ML20065P921
| ML20065P921 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/24/1982 |
| From: | Wells D DETROIT EDISON CO. |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20065P883 | List: |
| References | |
| EF2-59398, NUDOCS 8210260382 | |
| Download: ML20065P921 (5) | |
Text
,
c--
Donald A. Wells Manager Ouahty As%fance f
(313) 237-9657 Ec" son mar ue 2000 Second Aven i
September 24, 1982 EF2-59398 Mr. R.L. Spessard, Director Division of Project and Resident Prograrrs U.S. Nuclear Regulatory Ccmnission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Nonccxtpliance at Enrico Fermi Unit 2 Construction Site
Dear Mr. Spessard:
This letter responds to the items of noncciupliance described in your IE Report 50-341/82-08. This inspection of Enrico Fermi Unit 2 Site Construction activities was performed by Mr. I.T. Yin of NRC Region III on May 25-28, June 30, July 1-2, 1982 at the site, and July 1,1982 at the DECO Corporate office.
Only the cited items of nonecrupliance 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.
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 /WRW/cp cc: Mr. Richard DeYoung, Director Office of Inspection and Enforcerrent U.S. Nuclear Regulatory Ccmnission Washington, D.C. 20555 Mr. Bruce Little, Senior Resident Inspector U.S. Nuclear Regulatory Ccanission 6450 North Dixie Highway Newport, Michigan 48166 0CT 14 22 8210260382 821018 N
ADOCK 05000341
j PDR
^ -'
Mr. R.L. Spessard, Director September 24, 1982 Page TWo EF2-59398 bec:
T.A. Alessi J.C. Ard, Jr.
C.R. Bacon W.F. Colbert W.M. Everett W.J. Fahrner D. Ferencz E.P. Griffing C.M. Heidel W.H. Jens E. Lusis P.A. Marquardt/ Docket File (2)
E.H. Newton S.H. Noetzel J.W. Nunley J.D. Ryan L.E. Schuerrran H. Tauber G.M. Trahey R.A. Vance/L.E. Eix A.E. Wegele Site Document Control NRC Follow-Up Book /NRC File Chron File
_,w._
__y
--.~
(j THE DEIROIT EDISCN CCMPANY OUALITY ASSURANCE DEPARIMENT DRIOD FERMI 2 PRGTECT Response to NRC Report No. 50-341/82-08 Docket No. 50-341 License No. CPPR-87 Inspection at: Fenni 2 Site, Monroe, Michigan Inspection Conducted: May 25-28, June 30 and July 1-2, 1982, at the site and July 1, 1982, at the DECO Corporate office.
Prepared By:
m W.R. Wingfig, /lcad techanical Engineer ConstructiWOuality Assurance Noted By!
G///2g)29pm D. Ferencz, Ac Supervisor Construction lity Assurance Approved By:
T.A. Alessi, Director Project Quality Assurance
Page 2 of 3 Response to NRC Inspection # 50-341/82-08 1.
Statement of Violation 82-08, Appendix A (82-08-01)
Contrary to the requirements of '100R50, Appendix B, Criterion III and the Enrico Fermi 2 FSAR, Section A 17.1.3, the-licensee's control over the A-E's suspension system design, including the proper selection of required i
. sonN*rs, was inadequate in that rigid restraints were installed in close proximity with mechanical snubbers. The snubbers were made inoperable by restricting the mininum snubber travel required to initiate unit' lock-up..
-Restricting the snubber's travel could increase the design 1ctis at the affected rigid restraints.
Corrective Action Taken and the Results Achieved A stop. work order was issued.on May 25, 1982, for all snubber related construc-tion ~ activities. Based upon discussions and agreements between Mr. I.T. Yin l
(NRC Region III) and members of Edison's. Engineering staff, the stop work 1 -
order would not be lifted until a formal " Snubber Reduction Program" was issued for Fermi 2 by Edison and that program was reviewed and accepted by Mr. Yin.
On June 4,1982, Detroit Edison subnitted a proposed " Snubber Reduction Program" to Mr. James G. Keppler (NRC Region III). Based upon a June 7,1982, telephone 1
conversation between Mr. I.T. Yin and our Mr. J.H. Casiglia, Edison was informed i
that Mr. Yin had reviewed the proposed program and found it acceptable. On June 8, 1982,-Detroit Edison submitted a final record copy of the " Snubber Reduction Program" to Mr. James G. Keppler.
With the acceptance of the " Snubber Reduction Pmmu", Edison prrv=adad with lifting the stop work order and resumed snubber construction in an orderly and controlled fashion. To date, the major activities relative to the inplementa-j tion of this program consist of the following:
o In accordance with the " Snubber Reduction Program", on June 9,1982, the stop work order was lifted for the majority of the snubbers on the 2 inch and smaller ASME Class 2 and 3 lines that were analyzed by generic methods.
l o On July 12, 1982,the stop work order was lifted for approximately 160 snubbers on large bore piping systems which must be installed i
as per the criteria of the " Snubber Reduction Programs."
o In order to empliment construction activities, snubbers located near the RHR Punps and the Core Spray Punps were evaluated in accordance with the " Snubber Reduction Program." As-a result of that evaluation 28 snubbers are scheduled to be replaced with I
rigid struts and 4 snubbers will be cancelled.
o Inplementation of the " Snubber Reduction Program" is continuing at l
Edison. 'Ihe necessary activities are being coordinated with construc-tion activities and Edison's Piping Stress Reconciliation Programs.
In accordance with Mr. Isa T. Yin's request, Edison will provide j
cmparison of the number of all suspension conponents originally j
required and actually required after the snubber reduction program j
is empleted. This data will be included in the documentation that will be forwarded to the NRC when the program is empleted.
4 4
,,,n-.----n,,,.--n-~,..nn
,...,_,,,,,e
.n-,
,.,..,.,,--..__,,,..,n._,-,,,l
4 Page 3 of 3 Corrective Action Taken to Avoid Further Nonempliances Nme. Project Design is confident that the " Snubber Reduction Program" currently being carried out will identify any snubbers that are unnecessary frcm a thermal expansion viewpoint and will also resolve the issue of dynamic actuation of snubbers.
Date When Full Cmpliance will be Achieved Project Design estimates that full cmpliance with the " Snubber Reduction Program" will be achieved prior to fuel load.
2.
Statenent of Violation 82-08, Appendix A (82-08-02)
Contrary to 10CFR50, Appendix B, Criterion VI, and the Enrico Fermi 2 FSAR, Section A17.1.6, the Wisner arri Becker control of tM Interim Change Procedures (ICPs) was not considered to be adequate. The inspector found that all required ICPs were not inserted into the work procedures at the work locations.
Corrective Action Taken and the Results Achieved The Wisner and Becker Docunent Control Clerk verified on May 25, 1982, that records indicate the ICPs in question had been sent to the field. The responsible parties
- were contacted and advised that mrtain ICPs had been noted as missing frcm their procedure books. Required copies to correct the noted discrepancies were obtained and added to the procedure books. The conplete atriit of procedures issued to Constructicn forces was emplete an June 4,1982.
Site Document Ccntrol has performed an audit of their files and they are now up-to-date.
Corrective Action to Avoid Further Nonccmpliance A.
The Project Engineer has instructed the Docunent Ccntrol Clerk that all procedural changes to procedure books assigned to craft supervision are to be placed in the books by the Docunent Control Clerk, who will also l
remove and destroy superceded copies. This is in lieu of permitting the supervisors to update the books themselves.
l B.
The Project Engineer has issued a nemorandum to craft Supervision advising l
of the importance of maintaining current procedure books and instructing them that procedures are not to be removed frcrn tM books.
t Date When Full Cmpliance Will Be Achieved The above corrective action is inplemented and ongoing. For purposes of docunent-ing full empliance, tM date of this response is considered appropriate.
t i
i l