ML20073T201
| ML20073T201 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 02/22/1983 |
| From: | Wells D DETROIT EDISON CO. |
| To: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20073T185 | List: |
| References | |
| EF2-62617, NUDOCS 8305100399 | |
| Download: ML20073T201 (10) | |
Text
Donald A. Wells v ra:- omy Ar r:e yg m>wm Ecison !EE55" February 22, 1983 EP2-62617 Mr. W.S. Little, Chief Engineering Programs Branch U.S. Nuclear Regulatory Ccanission Region III Office 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Ncncmpliance at Enrico Fermi Unit 2 - IE Report 50-341/82-14
Dear Mr. Little:
This letter responds to the items of nonecapliance described in your IE Report No. 50-341/82-14. This inspection of Enrico Fermi Unit 2 construc-tion site activities was performed by Mr. K. R. Naidu and Mr. B.H. Little on September 8, 9, and 10, 1982.
The items of nonemplian are discussed in this reply as required by Section 2.201 of the NRC's " Rules of Practi ", Part 2, Title 10, Ccde of Fev ral Regulations.
The enclosed respanse is arranged to correspond to the sequence of items cited in the body of your report. The number for the items of nonecupliance are referenced as well as the applicable criterion.
We trust this letter satisfactorily answers the concerns raised in your report. If you have qmstions, please contact Mr. G.M. Trahey, Assistant Director - Project Quality Assurance.
Very truly yours,
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DAW /DF/cp cc: Mr. Richard DeYoung, Director Office of InsInction and Enfor nent U.S. Nuclear Regulatory Ccmnission Washington, D.C. 20555 Mr. Bru Little, Senior Resident Inspector U.S. Nuclear Regulatory Ccmniscion 6450 North Dixie Highway Newport, Michigan 48166 Sh[0 2 23 G
Mr. W.S. Little, Chief - Engineering Programs Branch February 22, 1983 Page 'No EF2-62617 bec:
T.A. Alessi A. Alexiou J.C. Ard, Jr.
C.R. Bacon W.F. Colbert W.M. Everett W.J. Fahrner D. Ferencz i
E.P. Griffing C.M. Heidel W.R. Holland W.H. Jens E. Lusis P.A. Marquanit/ Docket File (2)
E.H. Newtcr1 4
S.H. Noetzel I
J.W. Nunley J.D. Ryan L.E. Schuerman G.M. Trahey R.A. Vance/L.E. Eix A.E. Wegele Site Docunent Control NRC Follow-Up Book /NRC File Chron File J
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THE DEIROIT EIDSON ONPANY PRCATECT QUALITY ASSURANCE DRICO FERMI 2 PRCATECT i
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: Septenber 8 - 10, 1982.
I Prepared By:
C B.F. Kauppila, lead Electrical Engineer Construction Quality Assurance Noted By:
d D. Ferencz, g Supervisor Ccnstructio ' ' lity Assurance Approved By:
T.A. Alessi, Director Project Quality Assurance l
Statement of Nonempliance, 82-14--01A 10CFR50, Apperdix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documnted instructions, procedures, or drawings...and shall be acccmplished 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 and shall be accmplished with these documnts."
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Paragraph 3.10 of the Daniel Construction Procedure AP-VII-02 states, "At any time during the review and approval of a DDR that informtion is deter-mined to be inadequate, incorrect, etc., the DDR shall be returned to the person who originally provided this information, for correction, ard the DDR review / approval cycle shall then be repeated frcm the originator's Quality Manager forward."
Contrary to the above, after it was acknowledged in the response to L.K.
Ccxnstock DDR 1757 that the DDR contained incorrect information, the DDR was not returned to the person who provided the information for correction, and the DDR review / approval cycle was then not repeated frcm the originator's Quality Manager forward. Instead, the DDR was voided.
Corrective Action Taken and Results Achieved L.K. Ccxrstock Deviation Disposition Request (DDR) #1757 was issued on May 19, 1982.
During the processing of the DDR, it was determined that a nonconformance did not exist. A temporary conduit support was considered to be adequate to allow cable to be pulled.
L.K. Ccrnstock Work Instruction WI 000-03-008 Paragraph 3.1.1 estab-lished the conditions that had to be m t prior to cable pulling. DDR #1757 was voided per Paragraph 3.11 of the Daniel Site Administrative Procedure AP-VII-02 on June 11, 1982. At the tim of voiding Paragraph 3.11 read as follows:
3.11 "If, during the processing of a DDR, it is determined that no noncon-formance actually existed, the person making this determination shall notify the originator's Quality Manager, who shall consult with the appropriate Contractor Project Engineer, and other appropriate Engimer for agreement that no nonconfctmance exists."
"If agreemnt is reached, a DDR void form (referen Exhibit E), shall be initiated with the required approval signatures. The originator's Quality Manager shall mark the DDR void, sign and date, and attach
1 It did not require that the person who wrote the DDR being voided be notified.
Since that tine, Paragraph 3.11 has been revised to require "The originator's Quali.ty Manager to provide the initiator of the voided DDR a copy of the void font., when the initiator is available.
Subsequent to this letter, L.K. Ccrnstock OA/DC Manual, Section 4.3.3 and Work Instruction WI 000-03-008 were revised to include this regairement.
Corrective Action To Be Taken To Avoid Further Nonccmpliance See Above.
The Date When Full Cmpliance Will Be Achieved Full cmpliance has been achieved with the revision of AP-VII-02.
Statenent of Nonccupliance, 82-14-01B b.
Paragraph 3.11 of Daniel Construction Procedure AP-VII-02 states in part:
"the originator's Quality Manager shall mark the DDR void, sign and date and attach the void form to the DDR and transmit to the Project Quality DDR Coordinator."
Contrary to the above, the LKC Assistant OC Manager, instead of the DC Manager, who was present on site, marked the DDR void, and signed and dated the DDR."
Corrective Action Taken and Results Achieved L.K. Ccmstock OA/0C Manual, Section 4.1.3, Paragraph # 4.2 has been revised to read as follows:
4.2 Assistant Quality Control Manager's
" Reports to the OC Manager. Assists the Quality Control Manager in all th2 duties described in Section 4.1 and has full signature authority of the Quality Control Manager. Assumes all the duties of the Quality control Manager in his absence."
Corrective Action To Be Taken To Avoid Further Noncaipliance L.K. Ccustock OC management has been instructed to void DDRs only as directed by Procedure AP-VII-02.
Tle Date When Full Ccupliance Will Be Achieved Full ccupliance has been achieved with the revision of L.K. Ccestock QA/DC Manual, 1
Section 4.1.3.
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_Statenent of Nonempliance, 82-14-01C c.
Paragraph 4.1.5 of Daniel Construction 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 number is used, annotate log."
Also, Paragraph 3.4.3 of MC Procedure 4.11.1 states in part, "Upon closure of the nonconformance document the Hold Tags shall be removed and the Hold i
Tag Report shall be annotated with the removal date."
" Contrary to the above, even though DDR 1757, initiated on May 19, 1982, was closed on June 11, 1982, by marking it void, Hold Tag 1617 issued to DDR 1757 was still attached to the nonconforming conduit installaticn and-the EC OC Hold Tag Log indicated that Hold Tag 1617 remained open. Further-nore, even though DDR 1879 was initiated on August 19, 1982, a Hold Tag report was not initiated and maintained in the log by serial number."
Corrective Action Taken and Results Achieved T
Hold Tag #1617 was removed and the Hold Tag Log was updated to reflect renoval of the Tag.
Corrective Action to be Taken to Avoid Further Nonempliance A review of the Hold Tags and Hold Tag Iog is beir5g conducted to correct any I
other similar discrepancies.
The Date When Full Cmplian Will Be Achieved A cmplete review and correction of any other discrepancies is expected by March 15, 1983.
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Statement of Nonempliance, 82-14-02 10CFR50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings...ard shall be acccmplished in accordance with these instructions, procedures or drawings."
Paragraph 9.1 of DECO Procedure PDA No. 9 states in part, " Instructions, proce-dures and drawings prescribing activities affecting quality shall delineate the method and sequence an activity is performed and include appropriate quantita-tive and qualitative acceptance criteria for determining the activity has been l
satisfactorily perforned."
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Contrary to the above, IRC failed to establish qualitative and quantitative acceptance / rejection criteria relative to " adequate supports" for conduits.
Consequently, IRC craftsnen and OC inspectors were unable to determine whether a conduit was adequately supported, or not, prior to initiating a cable pull.
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Contrary to the above, inportant inspection information contained in Memor-I andum 7-28-82 dated July 19, 1982, which stated " Class I conduit may not be
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supported tenporarily for cable installation. Inspection of Class I conduit l
must be in accordance with Specification 3071-128 SID.ED," was not docunented in a procedure and ccrmunicated to cognizant inspection personnel.
Corrective Action Taken and Results Achieved L.K-Ccurstock's OA/0C Manual, Sections 4.3.3 and 4.3.6 have been revised for cable pulling and conduit inspection. The qualitative arrl quantitative accept-ance/ rejection criteria has been annended with reference paragraphs added to the check points. Tenporary supports may no longer be used. By rewording tre cable pulling procedure (Section 4.3.3) and conduit procedure (Section 4.3.6) the Quality Control Inspectors can allow cable pulling only after the OA Ievel I raceways have l
been accepted. The exception to this rule is expressed in letter EF2-58409 to j
the Regional Administrator of the NRC, Mr. James G. Keppler, and indicated in i
Section 4.3.3.
This exception states in part: "any deviation frca this will have I
to in approved by Detroit Edison Field Engineering."
Corrective Action Taken to Avoid Further Nonccmpliance See Above.
Date When Full Ccupliance Will Pe Achieved Full ccmpliance was achieved with the revisions of L.K. Ccustock's OA/0C Manual, 1
Sections 4.3.3 and 4.3.6.
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Statenent of Nonccmpliance, 82-14-03 10CFR50, Appendix B, Criterion XV states, " Measures shall be established to control materials, parts or ccmponents which do not confom to requirements 1
in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, docunentation, segregation, disposition and notification to the affected organizations."
i Section 16.1.5 of the DECO Quality Assurance Manual states, " Reports of non-j confoming items shall be made on Deviation Dispositicn Request (DDR) forms to project engineering for dispositioning in accordance with Configuration Control q
j Procedures." Paragraph 3.1.1 of LKC OC inspectors were using Field Surveil-j lance Corre: tion Reports (FSGs) instead of DDRs to doctment ncmccnforming 4
safety-relaced electrical conduit and conduit supports, for conditicns such as i
inadequate spacing of conduit supports and anchor bolts, insufficient number of anchors, and damaged conduit, which were in nonconformance with the DECO i
Specification 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 nonconformances 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. Ccastock OA/DC t
Manual Section 4.11.1, Paragraph 3.2.1 were revised as follows in order to agree with present field practices:
l 3.13 " Contractors may utilize a system for recording in process discrepancies
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that normally would be reported as Category "B" DDR's. This system shall j
be in accordance with their DA Program and shall not require a DDR. Addi-tionally, if a nonconforming item can be made to conform to a specification I
or drawing using approved procedures or practices, a PGA-approved method other than a DER may be used to document and ccntrol a nonconformance."
4 3.2.1 " Field Surveillance Correcticn Reports shall be used to document and control level I and II non-conformances where items can be made to conform to drawings or specifications using approved procedures or a
practices. FSCR's can also be used to document Ievel III discrepancies."
j Edison OA Manual, Section 16.1.6.4 states: "other nonconformances, where an i
item can be made to conform to specified requirenents by completion, reassembl-ing, or other corrective neans, must be docunented. The DDR or other approved i
methods may be used to document this type of nonconformance."
Corrective Acticn To Be Taken To Avoid Further Nonccmpliance see Above.
i The Date When Full Ccmpliance Will Be Achieved Full ccmpliance was achieved with the revision of AP-VII-02 and L.K. Ccustock OA/DC Manual, Secticn 4.11.1.
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Statenent of Nonecmpliance, 82-14-04 10CFR50, Appendix B, Criterion XVI, states in part, " Measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, devjations, defective material and equipent, and nonconformances are properly identified and corrected."
The Detroit Edison Quality Assurance Manual, Secticn 17, states, in part, "OA, QC and Test Personnel shall prcrnptly identify and report conditions adverse to quality, such as failures, malfunctions, deficiencies, noncon-formances, defective material and equipent, and procedural nonconformances.
In the event...prcrnpt corrective action is taken..."
Contrary to the above, though LKC DDR 1864 dated August 11, 1982, identified a severed cable in a tray, there was no docunented indication that corrective 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 dcne. Instead, the DDR was voided.
Corrective Action Taken and Results Achieved The cut cable in tray OK-307 has been determined to be scrap. This scrapped cable was removed 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 to reflect the scrap renoval.
Corrective Action Taken to Prevent Further Nonccmpliance A cable tray cleanup program addressed in L.K. Ccunstock procedure 4.3.0 in-cludes instructions for removing damaged or deformed cable. Also, Construc-tion OA has been reviewing DDRs to assure that none have been improperly voided.
Date Een Full Ccmpliance Will Be Achieved Full ccupliance has been achieved. Cable tray cleanup and review of DDRs by Construction OA will ccntinue throughout construction as deemed apprcpriate.
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