ML20073T193
| ML20073T193 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/31/1983 |
| From: | Wells D DETROIT EDISON CO. |
| To: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20073T185 | List: |
| References | |
| EF2-62619, NUDOCS 8305100393 | |
| Download: ML20073T193 (11) | |
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Donald A. We!!s vawe,-ouse, t.s me
< 3 '. '2 3 7 M 57 2000 Se Edison m=cond Avenuer ->>-
March 31,1983 EF2-62619 Mr. W.S. Little, Chief Engineering Programs Branch U.S. Nuclear Regulatory Ccmnission Region III Office c
799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Nancmpliance at Enrico Fenni Unit 2 - IE Report 50-341/82-14
Dear Mr. Little:
This letter amends our respanse, dated February 22, 1983, to items of nonempliance described in your IE Report No. 50-341/82-14. 'Ihis inspection of Enrico Fermi Unit 2 construction site activities was performed by Mr. K.R. Naidu and Mr. B.H. Little on September 8, 9 and 10, 1982.
The anended informaticn consists of inclusian of actual dates of cor-rective action taken, furtMr detail and clarification of tM respanse to item #82-14-01A, and correction of a typographical error in the Item 82-14-03 statement of noncmpliance.
We trust this letter satisfactorily answers the concerns raised in ycur report. If you have questions, please cantact Mr. G.M. Trahey, Assistant Director - Project Quality Assurance.
Very truly yours, cc: Mr. Richard DeYoung, Director Office of Inspecticn and Enforcement U.S. Nuclear Regulatory Ccmaission Washingtcn, D.C. 20555 Mr. Bruce Little, Senior Resident Inspector U.S. Nuclear Regulatory Ccmnissica 6450 North Dixie Highway Newport, Michigan 48166 h00 0
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Mr. W.S. Little, Chief - Engineering Programs Branch March 31, 1983 Page Two EF2-62619 l
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T.A. Alessi A. Alexiou J.C. Ard, Jr.
C.R. Eacon W.F. Colbert W.M. Everett W.J. Fahrner D. Ferencz E.P. Griffing C.M. Heidel W.R. Holland 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. Schuerman G.M. Trahey R.A. Vance/L.E. Eix A.E. Wegele Site Document Control NRC Follow-Up Book /NRC File Chron File a
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THE DETROIT EDISON COMPANY PROJECT QUALITY ASSURANCE DRICO FEINI 2 PROJECT Response to NRC Report No. 50-341/82-14 Docket No. 50-341 License No. CPPR-87 Inspection at: Fermi 2 Site, Newport, Michigan Inspection Conducted: September 8 - 10, 1982 Prepared By:
hw B.F. Kaulpila, Icad Elcotridal/ Engineer' i
Construction Quality Assurance Noted By:
b d/a"Jh!O, D. Ferencz, Actf g Supervisor Construction lity Assurance Approved By: 2 M /dsE T.A. Alessi, Director Project Quality Assurance s
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4 Statement of Nonempliance, 82-14-01A 10CFR50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be acccuplished in accordance with these instructions, procedures, or drawings."
The Detroit Edison Quality Assurance Manual, Section 9.0.1, states that "Activi-ties affecting quality shall be prescribed by appropriate written instructions, procedures, or drawings arxl shall be accmplished with these documents."
a.
Paragraph 3.10 of the Daniel Construction Procedure AP-VII-02 states, "At any time during the review and approval of a DDR that information is deter-mined to be inadequate, incorrect, etc., the DDR shall be returned to the person who originally provider 1 this information, for correcticn, and the DDR review / approval cycle shall then be repeated frcn the originator's Quality Manager forward."
Contrary to the above, after it was acknowledged in the response to L.K. Ccostock DDR 1757 that the DDR contained incorrect infomation, the DDR was not returned to the person who provided the information for correctico, and the DDR review /
approval cycle was then not repeated frcm the originator's Quality manager for-ward. Instead, the DDR was voided.
Corrective Action Taken and Results Achieved L.K. Cmstock OC management has been instructed to folicw the process outlined in Daniel Site Administrative Procedure AP-VII-02, Paragraph 3.10, which re-quires that the originator of a Deviation Disposition Request (DDR) be informed when his DDR is considered incorrect. He shall be given the reasons for re-vising tM DDR and also be given a copy of the corrected DDR. In addition, Paragraph 3.11 of AP-VII-02 which covers the voiding of DDR's has been revised i
to require that the writer of a DDR which has been voided receive a copy.
f The cable referenced in DDR No. 1757 has been tested by Startup and found to be satisfactory. The temporary support has been replaced by permanent support AA-069 and has been accepted by L.K. Cmstock (LKC) QC. The practice of pulling cable i
through non DC accepted, empty raceway is no longer approved for DA Level I installations. On septaber 10, 1982 a memo was written by W.J. Fahrner to j
J.C. Ard, Jr. (Daniel) requesting that he direct L.K. Ccustock to assure that "all empty conduit and tray shall have final inspection and OC signoff before pulling cable through the raceway." The memo was followed on September 13, 1982 by Stop Work Notice #42 which prevented the pulling of cable in OA Level I race-ways which had not been inspected and accepted by L.K. Ccustock OC. On Septmber 20, 1982 a second nemo was written by D.G. Hunt (Daniel) to R.C. O'Donnell (LKC)
" clarifying the intent of the Mr. Fahrner memorandum...in regard to DA IcVel I conduit inspection." This memo allows cable to be pulled in Class I raceway if it already contains scme cable, providing that the other DC requirements for i
cable protection are met prior to the pulls. The L.K. Ccustock OA/DC Manual was revised and implenentation was verified prior to the lifting of Stcp Work Notice #42 on Septmber 29, 1982.
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Corrective Action To Be Taken To Avoid Further Noncampliance L.K. Cmstock OA Manual, Sectim 4.3.1, Paragraph 3.4 was revised to include a requirement for DC verification of acceptance of cable tray and wireway supports as part of the inspection for trays.and wireway. Section 4.3.3, Paragraph 3.3 was revised to include a requirement for verifying that DA Ievel I raceway and seismic supports are inspected and accepted prior to cable pulling. It further stipulates that raceway which already contains cable does not require inspection and acceptance of seismic supports prior to cable pulling. Section 4.3.6, Paragraph 3.11 was added to require that conduit supports and pull boxes are accepted by DC before installation of conduit. Section 4.3.7, Paragraph 3.3 was revised to require OC verifica-tion of OA Ievel I conduit supports, cable tray / wireway hangers, and pull boxes by (a) OC weld stamp adjacent to weld indicating acceptability, (b) neasuring size and spacing of anchor bolts, or (c) verifying the weld in-spection checklist as appropriate before determining final acceptance.
The Date When Full Cmpliance Will Be Achieved Full empliance has been achieved with the revision of AP-VII-02 and the L.K. Cmstock OA/OC Manual on Octcber 5,1982. Routine surveillances will be conducted by Construction OA to assure continued empliance with the revised pro dures.
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Statement of Nonecupliance, 82-14-01B b.
Paragraph 3.11 of Daniel Ccmstructicn Procedure AP-VII-02 states in part:
"The originator's Quality Manager shall mark the DDR void, sign and date and attach the void fonn to the DDR and transmit to the Project Quality DDR Coordinator."
Contrary to the above, the LKC Assistant QC Manager, instead of the DC Fanager, who was present cn site, marked the DDR void, and signed and dated the DDR.
Corrective Action Taken and Results Achieved l
L.K. Ccrrstock OA/DC Manual, Section 4.1.3, Paragraph 4.2 has been revised to read as follows:
4.2 " Assistant Quality Control Managers"
" Reports to the OC Manager. Assists the Quality Control Manager in all the duties described in Section 4.1 and has full signature authority of the Ouality Control Manager. Assurres all the duties of the Quality Control Manager in his absence."
Cormctive Action To Be Taken To Avoid Further Nonccrnpliance L.K. Cctrstock OC management has been instructed to void DDRs only as dimcted by Procedure AP-VII-02.
The Date When Full Ccrnpliance Will Be Achieved Full ccripliance was achieved with the revision of L.K. Ccustock OA/DC Manual, Section 4.1.3 on September 28, 1982. Routine surveillances will be ccnducted by Construction OA to assure continued ccupliance with the revised procedure.
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Statement of Nonempliance, 82-14-01C
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Paragraph 4.1.5 of Daniel Constructicn Procedure AP-VII-02 states in part:
"If it is determined that there is no nonconformance, notify the originator to remove the Hold Tag. When the contractor nm ber is used, annotate log."
1 Also, Paragraph 3.4.3 of IEC Procedure 4.11.1 states in part, "Upon closure of the nonconformance doctanent the Hold Tags shall be removed and the Hold Tag Report shall be annotated with the removal date."
4 Contrary to the above, even though DDR 1757, initiated on May 19. 1982,was closed on June 11, 1982, by Irarking it void, Hold Tag 1617 issued to DDR 1757 was still attached to the nonconforming conduit installaticn and the LKC OC Hold Tag Iog indicated that Hold Tag 1617 I m ained open. Furthermore, even though DDR 1897 was initiated on August 19, 1982, a Hold Tag Report was not initiated and main-tained in the log by serial number.
Corrective Action Taken and Results Achieved i
Hold Tag #1617 was removed and the Hold Tag Log was updated to reflect rmoval l
of the tag.
Corrective Action To Be Taken To Avoid Further Nonempliance i
A review of the Hold Tags and Hold Tag Iog was conducted and corrective actions were cmpleted by March 30, 1983.
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The Date hfuen Full Cmpliance Will Be Achieved a
1 A cmplete review and corrections were cmpleted by March 30, 1983. ' Routine surveillances will be conducted by Construction OA to assure continued empli-ance with the approved Hold Tag program.
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i Statenent of Nanccrrpliance, 82-14-02 10CFR50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings...and shall be acccznplished in accordance with these instructions, procedures or drawings."
Paragraph 9.1 of DECO Procedure POA No. 9 states in part, " Instructions, proce-dures and drawings prescribing activities affecting quality shall delineate the nethod and sequence an activity is performed and include appropriate quantita-tive and qualitative acceptance criteria for determining the activity has been satisfactor11y performed."
a.
Contrary to the above, LKC failed to establish qualitative and quantitative acceptance / rejection criteria relative to " adequate supports" for conduits.
Consequently, LKC craftsnon and OC inspectors were unable to deterntine j
whether a conduit was adequately supported, or not, prior to initiating a cable pull.
b.
Contrary to the above, important inspection information ecntained in Meror-andum 7-28-82 dated July 19, 1982, which stated " Class I conduit may not be supported tmporarily for cable installation. Inspection of Class I conduit nust be in accordan with Specification 3071-128 SID.ED," was not documented i
in a procedure and carmmicated to cognizant inspection personnel.
Corrective Action Taken and Results Achieved L.K. Ccrastock's OA/QC Manual, Sections 4.3.3 and 4.3.6 have teen revised for cable pulling and conduit inspection. The qualitative and quantitative accept-ance/ rejection criteria has been anended with reference paragraphs added to the check points. Temporary supports may no longer be used. By rewording the cable pulling procedure (Section 4.3.3) and ccexluit procedures (Section 4.3.6) the.)uality Control Inspectors can allow cable pulling only after the CA Ievel I raceways have been accepted. The exception to this rule is expressed in letter EF2-58409 to the Regional Aininistrator of the NRC, Mr. James G. Keppler, and indicated in Section 4.3.3.
This exception states in part:
"Any deviation frmt
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this will have to be approved by Detroit Edison Field Engineering."
t Corrective Action Taken to Avoid Further Noncmpliance i
See Above.
Date When Full Cm pliance Will Be Achieved Full ccrnpliance was achieved with the revisions of L.K.- Ccrnstock's OA/DC Manual, Sections 4.3.3 and 4.3.6 on November 5, 1982. Routine surveillances will be conducted by Construction OA to assure ccntinued compliance with the revised procedures.
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Staterent of Nonconpliance, 82-14-03 10CFR50, Appendix B, Criterion XV states, " Measures shall be established to control materials, parts or ccxnponents which do not conform to requiremnts in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, docu m ntation, segregation, disposition and notificaticn to the affected organizaticns."
Section 16.1.5 of the DECO Quality Assurance Manual states, " Reports of non-conforming items shall be made on Deviation Dispositicn Request (DDR) forms to project engineering for dispositioning in accordance with Configuration Control Procedures." Paragraph 3.1.1 of LKC OC Procedure No. 4.11.1 states
" Nonconforming level I and Ievel II items shall be identified on a Deviation Disposition Request (DDR) (Attachment I) in accordance with Daniel Procedure AP-VII-02.
Contrary to the above, on September 9,1982, during an inspection in the RHR Building, the inspectors found that LKC OC inspectors were using Field Sur-veillance Correction Reports (FSCRs) instead of DDRs to document nonccnform-ing safety-related electrical conduit and conduit supports, for conditicos such as inadequate spacing of conduit supports and anchor bolts, insufficient number of anchors, and damaged conduit, which were in nonconformance with the DECO Specificaticn and drawings.
Corrective Action Taken and Results Achieved The FSCR's in question were found to have been written to document and control level I and II nonecnformances which could be made to conform to existing Detroit Edison EF2 drawings or specifications.
Administrative Procedure AP-VII-02, Paragraph 3.13 and L.K. Ccrnstock OA/OC Manual Section 4.11.1, Paragraph 3.2.1 were revised as follcws in order to agree with present field practices:
3.13
" Contractors may utilize a system for recording in-process discrepancies that normally would be reported as Category "B" DDR's.
This system shall be in accordance with their QA Program and shall not require a DDR. Additionally, if a nonconforming item can be made to conform to a specification or drawing using approved procedures or practices, a POA-approved method other than a DDR may be used to document and ccn-trol a nonconformance."
3.2.1
" Field Surveillance Correction Reports shall be used to document and control Level I and II nonconformances where items can be made to conform to drawings or specifications using approved procedures or practices. FSCR's can also be used to docunent Level III discrepancies."
Edison OA Manual, Section 16.1.6.4 states:
"Other nonconformances, where an item can be made to conform to specified requirements by ccrnpletion, reasserbl-ings, or other corrective mans, must be documented. The DDR or other approved nothods may be used to document this type of nonconformance."
Corrective Action To Be Taken To Avoid Further Noncanpliance See Above.
The Date When Full Coupliance Will Be Achieved Full cmpliance was achieved with the revisicn of AP-VII-02 and L.K. Constock OA/Oc Manual, section 4.11.1 on October 5,1982. Routine surveillances will be conducted by Construction OA to assure continued canpliance with the re--
vised procedures.
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Statement of Nonempliance, 82-14-04 10GR50, Appendix B, Criterion XVI, states in part, " Measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipnent, and nonecnformances are prcperly identified and corrected."
The Detroit Edison Quality Assurance Manual, Section 17, states in part, i
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"CA, OC and test personnel shall prmptly identify and report ecnditions adverse to quality, such as failures, malfunctions, deficiencies, ncocen-i i
formances, defective material and equipnent, and procedural ncnconformances.
In the event...prcept corrective action is taken..."
Contrary to tha above, though IEC DDR 1864 dTted August 11, 1982, identified a severed cable in a tray, there was no documented indication that corrective l
action was taken to remove the severed cable.
Furthermore, even though LKC Field Engineering requested OC to research and furnish the cable number, this was not done. Instead, the DDR was voided.
l Corrective Action Taken and Results Achieved j
The cut cable in tray OK-307 has been determined to be scrap. This scrapped l
cable was recoved prior to the issuance of the DDR Void / Revision Request Form on August 23, 1982 and the voided DDR has since been annotated by the inspector q
to reflect the scrap removal.
1 Corrective Action Taken to Prevent Further Nonctupliance j
1 A cable tray cleanup program addressed in L.K. Ccestock Procedure 4.3.0 in-cludes instructions for renoving damaged or deformed cable. Also, Constrc-j tion OA has been reviewing DDRs to assure that none have been improperly voided.
1 Date When Full Ccrnpliance Will Be Achieved Full ccepliance was achieved on February 21, 1983. Surveillance of cable tray l
cleanup by L.K. Ccustock and Inview of DDRs by Construction OA will continue j
throughout construction at a frequency necessary to assure continued effective-ness of the corrective actions taken.
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