43), we transmitted HRC Inspection
- Report No. 50-341/82-01 which identified itens of non-conpliance with the NRC
, quality assurance criteria. Enclosure'l provides Detroit Edison's response for these non-compliance items. s 4
/ N Enclosure 2 provides revised radiological energency response plans for Fermi 2,
- the State of Michigan, Monroe. County, and Wayne County. Implementing procedures for the Femi 2 plan which provide detailed action descriptions are listed in Appendix 2 of the Femi 2 plan. These proceduresswere transmitted to the NRC but are not included in this board notification becauss thesenergency action descrip-tions in the Fermi 2 emergency plan are sufficient 1y' detailed. Enclosure 2 'also
, provides a report entitled "Estinate of Evacuation Tin'es" that was transnittdf1 to the NRC with the emergency pisns. Enclosure 2 is incipded only with copies sent to those on trJe'0 ELD service list because the energency plans are bulky and ,
they have received the standard NRC distribution. N (\ The information transmitted in this board notification is uniq\ue to the Fermi 2 plant. Sincerely, ,
' I Darrell G. Eisenhut, Director '
Division of Licensing Office of Huclear Reactor Regulation , i i
Enclosure:
As stated
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DISTRIBUTION OF BOARD NOTIFICATION Fermi 2/ASLB ** Docket No. 50-341 ACRS Members
- Gary L. Milhollin, Esq. Dr. Robert C. Axtmann Dr. Peter A. Morris Mr. Myer Bender Dr. David R. Schink Dr. Max W. Carbon Mr. Jesse C. Ebersole Mr. David E. Howell Mr. Harold Etherington Peter A. Marquardt, Esq. Dr. William Kerr Harry Voigt, Esq. Dr. Harold W. Lewis Dr. J. Carson Mark Atomic Safety and Licensing Mr. William M. Mathis Board Panel Dr. Dade W. Moeller Atomic Safety and Licensing Dr. David Okrent Appeal Panel Dr. Milton S. Plesset Docketing and Service Section Mr. Jeremiah J. Ray Document Management Branch Dr. Paul C. Shewmon Dr. Chester P. Siess Mr. David A. Ward with Enclosure 1 with Enclosure 1 and 2 t
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s __ . ' 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 i Peter A. Marquardt, Esq. Co-Counsel The Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Mr. William J. Fahrner i Project Manager - Fermi 2 i The Detroit Edison Company i' 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 U. S. Nuclear Regulatory Commission Resident Inspector's Office 6450 W. Dixie Highway l Newport, Michigan 48166 l Dr. Wayne Jens i Detroit Edison Company 2000 Second Aver.ae Detroit, Michigan 48226 l Mr. James G. Keppler Nuclear Regulatory Commission Region III , 799 Roosevelt Road l Glen Ellyn, Illinois 60137 l l
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? ; Enclosure 1 Detroit Edison Company Response 't to Items of Non Compliance described in IE Report 50-341/82-01 t
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1 n j Docket No. 50-341 i The Detroit Edison Company ATTN: Mr. Donald A. Wells Manager, Quality Assurance
, i 2000 Second Avenue i ,
Detroit, MI 48226 j i Gentlemen: i ! Thank you for your letter dated April 30, 1982, and your amended response
; - dated June 7,1982, informing us of the steps you have taken to correct the i I noncompliances which we brought to your attention in Inspection Report No. 50-341/82-01 forwarded by our letter dated April 1,1982. We will j examine these matters during a subsequent inspection.
l Your cooperation with us is appreciated. i Sincerely, l, i 3 R. L. Spessard, Director i Division of Project and Resident Programs l . cc w/ltrs dtd 4/30/82
! and 6/7/82:
l : DMB/ Document Control Desk (RIDS) 4 i Resident Inspector, RIII l Ronald Callen, Michigan Public i l Service Comission j ; Harry H. Voight, Esq. i
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%cMan l (313) 237 8000 48226 April 30, 1982 EF2-57465 Mr. R.L. Spessard, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Ccmission Region III 799 Roosevelt Road
. Glen Ellyn, Illinois 60137
Subject:
Ncnccepliance at Enrico Femi Unit 2 Construct 1cn Site
Dear Mr. Spessard:
- This letter responds to tra ite=s of nerampliance described in your IE
- , Report 50-341/82-01. This inspection of Enrico Femi Unit 2 Site Con-struction activities was perforred by the Site Resident Inspectors Messrs.
B.H. Little and P.M. Byron of NRC Region III during the I:enth of January,
,8 ! 1982.
Only the cited items of nonccepliahce are discussed in this reply, as re-quired by Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Ccde of Federal Regulations. The enalosed respense is amW. in semence of iters cited in the bcdy. of your report. The finding and section numbers are referenced. We trust this letter satisfactorily answrs the concerns raised in your report. We j . will be glad to discuss any further concerns you may have. Very truly ym rs, g l q)% 1 i j l l
.M) h cAN/HAN/cp cc: Mr. Richard DeYoung, Director Office of Inspecticn and Enforce:rnt U.S. Nuclear Regulatory Ccmission Washingten, D.C. 20555 Mr. Bruce Little, Pasident Inspector .' U.S. Nuclear Regulatory Ccmission 1 6450 North Dixie Highway 9 Newport, Michigan 48166 U 'i i?
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Mr. R.L. Spessarti April 30,1982 Page Two EF2-57465
; bec: T.A. Alessi l'
J.C. Ard, Jr. C.R. Bacon j W.A. Boelter i W.F. Colbert
, W.J. Fahrner
} E.P. Griffing/E.H. Newton C.M. Heidel i W.H. Jens P.A. Marquardt/ Docket File (2)
S.H. Noetzel -
; J.W. Nunley J.D. Ryan -
L.E. Schuerman H. Tauber
, G.M. Trahey R.A. Van /L.E. Eix H.A. Walker A.E. Wegele hm=nt Control l NRC Follow-Up Book /NRC File Chron File .t t
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THE DETROIT EDISCN CCMPAW OUALITY ASSURANCE DEFIRD E7f
, ENRICO FERE 2 PROJECT Response to NRC Report No. 50-341/82-03 Docket No. 50-341 License !b. CPPR-87 Inspection at: Fer:ni 2 Site, Mcnroe, Michigan
. Inspection conducted: January, 1982
/ n Pre W my: ,ue w 4f.A. Walker, Super /1scr Ccnstruction CA Approved By: [ b __
T.A. Alessi, Director (j Project Quality Assurance ll !J t U lI u li fl lt ,i ,i i o !} l MO f M _2WM g F W,. ' %E EW' Whh .' MOM MT"ui- Ib A t- B*Mesp'e. 9* 6 s w.9 .m,=Mm=%=.h=..' .*=&" *** " - - " " * "
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Response to NRC Inspection Recort 4 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 Fezmi Unit 2 Quality Assurance Manual, Section 17.1.3, inadequate corrective actions were taken with regard to the failure of the Core Spray System Dcpansion Bellows during system hydrotest, in that actual pressure and displacement conditicns which centributed to failure of the bellows were not factored into the evaluaticn of the failure, and were not dm=nted 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 renoved prior to initiation of a nonconfornance report (NCR) . An NCR was issued and is being processed through the site NCR system. -
'1he Core Spray System Bellows apparently failed due to over pressurization during a filling operaticn prior to flushing. Engineering has performed a re-evaluation of ccanponents in the core spray system and the flushing pressure was reduced for this system.
Engineering investigaticn 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 movement in the lateral and vertical directions. However, the bellows were designed and delivered without tie-rods. Encuneering design p:a..santly requires replacing hod. M.si.:n bclima with bellows that include tie-reds. Corrective Action Taken to Avoid Further Ncnccrpliance This incident has bcen discussed thoroughly with the management of the organi-zations involved and the necessity for 1::rediate dm=ntation of nonconfonrances has been ecphasized. No additional incidents of removal of nonconforming items prior to initiation of NGs and evaluation of failures have been noted. .i A hold was placed on flushing operaticos and Eng.4neering performed a re-evalua-tien of w w mEntt in other systems being flushed at pressures in excess of i the required hydre 'atic test pressure. As this re-evaluation was empleted flushing operations were allowed to resume. Date When Full Ccepliance Will Be Achieved Engineering re-evaluation of system ccuponents and investigatien of the prcblem have been ecmpleted. Replacement Core Spray System Bellows will be installed prior to fuel load.
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- 2. a. Statement of violation 82-01, Arundix A -(82-01-01)
Cmtrary to 10CFR50, Appendix B, Criterion V, and the Enrico Fermi 2 Quality Assurance Manual, Section 9.1.5, Reactor Controls (RCI) Pro-cedure AC-1, Revision 2, requirements regarding access cleanliness control were not being implemented in the area of the reactor pressure L 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
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persmnel were allowed to enter the RPV without removing 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 perscnal items I is now being performed. After discovery of the problem persmnel em-trolling access to the reactor pressure vessel were 4-=A4=tely reindoc-trinated in procedural requirements. Cmpliance to the procedure was verified by both Reactor Ccatrols Quality Cmtrol and Project Quality Assurance. Corrective Action Taken to Avoid Further Nonccumliances j Personnel ccntrolling access to the reactor vessel were i==d4=tely re-indoctrinated in the requirements of RCI Procedure AC-1, Revisica 2. 'Ihe procedure (AC-1) was re-reviewed for cmpliance to General Electric and . Project requirements and was updated for clarificaticn. Date When Full Ccrmlian 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 10CER50, Appendix B, Criteria V, and the Enrico Fermi 2 Quality Assurance Manual, Section 9.1.5, Detzeit Edison's subcontractor failed to u provide h==nted instructions for an activity affecting quality, i.e., the removal of machining chips frcm the control rod drive housing. 1 L Corrective Acticn Taken and the Results Achieved The machining chips in the CRD housing assemblies were re oved 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. 'Ihis was the method specified by a memorandum frcm General Electric. After removal of the chips the affected_ surfaces of the CRD housing assemblies were re-inspected using ! the GE manufacturing drawing for acceptance or rejection of the assemblies. , All CRD housing assemblies were insi=cted in this area. The entire operation l J " is very simple and should not require a detailed doc'xnented procedure to perform. Detroit Edison feels that to proceduralize to this level is imprac-tical and beyond the intent of Criterion V of 10CFR50, Appendix B. i 1 r
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Corrective Acticn Taken to Avoid Furder Ncncmpliance
'Ihis matter has been thoroughly diemM with the Contractor quality persconel. They are fully infor::ed of the requirenent and need for procedures for work on safety related equip:ent.
Date When Full Ccepliance Will Be Achieved
'Ihe Fermi 2 Project is now in ccr:pliance with requirerents in this area.
- 3. Staterent of Violation 82-01 Appendix A (82-01-02)
Contrary to 10CER50 A;-AN B, Criterion XVI and the Enrico Fermi Unit 2 Cuality Assurance Manual, Section 17.1.1, Detroit Edison's subcentractor Cuality Centrol personnel failed to prtz:ptly identify and report on machin-ing chips found in the centrol red 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 rachining chips in his weekly report in week 17 of 1981. 'Ihis item was i then recorded in GE's Open Items Irg. 'Ihis method of tracking unresolved
; items is required by the General Electric CA Program. All loose and easily removed chips have been removed and the centrol red drive (CRD) housings have been re-inspected. A Deviaticn Disposition Request (nonconformance leport) has been written on nine CRD housing asserblies frcm which th chips cculd not be re:cved or which have a rough rachined surface. This DDR is now being processed through the Project DCR system.
The rachining chips were not ecmsidered a significant problem for the felleving reascns:
- 1. The machining chips were not loose and probably would not have been dislodged in nomal operations.
- 2. The machining chips did not interfere with the insertion and locking
, of the ther::a1 sleeve during the themal sleeve trial fit.
- 3. If the problem had not been noted and the chips were to be dislodged, the most likely tire would be during flushing operatiens which would g nean they would be re::cved frcm the system.
u 4. With the themal sleeve installed, it is almost irpossible for chips to reach the CRD. 1 5. Three filters are provided en the CRD to prevent foreign material frcm
! entering the drive.
l Corrective Action Taken to Avoid Further Ncacmpliances Procedural requirements for denting nonconfomances have been discussed with RCI and GE. These centractors have been instructed to take the steps necessary to ensure that the centractor organizations follow Project Proce-dures for controlling ncnconforming raterial. H
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7 Date kten Full Ccroliance Will Be Achieved The Fermi 2 Project is now in c:rpliance with requirerents in this area.
- 4. Notice of Violation 82-01, Areendix A (82-0M4)
Contrary to 10CFR50, Appendix B, Criterion XV and the Enrico Fermi 2 Quality Assurance Manual, Section 7.0.1 effective reasures were rot established to prevent the installation of nonconfor dng control rod drive housings (i.e., they contained eachining chips) in the reactor vessel. Corrective Acticn Taken and the Results Achieved
! The Control Rod Drive Housing asserblies were ranufactured by General Electric at their Wilmington, North Carolina facility and received at the site in 1972. After ranufacture the p were efeaned prior to final inspection by 1:mersion in an agitated hot (f80 F) alkalira solution followed by a hot deionized water rinse (180 F) . The A were tilted at each cperation to accelerate drainage frcet the narrow opening (cap end) to the bottcr.1 erd.
- The parts were examined 100% visually for cleanliness following these clean-i ing operations. (It should be noted that the machining chips were not loose and were located underneath the inside lip of the CRD Pousing assemblies where they were not visible without an inspection mirror.)
In addition to this, at the time of ranufacture a Detroit Edison source inspector perforced a sa:gling inspection to assure that GE's inspections were being adequately performed. Corrective Action Taken to Avoid Further Ncncccc11ance
; General Electric was notified of the problem and they have stated that the problem had been previously addressed. GE's letter of Febra7 5,1982 states, "We have had previous occurences similar to the incident at Fer=1. , There has not been any similar prcblers in the past few years and this is attributed to an increased awareness of cleanliness m;uirements by j inspector and shop cleaning personnel. 'Ib my krowledge, no eccplaints ; have been received since the added discipline was i= posed".
i Date Khen Full Ccrnlaince Will Be Achieved i
; 'Ihe Fermi 2 Project is row in ccrpliance in this area.
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'l H.A. Walker, Supervisor Construction Quality ASsurarce
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- W iv Detro.t. Micnigan 48226 (313) 237 8000 June 7, 1982 EF2-58073 Mr. R.L. Spessard, Director Division of N oject and Resident Programs U.S. Nuclear Regulatory Ccmnission Region III 799 Rcesevelt Road Glen Ellyn, Illinois 60137 t"
Reference:
Intter EF2-57465 Dated April 30, 1982 frczn Donald A. Wells to R.L. Spessard
Subject:
Ncnccarpliance at Enrico Fermi Unit 2 Construction Site
Dear Mr. Spessard:
This letter provides an arended response to the items of nonectrpliance described in your IE Report 50-341/82-01. This inspecticn of Enrico Fermi Unit 2 Site Construction activities was perfon ed by the Site Resident Inspectors Messrs. B.H. Little and P.M. Byron of NRC Region III during the renth of January, 1982. Based on discussions with the NRC Site Resident Inspectors and Project Quality Assurance Manay~, Streit Ediscn h's decided tc revice the action taken en inspection iters 2-b and 4. Although the entire report is being re-subnitted, no other iters or inforration.has been changed. We feel this revised response more accurately describes the actions taken. The enclosed response is arranged in sequence of iters cited in the body of your report. The finding and section nurlers are referenced. We trust this letter satisfactorily answers the concerns raised in your report. We will be glad to discuss any furtter concerns you ray have. Very truly yours,
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DAW /WM/cp , cc: Mr. Richard DeYoung, Director i Office of Inspection aid Enforcement U.S. Nuclear Regulatory Ccrmission Washington, D.C. 20555 , Mr. Bruce Little, Resident Inspector U.S. Nuclear Regulatory Ccur.ission 6450 North Dixie Highway Newport, Michigan 48166
*i j#) EfMUM1 G PDR JUN 16 1982
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'IEE DETROIT EDISOi CCMPNTI CUALITY ASSURNKE DEPARDE24T ERICO FERE 2 PRODrr Amended Response to NRC Report No. 50-341/82-01
- Docket No. 50-341 License No. CPPR-87 Inspection at: Fer:ni 2 Site, Monroe, Michigan -
1 Inspection conducted: January, 1982 L Prepared By: - [- fi.A. Walker, Supervisor Construction CA
,' Approved By:
.' T.A. Alessi, Direc+wr Project Quality Assurance a t
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, Page 2 of 6 Resconse to NRC Insoection Report # 50-341/82-01
- 1. Statement of violation 82-01, Apoendix 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 and displacement conditions which contibuted to failure of the bellows were not factored into the evaluation 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 ncnconformance 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. Enginearing has performed a re-evaluatien of ccuponents 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 seirmic load, cnly 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 1: mediate dccumentation of nonconforrances F has been emphasized. No additional incidents of removal of nonconfor:ning iters 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 ccrponents in other systems being flushed at pressures in excess of the required hydrostatic test pressure. As this re-evaluation was ccnpleted flushing operations wre allowed to resume. 1 Date hhen Full Cmp 11ance Will Be Achieved _ Engineering re-evaluation of system cmponents and investigation of the problem have been cmpleted. Replacement Core Spray System Bellows will be installed prior to fuel load. b
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- 2. a. Statement of Violation 82-01, Appendix A (82-01-01)
Contrary to 10CFR50, Apperdix B, Criterion V, and the Enrico Fermi 2 t Quality Assurance Manual, Section 9.1.5, Reactor Controls (RCI) Pro-cedure AC-1, Revision 2, requirerents regarding access cleanliness centrol were not being implemented 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 ard out of the RPV, and
' personnel were allowed to enter the RPV withcut removing or securing loose personal articles.
Corrective Action Taken and the Results Achiewd, A clean rocm has now been established at the entrance to the reactor pressure vessel and the logging of tools and securing of perscnal iters is now being performed. After discovery of the prcblem personnel con-trolling access to the reactor pressure vessel were imediately reindoc-trinated in procedural requirements. Cmpliance to the procedure was 1 verified by both Reactor Controls Cuality Control and Project Quality Assurance. Corrective Action Taken to Avoid Further Ncnccxmliances Personnel controlling access to the reactor vessel were imediately re-indoctrinated in the requirements of RCI Procedure AC-1, Revision 2. The
; procedure (AC-1) was re-reviewed for ccxrpliance to General Electric and Project requirements and was updated for clarificat.icn.
Date Khen Full Ccrmliance Will Be Achieved The Fermi 2 Project is now in ccepliance withiWts in this area. 1 2. b. Statement of violation 82-01, Accendix A (92-01-03) i Centrary to 10CFR50, Appendix B, Criteria V, and the Enrico Fermi 2 Ouality
- Assurance Manual, Section 9.1.5, Detroit Edison's subcontractor failed to i provide documented instructions for an activity affecting quality, i.e.,
J the removal of eachining chips frcm the control rod drive housing. i Corrective Action Taken and the Results Achieved f The machinjag chips in the CRD housing asse=blies were reroved where i possible by locating the chips by using a mirror and then remcVing the
, chips by using angle needle nose pliers, a wire hook or other suitable means. This work has now been ecupleted ard is tra method specified by the memorandum frcm General Electric. After rencval of the chips all affected surfaces of the CRD housing asserblies were re-inspected using 1 the GE manufacturing drawing for acceptance or rejection of the asserblies.
Based on this criteria nine of the asserblies were rejected where ccuplete renoval of the chips could not be acccuplished. These asserblies are now being processed by the site Deviation Dispositicn Request (DDR) system. Althcugh the chip removal was not proceduralized in detail, the results are considered acceptable by Detroit Edisen with the exception of the nine CRD housing asserblies which were rejected. t i syi-*-+*+-- ,+ e w + % s= == avw= == ==em- m -e + - me,.%-++-N-_me-;-rw-+~**~*~+- . a~~**- -+--*e==~~~- **'+7- c ~ m
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Corrective Action Taken to Avoid Further Nonca:cliance
' This matter has been thoroughly ' discussed with the Contractor quality personnel. They are fully informed of the requirenent and need for procedures which adequately describe acceptance criteria for work on safety related equiptent.
Date When Full Cctrpliance Will Be Achieved The Fermi 2 Project is ncw in ca:pliance with requirements in this area.
- 3. statement of violation 82-01 Apoendix A (82-01-02)
Contrary to 10CFR50 Appendix B, Criterion XVI and the Enrico Fezmi Unit 2 1
, Quality Assurance Manual, Section 17.1.1, Detroit Edison's subcontractor
' Cuality Control personnel failed to prenptly identify and report on machin-ing chips found in the control red drive housings in accordance with the licensee's procedures.
; Corrective Action Taken and the Results Achieved ij 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 i then recorded in GE's Open Items Icg. This 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 red drive (CRD) housings
have been re-inspected. A Deviation Disposition Request (noncenfor:rance report) has been written on nine CRD housing asserblies frcan which the chips
- i 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 folicwing reasons:
- 1. The machining chips were not 1cose and probably would not have been dislodged in noI=al operations.
l 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 renoved fran the system.
t! 4. With the thermal sleeve installed, it is almost 1::possible for chips { to reach the CRD.
- 5. Three filters are provided on the CRD to prevent foreign raterial fran
- t entering the drive.
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Corrective Action Taken to Avoid Further Noncer pliances Procedural requirerents for dtv m uting nonconforrances have been discussed with RCI and GE. These contractors have been instructed to take the steps necessary to ensure that the contractor organizations follcw Project Proce-dures for controlling nonconfoming material. Date When Full Carpliance Will Be Achieved The Fem.12 Project is ncw in ccupliance with requirements 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 contaired machining chips) in the reactor vessel. , Corrective Action Taken and the Results Achieved The rachining chips have been reroved frcm the control red drive housing
, assemblies where possible and the housings have been re-inspected to ranu-facturing requirements, i
Corrective Action Taken to Avoid Further Nonccrrpliance 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 similar to the incident at Fermi. There has not been any similar prcblers in the past few years and this is 4 attributed to an Jr. creased awareness of cleanlir.ase requirew.nts by inspector and shcp cleaning personnel. To my knowledge, no cceplaints have been received since the added discipline was imposed." Since the receipt of the CRD housing assemblies additicnal steps were taken to improve source inspection activities. These are as fo11cws: 4 a. One Hundred percent scurce inspectica is new required in prcblem areas instead of allowing Scurce Inspectors to sanple.
- b. Source inspecticn criteria has been clarified in problem areas to
- provide better inspecticn.
4
- c. Problem areas are diccussed with source inspectors to provide increased awarerass in trase areas.
This ratter has been thoroughly discussed with the site contractor in this area to ensure that he understands the need for verifying that adequate inspections !j are ccupleted for ensuring conforrance to requirer'nts. Date When Full Cc=pliance Will Be Achieved The Fermi 2 Project is ncw in ecrpliance in this area. il .i
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1 The foregoing statements are based on facts and circurstances which are true and accurate to the best of my knowledge and belief.
- f. g. #A H.A. Walker, Supervisor Construction Quality Assurance
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Subscribed and stern to before me this 8th day of Jtme,1982 4
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,, % JENNIFlY KYKO %
Notary Public, Monroe County, MI
, My Ccmmission Expires Nov.26,1984
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BOARD NOTIFICATION DISTRIBUTION: J)L261982 BN 82-77 iDecument Contro1r(50-341),*p NRC PDR* L PDR
- TERA
- NSIC
- LB#1 Rdg.
- JYoungblood
- LKintner
- MRushbrook
- RTedesco/JKerrigan/LBerry DEisenhut/RPurple Williams HDenton/ECase
- PPAS ASchwencer FMiraglia EAdensam SSPB Branch Chief RVollmer HThompson RMattson SHanauer Attorney, OELD* .
OIE WJDircks, ED0 (3) ABennette (4) EChristenbury, ELD
- JScinto, ELD
- cc: OELD Service List **
LBf1 Service List
- with Enclosure 1
** with Enclosure 1 and 2 l
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