ML20098C729
| ML20098C729 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/10/1984 |
| From: | Jens W DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20098C721 | List: |
| References | |
| EF2-72793, NUDOCS 8409270155 | |
| Download: ML20098C729 (5) | |
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- Wryne H. JIna k.
. Vee Pres cent
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Nuckar Opera ions i
Detroit-6400 North Dix % H,ghway i
Newport, McNgan 48166 13'3) saS41so September 10, 1984 EF 2-7 27 93 PRINCIPALSI/FFk Mr. James.G. Keppler N
Regional Administrator
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Region III RC \\
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Nuclear Regulatory Commission PA0
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' 799 Roosevelt Road
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Glen Ellyn, Illinois - 60137 III OI \\
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Dear Mr. Keppler:
Reference:
Fermi 2 NRC Docket No. 50-341
Subject:
Noncompliance at Fermi 2 Inspection Report 50-341/84-30 This letter responds to the item of noncompliance described in your Inspection Report No. 341/84-30.
This inspection was performed by Mr. J.
Norton on June 27-29, and July 10-12, 1984.
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.
We trust this letter will satisfactorily respond to the noncompliance cited in your report.
If you have questions regarding this matter, please contact Mr. Lewis P.
- Bregni, (313) 586-5083.
Sincerely, cc:
Mr.
P.
M.. Byro n Mr.
R.
C. K nop Mr. J.
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THE IEI'ROIT EDISON CWPN1Y FERMI 2
- NUCEAR OPEPATIONS TGNIZATION Response to IGC lbport No. 50-341/84-30 Docket No. 50-341' License No. CPPR-87
-Inspect on at: Fermi.2, Newport Michigan i
Inspection Corducted: June 27-29, 1984 ard July 10212, 1984 r-I i '
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k RESPONSE 'ID NRC INSPECTION REIVIE tb. 50-341/84-30 Statement of Nonempliarce 84-30-01, Criterion XVI 10CFR50, Apperdix B, Criterion XVI, as implemented by Detroit Ddison's Errico Fermi Atomic Power Plant Unit 2 FSAR, Volute 9, Section 17.1.2, Paragraph q., ard the Quality Assurarce Manual, Errico Fermi Power Plant Unit 2, Policy 17.0, Paragraph 17.0.1, require that appropriate ard prarpt corrective action be taken when corditiors adverse to quality are identified.
Contrary to the above,' Deviation Disposition Request Ib. C-12154, addressirg shore barrier str.ucture configuration deviatiors from design requirerents, was improperly and inadequately dispositioned in
.that:
a.
The recomnended FIELD PROIOSED DISIOSITION was "use-as-is" even though supportirg data clearly showed that corstruction tolerances were significantly exceeded.
b.
The stpportire data was misleadire ard contained errors of omission.
c.
'Ihe dispositiorsrg was based on data which evidently was rot analyzed thoroughly.
~
Corrective Action Taken ard Results Achieved Statement of Norconformarce 84-30-01 bases its corclusion that Devia-tion Disposition Request (DDR) C-12154 was improperly ard inadequately -
dispositioned on three observatiors. Detroit F111 son has re-evaluated its disposition of this DDR in light of these observatiors.'
a.
"The reconmerded Field Proposed Disposition was "use-as-is" even though supportire data clearly showed that corstruction toler-arces were significantly exceeded."
This observation is correct in that the corstruction tolerarces were exceeded ard that the disposition was "use-as-is."
The disposition of DIR C-12154 was based on the unstated determination that the elevation
. was satisfactory W1ere the barrier meets the fill for the entire 1ergth of the barrier ard that the corstruction tolerarce, as it applies to the full width of. the barrier, was more restrictive than necessary. Sirce the elevation was satisfactory at fill for the full 1ergth, the barrier would meet.its design furotion of maintaining the fill. - A tolerance of + 6 irches for the placement elevation of ran-danly shaped rock with typical dimensiors of 3 feet to 5 feet was rot
= necessary for the structure to fulfill its intended purpose. Modifi-cation of the structure to cmply with the specified a>rstruction
-tolerarce was ard still is judged to be unnecessary. _
r We disposition of DDR C-12154 was based on an analysis of the eleva-tion at eleven statiors Wich revealed an average variation of.minus 0.75 feet. As a result of the NRC concern, a secord evaluation was corducted by the shore barrier design engineer, R. M. Ibble of
-R. M. Ibble Associates in July 1984.
Elevation variatiors at the eleven statiors of DDR C-12154 ard the elevation variation at the lowest.part of the shore barrier (N6864) were corsidered. Mr. Noble's evaluation,.reprted in the attachment to Dames & Moore letter D10-01, confitned the adequacy of the "use-as-is" disposition.
b.
"The stpportirg data was misleading ard contained errors of omission."
DDR C-12154 corsidered data taken at Ire-determined survey points.
The survey points were mlected at 100 foot intervals alorg the entire length of the shore barrier startirg with the first full cross section at station N6800. Eis approach ard interval spacire cx:np.1ied with
- the cannitment made in FSAR Apperdix E5 item 321.5.
As a result of the NRC corcern, Ibnconformance Report (ICR) 84-1081 dated July 18, 1984, was written to docunent the fact the DDR C-12154 did rot account for the greatest variatiors in elevation. Se evalua-tion of.lCR 84-1081 included data at worst case locatiors (N6864).
This data ms evaluated by the shore barrier design ergineer ard the shore barrier was fourd to be acceptable becatse it would meet its design function of protectire the site fill.
c.
"The disrositionirg was based on data Wich evidently was rot analyzed thoroughly."
This observation zddresses the dispsitionirs ergineer's justification for dispsitionity the DDR based on ergineerirg judgenent ard rot revisirg the design calculation.
The design calculation corsiders only the height of the barrier at the fill ard the weight of the irdividual rocks. Since low elevations were fourd only at the leadire edge of the barrier, revisions to the calculation were rot considered recessary. This corclusion is supported by the re-evaluation performed by R. M. Ibble.
Corrective Action Taken to Avoid Further Nonccmpliance Personrel involved in the dispositioning of DDR C-12154 will review
. appropriate Fermi 2 procedures for dispsitioning rorronformances.
These procedures state the need to provide a documented technical justification to substantiate that "use-as-is" dispositiors will rot adversely affect the ability of an item to perfonn its interded function. Additionally, these procedures require that dispositiors which affect configuration be subnitted for approval to the organiza-tion resporsible for design. i
J-
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< s 1Date When Full Compliance Will-be Achieved
^
' The Architectural-Civil Supervisor 'ard work leader. will docunent the
' fact lthat they have re-read the appropriate Exocedures for.disposi-
- tionirg torronfonnarces by September 14, 1984.
4.
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