ML20086T169

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Responds to NRC Re Noncompliance Noted in IE Insp Rept 50-341/83-29.Corrective Actions:Plant Operation Manual 12.000 Revised,Damaged Unistrut Scrapped & Satellite Storage Areas Marked & Roped Off
ML20086T169
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 01/23/1984
From: Alessi T, Wells D
DETROIT EDISON CO.
To: Knop R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20086T151 List:
References
EF2-66492, NUDOCS 8403060177
Download: ML20086T169 (5)


Text

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Donald A. Webs upaq." ca:M/ Av.s vce n1h 237 Mb7 2000 Second Avenue 31 3-January 23, 1984 EF2-66492 Mr. R.C. Knop, Chief Projects Branch 1 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Nonempliance at Enrico Fermi Unit 2 - IE Report 50-341/

83-29

Dear Mr. Knop:

This letter responds to the itms of nonempliance described in your IE Report 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 Noverrber 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 itms cited in the body of your report. The number for the itms of nonccmpliance 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, l

ts k

DAW /EHN/pn cc: Mr. Richard DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Ca mission Washington, D.C. 20555 Mr. Paul Byron, Senior Resident Inspector U.S. Nuclear Regulatory Cm mission 6450 North Dixie Highway Newport, Michigan 48166 9403060177 840301 PDR ADOCK 05000341 8 PDR _

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THE DEIROIT EDISON COMPANY PROJECT QUALITY ASSURANCE ENRICO FERMI 2 PROJECT Response to NRC Report No. 50-341/83-29 Docket No. 50 ~41 License No. CPPR-87 Inspection at: Fermi 2 Site, Newport, Michigan Inspection Conducted: . October 1 through Novenber 30, 1983 Approved by: * -

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T.A.Alessi,Dirptor Project Quality Assurance Date: / b

Response to NRC Inspection Report No. 50-341/83-29 (83-29-01)

Statement of Nonempliance, 83-29-01, Criterion V 10CFR50, Appendix B, L iterion V, states in part, " Activities affecting quality shall be prescribed by &vmmnted instructions, procedures ... and shall be accmplished 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 reg 2irements of this Program Policy".

Contrary to the above, the Nuclear Administration Information Sys-tems group had been using a procedure, P m 12.000.40, since April, 1983, which was not made active until October 7, 1983. In addition, the licensee listed this procedure as a corrective action measure to a noncompliance and stated that full empliance would be achieved by Septaber 1, 1983.

This is a Severity Level V violation (Supplement II) .

Corrective Action Taken and Results Achieved

- The status of Plant Operating Manual (PCM) 12.000.40, "Mmagement of Controlled Documents", was listed in the PCM Index (POMI) 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 Noncmpliance Nuclear Operations' Interfacing Procedure (NOIP) 11.000.02,

" Updating Part V of the PCM Index", has been written and includes controls which should assure that listed information is correct.

Date When Full Cmpliance will be Achieved NOIP 11.000.02 will be issued by February 6, 1984.

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t Response to NRC Inspection Report No. 50-341/83-29 (83-29-02)

Statement of Nonempliance, 83-29-02, Criterion XII_I_

10CFR50, Appendix B, Criterion XIII, states in part, " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipnent in accordance with work and inspection instructions to prevent damage or deterioration".

The licensee's OA Manual states that their program explies 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:

a. Section 5.4 of ANSI N45.2.2 requires material OC inspection per-sonnel to designate all material inspected aa either " Accept-able" or " Unacceptable" and to tag the material. Damaged Uni-strut was observed in a OA-1 outdoor storage area without DC tags 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 stor&ge areas were observed in which OA Ievel 1 material was laying on the ground.

This is a Severity Ievel IV violation (Supplcment II) .

Corrective Action Taken and Results Achieved

a. Section 5.4 of ANSI N45.2.2 requires material 0.C. inspection personnd to designate all material inspected as either " Accept-able" or " Unacceptable" and to tag the material. The damaged 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 rcn.aining satellite storage areas are now 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 Lains that all material was on dunnage and out of standing water.

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Response to NRC Inspection Recort 50-341/03-29 (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 inve been inspected and all material have been placed on dunnage.

Corrective Action Taken to Avoid Further Nonempliance 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 responsib'.e contractor.

On a broader basis, PPA Procedure 7.27 " Project Housekeeping" is being revised to be more specific in housekeeping inspection i- requirements. PPM Prt.cedure 7.38 " Storage and Handling of Materials" is being reviset to better identify the status of material in temporary storage.

. Date When Full Cmpliance 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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