ML20082F622
| ML20082F622 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/10/1983 |
| From: | Wells D DETROIT EDISON CO. |
| To: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20082F620 | List: |
| References | |
| EF2-65290-REV-1, NUDOCS 8311290170 | |
| Download: ML20082F622 (4) | |
Text
..
e Donald A. Wells f
$2h/II 2000 Second Avenue 31 3
November 10, 1983 EF2-65290, Rev. 1 1
Mr. R.C. Knop, Chief Projects Branch 1 U.S. Nticlear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Amendment to Response on Noncompliance at Enrico Fermi Unit 2 - IE Report 50-341/83-17
Dear Mr. Knop:
This letter amends the previous response to the item of noncompliance described in your IE Report No. 50-341/83-17. This inspection of Enrico Fermi Unit 2 construction site activities was performed by Messrs. P.M.
Byron, M.E. Parker and B.H. Little on July 1 through August 31, 1983.
The item of noncompliance is 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 amended response is arranged to correspond to the sequence of items cited in the body of your report. The number for the item of noncompliance and the applicable criterion is referenced.
We trust this letter satisfactorily answers the concern raised in your report. If you have questions, please contact Mr. G.M. Trahey, Assistant Director - Project Quality Assurance Very truly yours, b[U C
?
DAW /EHN/cp cc:
Mr. Richard DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Paul. Byron, Senior Resident Inspector U.S. Nuclear Regulatory Commission 6450 North Dixie Highway Newport, Michigan 48166 8311290170 831122 HOV 17 PDR ADOCK 05000341 G
PDR J
r THE DETROIT EDISON COMPANY PROJECT QUALITY ASSURANCE ENRICO FERMI 2 PROJECT Amended Response to NRC Report No. 50-341/83-17 Docket No. 50-341 License No. CPPR-87
-Inspected at: Fermi 2 Site, Newport, Michigan Inspection Conducted: July 1 through August 21, 1983 APPROVED BY:
M ss/
T.A. Alessi, Director Project Quality Assurance
////p/f_3 Date:
/
r
Amended Response to NRC Inspection Report No. 50-341/83-17 (83-17-01)
Statement of Noncompliance, 83-17-01 10CFR50, Appendix B, Criterion V states in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings".
DECO Quality Assurance Procedure 9.1.1 states: " Instructions, pro-cedures, or drawings prescribing activities affecting quality shall delineate the method and sequence an activity is performed and include appropriate quantitative or qualitative acceptance criteria for determining the activity has been satisfactorily performed".
Contrary to the above, the inspectors observed on August 12, 1983, work being performed on Emergency Diesel Generator No. 11 voltage regulator with an illegible and unreadable PN 21, Operating or Maintenance Order, and an electrical single line sketch which had no references or description.
This is a Severity Level IV violation.
Corrective Action Taken and Results Achieved Upon notification of this violation, work was stopped and a new temporary modification, #44, was issued to replace temporary modi-fication #12. This modification attached a copy of the reviewed design being installed.
The NRC had a concern with an illegible PN-21 being used by an STE in placing a Temporary Modification. Normally a PN-21 on this site is not the work document, it usually is accompanied by a Punchlist card, Attachment "A",
7.8 etc.
It is normal to have the PN-21 state, ' Implement Temporary Modifi-cation No.
In this case, the STE was using an illegible copy of a PN-21, however, he had written the PN-21 and was therefore aware of the content. Each PN-21 has a specific number which is machine printed and legible on all copies. This allows for traceability back to the tagging center, other locations, and documents (including the Temporary Modification Log).
Corrective Action Taken to Avoid Further Noncompliance A procedure comment control form was issued by the Lead Start-Up Engineer (LSTE) - Electrical, to Nuclear Production requesting a revision to the temporary modification procedure 12.000.25T. This requires that a copy of the reviewed design or sketches be attached to applicable temporary modifications. This will provide an approved reference for installation and design configuration of the temporary modification.
Procedure 12.000.25T was revised on September 6, 1983, to reflect this change. All Start-Up test personnel have received training for this procedural revision.
Efforts will be made to assure that the quality of support documents used in the field are legible enough to satisfy any reviewer's needs.
A memo will be issued to Site Management by the QA organization emphasizing the need for legib12 documents. In addition, Startup Instructicn 4.7,0,01, PN-21 Flow Sequence was revised to include a statement that all copies must be legible.
The Date When Full Compliance Will Be Achieved Full compliance was achieved with the issue of revision eleven (11) of Start-Up Instruction 4.7.0.01.
This was issued on November 4,1983.
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