ML20079N688
| ML20079N688 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/23/1984 |
| From: | Wells D DETROIT EDISON CO. |
| To: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| EF2-66492, NUDOCS 8401300301 | |
| Download: ML20079N688 (6) | |
Text
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OmB Donald A. Wells Manager cuainy Assurance (313) 237 965/
l b? me :m (313) 227-mW
. N uary 23, 1984 EF2-66492 Mr. R.C. Knop, Chief Projects Branch 1 U.S. Nuclear Regulatory Cm mission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Subject'. Noncmpliance at Enrico Felmi Unit 2 - IE Report 50-341/
83-29
Dear Mr. Knop:
This letter responds to the itms of nonempliance described in your IE Repcrt No. 50-341/83-29. This inspection of the Enrico Fermi Unit 2 construction site activities was performed by Messrs.
P.M. Byron and M.E. Parker on October 1 through Nov mber 30, 1983.
The itms of noncmpliance 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 to correspond to the sequence of items cited in the body of your report. 'Phe number for the itms of noncmpliance and the applicable criterion is referenced.
We trust this letter satisfactorily answers the concerns raised in your report. If you have questions, please contact Mr. G.M. Trahey, Assistant Director - Project Quality Assurance.
Very truly yours,
?
g V
DAW /EHN/pn cc: Mr. Richard DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Cmmission Washington, D.C.
20555 Mr. Paul Byron, Senior Resident Inspector U.S. Nuclear Regulatory Ca mission 6450 North Dixie Highway Newport, Michigan 48166 8401300301 840123 PDR ADOCK 05000341 JAN 2 61984 G
PDR ZEM \\ )
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Mr. R.C. Knop, Chief January 23, 1984 EF2-66492 Page 2 bec:
F.E. Agosti
-T.A. Alessi L.P.-Bregni O.K.' Earle W.J. Fahrner/S.H. Noetzel M. Gavin A. Godoshian W. Hastings C.M. Heidel W.R. Holland
-Institute of Nuclear Power Operations (INPO)
. W.H. Jens/E.P. Griffing R.S.-Lenart-P.A. Marquardt/ Docket File (2)
.J. Piana G.M. Trahey
' Approval Control NRC Follow-Up Book /NRC File Chron File i
i THE DETROIT EDISON COMPANY PROJECT QUALITY ASSURANCE ENRICO FEE 01I 2 PROJECT
-Response to NRC Report No. 50-341/83-29 Docket No. 50-341 License No. CPPR-87 Inspection at: Fermi 2 Site, Newport, Michigan Inspection Conducted: October 1 through November 30, 1983 Approved by:
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T.n.Alessi,Directp Project Quality Assttrance
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Response to NRC Inspection Report No. 50-341/83-29 (83-29-01)
Statement of Nonecunpliance, 83-29-01 10CER50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by dtvm-nted instructions, procedures... and shall be acccrnplished in accordance with these instructions, procedures, or drawings".
Operational Quality Assurance Manual, Program Policy 5, Revision 0, Section 2.2, states, " Organizations responsible for the specifica-tion or performance of activities affecting quality shall provide documents that prescribe the activities and meet the requirements of this Program Policy".
Contrary to the above, the Nuclear Administration Information Sys-tems group had been using a procedure, POM 12.000.40, since April, 1983, which was not made active until October 7,1983. In additian, the licensee listed this procedure as a corrective action measure to a nonccupliance and stated that full ccrepliance would be achieved by September 1, 1983.
This is a Severity Ievel V violation (Supplement II).
Corrective Action Taken and Results Achieved The status of Plant Operating Manual (POM) 12.000.40, " Management of Controlled Documents", was listed in the PCM Index (PO4I) as inactive due to error. The status of this procedure was corrected, as the inspector noted on October 7, 1983.
Corrective Action Taken to Avoid Further Nonccrnpliance Nuclear Operations' Interfacing Procedure (NOIP) 11.000.02,
" Updating Part V of the COM Index", has been written and includes controls which should assure that listed information is correct.
Date when Full Ccrnpliance will be AchievM NOIP 11.000.02 will be issued by February 6, 1984'
Response to NRC Inspection Report No. 50-341/83-29 (83-29-02)
Statement of Nonccxnpliance, 83-29-02 10CFR50, Appendix B, Criterion XIII, states in part, " Measures slall be ertablished to control the handling, storage, shipping, cleaning and preservation of material and equignent in accordance with work and inspection instructions to prevent damage or deterioration".
The licensee'.s OA Manual states that their program ccznplies with the intent of Regulatory Guide 1.38 which endorses ANSI N45.2.2-1972.
Contrary to the above, the inspectors observed the following discre-pancies in the storage and handling of safety-related materials:
r.
Section 5.4 of ANSI N45.2.2 requires material DC inspection per-sonnel to designate all material inspected as either " Accept-able" or " Unacceptable" and to tag the material. Damaged Uni-strut was observed in a OA-1 outdoor storage area without OC taga on October 3 and 24, 1983.
b.
Section 6.1.2 of ANSI N45.2.2 requires areas to be marked and designated for storage. Several storage areas were observed which were not designated, c.
Section 6.1.2 of ANSI N45.2.2 requires storage areas to be well drained. Several outside storage areas were observed which were not well drained and contained wet spots, d.
Section 6.1.2 of ANSI N45.2.2 requires material to be stored on cribbing or equivalent. Several storage areas were observed in which OA Level 1 material was laying on the ground.
This is a Severity level IV violation (Supplement II).
Corrective Action Taken and Results Achieved a.
Section 5.4 of ANSI N45.2.2 requires material 0.C. inspection personnel to designate all material inspected as either " Accept-able" or " Unacceptable" and to tag the material. The da: raged unistrut observed in the OA-1 outdoor storage areas has been scrapped.
b.
Section 6.1.2 of ANSI N45.2.2 requires areas to be marked and designated for storage. At the time of this tour, the plant was in the process of eliminating satellite storage areas and con-solidating material to a central area under the control of the warehouse. The renaining satellite storage areas are ncw marked and roped off as to the OA storage level or type of storage.
c.
Section 6.1.2 of ANSI N45.2.2 requires storage areas to be well drained. French drains were installed in several storage areas.
One storage area was elevated with additional rock material.
All storage areas were inspected to insure that in case of heavy rains that all material was on dunnage and out of standing water. [
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Response to NRC Inspection Report 50-341/83-29 (83-29-02)
- Corrective Action Taken and Results Achieved (cont'd) d.
Section 6.1.2 of ANSI N45.2.2 requires material to be stored on cribbing or equivalent. All storage areas have been inspected and all material have been placed on dunnage.
Corrective Action Taken to Avoid Further Noncorpliance To avoid noncompliances similar to the examples cited, each external storage area is inspected at least every other day by Detroit Edison and by the responsible contractor.
On a broader basis, PPM Procedure 7.27 " Project Housekeeping" is being revised to be more specific in housekeeping inspection requirements. PPM Procedure 7.38 " Storage and Handling of Materials" is being revised to better identify the status of material in temporary storage.
Date when Full Compliance will be Achieved The external storage area inspection activity is in place. The pro-cedure revisions will be issued by January 31, 1984.
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