ML20080S719

Responds to NRC Re Violations Noted in IE Insp Rept 50-341/83-28.Corrective Actions:Testing Terminated & Test Exception Disposition Rept 29 Initiated,Deferring Testing of Applicable Procedure Until Air Line Reconnected

ML20080S719
Person / Time
Site:	Fermi
Issue date:	02/17/1984
From:	Jens W DETROIT EDISON CO.
To:	Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20080S703	List: ML20080S719
References
EF2-67127, NUDOCS 8402290228
Download: ML20080S719 (7)

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7 Coyne H. Jens Ves President Nuclear Operations '

2000 Second Avenue Edison m'ar*~

Febniary 17, 1984 EF2-67127 Mr. J.G. Streeter, Chief Engineering - Branch 1 U.S. Nuclear Regulatory Ccrmission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

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Subject:

- Noncmpliance at Enrico Fermi Unit 2 - Inspection Report 50-341/83-28 This letter responds to the items of nonempliance described in your Inspection Report No. 50-341/83-28. This inspection of the Enrico Fermi Unit 2 construction site activities was perfonmd by Mr. S.G.

DuPont on November 28, 1983 through January 5, 1984.

The items of nonempliance 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 re p rt. The number for the items of noncmpliance'and the applicable criterion is referenced.

We trust this letter satisfactorily answers the concerns raised in your report. If you have any questions, please contact Mr. Lewis Bregni, (313) 586-5083.

. Sincerely, cc: -ME. P.M. Byron' s / yu too Mr. R. DeYoung Mr. J.E. Konklin l

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j TIE DEIROIT EDISON CCHPANY ENRICO FERMI AENIC POWER PIAVf, UNIT 2 NUCLEAR OPERATIONS DEPAR'IMENT

~ Response to NRC Report No. ' 50-341/83-28

. Docket No. 50-341 License No. CPPR-87 Inspection at: Enrico Fermi 2, Newport, Michigan Inspection Conducted: November 28, 1983 through January 5, 1984 I

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Response to NRC Inspection Report No. 50-341/83-28 Statenent of Nonempliance, 83-28-03, Criterion V 10CER50, Appenctix E, Criterion V, as impimented by DECO Quality Assurance Manual, Section 9.0.1,_ requires that activities affecting quality be. prescribed by appropriate written instructions and pro-cedures.

Contrary to the above, preoperational procedure B3100.001, " Reactor Recirculation System", was not appropriate in that it did not pro-vide for the verification of the operability of controlling air as a pterequisite or initial test condition.

Corrective Action Taken and Results Achieved Upon finding that the applicable section of PRET.B3100.001 could not be empleted, action was taken innediately to terminate testing and Test Exception Disposition Report (TEDR) #29 was initiated. TEDR

1. 29 defers testing of applicable procedure steps until the air line is reconnected. In addition, an investigation was carrrrenced to determine why the air supply line was disconnected. The investiga-tion revealed the following:

One and one-half days prior to the actual test the Startup Test

- Engineer (STE) had verified the system configuration for performance of the scheduled test. . Subsequent to his walkdown and prior to his attspted test, a hydro (T48-02-20) was released for performance.

The prerequisites for this hydro required that certain affected pneumatic lines in the drywell be disconnected and capped. One of the lines which was capped was the supply to valve B31-F019. As a consequence, attempting to stroke this valve as required per PRET.B3100.001 resulted in failure.

Corrective Action Taken to Avoid Further Noncmpliance Preoperational Test Procedure B3100.001 did not include a prerequi-site or initial condition to verify the applicable pneumatic sup-plies. As a result, Test Change Notice (TCN]506) has been issued against PRET.B3100.001, Revision 1, to verify that_the pneumatic supplies to the air operated valves within the B3100 system are available.

The larger area of concern artning frcs this nonempliance, however, is a lack of control of Tbst coundaries. Tb address this issue, the following is being or has been done:

1. Staff meetings were held with the Lead Startup Test Engi-neers (LSTEs) to discuss the areas of concern. The need to maintain awareness of systs test boundaries, the need for cross-ccxmunication between the various STEs, and tina need for improved awareness and timeliness of the verifica-tion of test peerequisites and initial conditions was L

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' Response to NRC Inspection Report No. 50-341/83-28

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- Corrective Action Taken to' Avoid Further Noncmpliance (cont'd) stressed. ' Reviewers of test procedures were cautioned to look for items such as the one mentioned when reviewing procedures or Test Change Notices (TCNs) . The recent issu-ance of Startup necrandum SU-84-0213, " Coordination and

- Control Over Work in the Plant", also ernphasized these .

aspects.

2. The Joint Test Group (JIU) was formad in NWr,1983.

The chairman of the JIU is the Assistant Superintendent. -

Nuclear Production and the Assistant Chairman is the a Startup Director..- One of primary tas).s of the JIU is to coordinate testing.to ensure that system test boundaries are maintained.. The JIU meets in the morning of every work day to discuss the day's activities. -To support its role, the JIU has shift engineers' assigned to coordinate and

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monitor testing and related activities. It should be noted

'these engineers are in addition to the STEs and are on shift when testing is being performed.

Date When Full Cmpliance Hill be Achieved TCN'lS06 has been approved and full ccrpliance has- been achieved.

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Response to NRC Inspection Report No. 50-341/83-28 Statement of Nonempliance, 83-28-04, Criterion XVI 10CFR50, Appendix B, Criterion XVI, as implenented by DECO Quality Assurance Manual, Section 17.1.3, requires that measures be estab-lished to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equignent, and nonconformances are pro.ptly identified, cor-rected, and that the measures assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, the licensee's corrective measures failed to preclude repetition of intrusion of foreign material into a OA Level 1 piping system, as evidenced by the licensee's discovery of foreign material in the RHR Test Return Line after the system had been inspected and closed.

Corrective Action TLken and Results Achieved The foreign material (weld blanket) was removed from the RHR Test Return Line. Before the torus was flooded, two inspections were conducted as required:

1. An inspection tour was conducted by Metalwald (the coatings contractor), Project Quality Assurance (PDA) and the Nuclear Shift Supervisor. This inspection was done in order to sign off the PN-21 (coating work order) .

2. An inspection tour was conducted by Startup prior to flood-ing of the torus in accordance with procedure CAIO.000.008, Revision 6, " Generic Checkout and Initial Operations Test Procedure Flushing and Cleaning of Mechanical Systems",

Section 8.4.

No abnormal foreign material was discovered in these inspections.

On January 4, 1984, Construction Quality Assurance was made aware of the welding blanket having been found in the RHR Test Return Line.

Due to the existing 10CFR50.55(e) (#101) against debris in piping systems, Construction Quality Assurance notified NRC Region III.

Startup then initiated Nonconformance Report (NCR) 84-0005 to docu-ment the condition and Construction Quality Assurance initiated Quality Surveillance Report 84-002 to address the overall events associated with the NCR.

Corrective Action Taken to Avoid Further Ncncmpliance The RHR Test Return Line is an open ended pipe in the torus of the Mark I Containment. It is anticipated that the required close out inspections as documented above would hue led to discovery of the welding blanket 9 is their purpose. Notwithstanding, it has been recognized previously that there is a need to strengthen management controls over housekeeping, cleanliness, and control of foreign materials in the vicinity of open systems. To address this, the

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Response to NRC Inspection Report No. 50-341/83-28 Corrective Action Taken to Avoid Further Noncmpliance (cont'd) following specific and general actions are or have been taken:

In Specific:

1. Construction Quality Assurance (COA) initiated Quality Sur- '

veillance Report 84-002 to investigate the-incident as stated.- The findings-indicated that there were same minor deficiencies in the Wismer and Becker (one of the tuo pri-mary contractors in the torus at the time) QC program for maintaining systs cleanliness. As.a consequence, Wismer

-and Becker has initiated on the job training to understand proper use of the OA Level'1 Closure Checklist (W&B Form EF 285), and have modified the form to account for multiple

. openings in systems.

-2. The Systems Ccmpletion Organization (SCO) issued SCO Proce-

- dure-10.3 " Access.and Work Control in the Torus" to speci-fically control cleanliness of the torus and attached pip-ing. This procedure provides controls to monitor materials brought into the torus. An access-log is maintained, which as a minimum, provides a description of material and its time in and out of the torus.

In General:

3. On October 25, 1983, menorandum F2S83-8239 was issued to provide explicit instructions for maintaining cleanliness of DA 1 piping systems.- The memorandum provided directions for ensuring:

a. Acce.3s to DA Level 1 systems in high traffic areas is limited.

b. Visual inspections.for foreign material are made when systems are opened, .with appropriate notifications made if materials are found,

c. No tools or materials-have loose parts which can became detached, and that all tools and temporary materials

.have been removed frm the system.

d. Visual verification of syst s cleanliness by QC prior to closure.

e. . Responsible craft personnel or security are present while a system is open or a solid, sealed, securely fastened protective cover is provided to prevent undetected access to'the systs.

It was in response to this nemorandum that Wismer and

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Response to NRC Inspection Report No. 50-141/83-28

- Corrective Action Taken to Avoid Further Noncompliance (cont'd)

Becker had fontulated the Closure Checklist mentioned. All-

_ other applicable site organizations are or have implemented similar controls. For example, Nuclear Production has

~ implemented a tmporary change to Procedure 12.000.48 to ensure foreicrn reaterial doesn't enter DA Ievel 1 systems during construction or maintenance periods. The Sp tes Ccupletion Organization has issued procedure 13.1, "Sur-

. veillance Coordination". This procedure requires Project Ccupletion Organization -(PCO)' inspectors to perform a daily

.walkdown in their designated areas. The inspectors are-required to cmplete a checklist to hwnt their find-ings. (The checklist includes an inspection for end pro-tection on piping, tubing and conchit.) In accordance with the procedure deficiencies are reported to the responsible

,, contractor and POO management for corrective action. Con-trols are also in place to monitor progress to closecut deficient items.

Detroit Edison' believes that the above actions will provide a signi-ficant improvment in controlling future system cleanliness. ' It should be recognized that see of the actions referenced were in process during the time period the noncmpliance was identified.

-The implementation of the actions mentioned should help to preclude

-similar occurrences._ It should also be notea that the generic issue of foreign debris in existing systems is being addressed in response

to 10CFR50.55(e) No.101. Further actions related to past system housekeeping and cleanliness may be required as necessary in response to that deficiency.

9 Date When Full Compliance Will be Achieved Full cmpliance will be-achieved by February 24, 1984.

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