ML20087P712

Deficiency Rept,Item 117 Re Commercial Grade Matl in QA safety-related Applications.Initially Reported on 840215. Approx 2,300 Purchase Requisitions Identified.Purchase Documentation Reviewed & Historical Profile Created

ML20087P712
Person / Time
Site:	Fermi
Issue date:	03/27/1984
From:	Jens W DETROIT EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
117, EF2-66730, NUDOCS 8404090300
Download: ML20087P712 (3)

Text

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N lear p tions Detroit ~

20M Sumd Avenue f3NIs%N0an 4822s March 27, 1984 EF2-66730 Mr. James G.

Keppler Regional Administrator U.S.

Nuclear Regulatory. Commission Region III 799 Roosevelt Road Glen Ellyn,' Illinois 60137

Reference:

Fermi 2 NRC Docket No. 50-341

Subject:

Report of 10CFR50.55(e) Item on Commercial Grade Material in QA I Applications ( # 117-)

On February 15, 1984, Detroit Edison's Mr.

W., R.

Wingfield - Construction Quality Assurance telephoned Mr.sF.-C.

Hawkins of NRC Region III to' report a, potential deficiency concerning' the use of.commercia,1 grade material at Fermi 2.

The potential deficiency;xeported involves the use of commercial grade material for' safety-related applications ("CQ"' material) where evaluEtion of the mate-rials for.this application'is-not adequately documented.

This potential deficiency was initially identified during an NRC' inspection in late 1983. ' Subsequent to this inspection, Detroit Edison has discussed this matter with' your staf f - in meetings and by telephone.' f Description of the Deficiency In-response to this potential deficlency, Detroit Edison assigned a task force _to determine the extent of the y

deficiency and to propose a corrective action plan.

To - ~

.date the-task force.has identified approxinately 2,300t,

commercial grade material purchase req 01sitions, issued)d e-i during the period 1978 through 1983, which were intended for use in safety-related systems and components.

The materials included n6ts, boldh,. anchors and support materials as well as electrical. components such as relays, circuit breakers and circuit boards.

Replacement CQ g

i materials'were purchased "like for like" (i.e.,'same

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manufacturer, model number, or part" number) from suppliers or distributors.

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- )Mr.? James (G. Keppler March :27, 1984 t

EF2-66730:

Page 2 (The purchase requisitions affected include past purchases

. including some' purchases.from original equipment manufac-f turersL(OEMs).- 'Past purchases are,those commercial grade materials already ordered and either installed or in stock Lon site.. OEMs are purchases from the original manufac-n

'turer, who was an: approved QA-1 supplier.- However, in isomelcases the manufacturer was no longer on Detroit

Edison's. Approved 1 Suppliers 1 List at the - time replacements

- Lwere purchased.

Anhlysis of the Safety Implications

<The! area ~of1immediate concern involves CQ materials pur-

. chased f for iuse in safety-related applications that have been installed -in the J plant.

Evaluation of the material

c for=this application'was not in all cases adequately J

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! documented.;TThis: result'ed in a potential for less'than h ;;

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3 adequate verification'of theEquality of the installed: CQ material and :the ability of that material to perform ~its l safety-relatedefunction..

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',, DetroitiEdison has reevaluatedDa significant number of

~past3 purchases:toJdetermine:the adequacy of!these i_

materials for-their intended safety-related applications.

.Thehresults of-Lthe review of CQ purchase' documentation to

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date haverindicated that' the, items purchased were Lappropriate for/the: intended application.

From this it

}seems{ apparent;that in the_past,Eevaluations necessary'to

determineithe Jappropriate.use of CQ materials at Fermi-2 Lhad.been performed.-However, the evaluations were-not in all e cases ' documented. Onithis basis,oit has - not been" n

possible 1toiprovidei assurance that iall ' equipment

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specifications and/ororequirements' have been ' met. 'However

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. based : onithe ' results ' of our investigation ef fort thus far,

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s% g" Detroit = Edison ;does. not-expect to find purchases that will LS adversely-affect! safety-related'systemsJor consequently p

impact 4theEsafe operation of the. plant.

' E (g l Corrective Action'

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s Detroit) Edison:has implemented a program,.with a dedicated '

[CQ Engineering; Group,_to evaluate'and document past pur-chases,1new; purchases and OEMs.'

All'past CQ~ purchases are

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Lclassified 'byDequipment, part or -material type.

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y,. i Mr. James G. Keppler March-27,-1984 EF2-66730 Page--3 The:actionsnecessarytoqualify}

Existing purchase documentation is reviewed and a histor-ical profile is created.

the material.are performed,and the evaluation is doc-

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umented. : Conditional releases may be used where work 9

- progress;could be impacted.

OEMs are assessed to verify their status.. Material may be found acceptable based on testing, histor'.calidata or supplier history such as past audits, manufacturer-_ survey (reaudit) or industry

.. experience with a. manufacturer.

New CQ. purchase requisitions or change requests are pro-cessed in a similar manner'to past purchases.

However, refined procedures ensure that each item is evaluated from Janfengineering and quality assurance viewpoint and i

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-supporting documentation.is prepared and maintained,

.Until recentty most of the emphasis has been directed-at

,-evaluating. materials to support. construction and testing.

Welare. confident.that, adequate' controls-are now in place i

2 to" control._the purchase, and. issuance of CQ materials,

and

Detroit Edison is shifting emphasis to evaluate

^ materials?already installedkin the plant" However, as-

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this reevaluation

.. stated above,: Detroit Edison expects will confirm the. adequacy of; materials already installed i

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inithe plant.

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. Detroit Edisoncbelieves -. that the program and actions

' described above will-Lensure that proper-documentation is e

maintained which. delineates the engineering and quality 7 assurance. assessments, inspections or - tests. performed to E

support the.use'of commercial grade materials in i

safety-related. applications....We-will provide another report.on' thissitem, either-interim or final,.when further

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information -is"available.

If-you have questions con-cerningithis matter, please contact Mr.

L.

P.-Bregni f(313) 586-5083.' _

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4, Very truly-yours, W

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