ML20114D394

Suppls Response to NRC Re Violations Noted in Insp Rept 50-341/83-31.Corrective Actions:Personnel Informed That use-as-is Dispositions Must Include Written Technical Justification on Nonconformance Rept

ML20114D394
Person / Time
Site:	Fermi
Issue date:	11/27/1984
From:	Jens W DETROIT EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20114D390	List: ML20114D394
References
EF2-70046, NUDOCS 8501310265
Download: ML20114D394 (3)

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Fermi-2 Edison <"ar=orthDueHghway 6400 N November 27, 1984 EF 2-7004 6 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

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Reference:

1)

Fermi 2 NRC Docket No. 50-341 2)

Letter, W. H. Jens to J. G. Keppler, October 22,1984, EF2-70032

Subject:

Supplemental Response NRC Insoection Report No. 50-341/83-31 This letter provides clarification and an addition to Detroit Edison's response to Noncompliance 50-341/83-31-18A-and is intended to supplement the response contained in Reference 2.

This item of noncompliance involved the failure to provide a documented technical justification for the "use-as-is" disposition assigned to Deviation i

Disposition Request (DDR) No. E-ll430.

To address.the specific concern, Detroit Edison took the following. corrective action which was not mentioned in the original response:-

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Edison Field Engineering personnel have been informed by internal correspondence EF2-103709, and during a nonconformance report training session held on October 2-4, 1984, that "use-as-is" dispositions must include a written technical justification on the NCR.

To_ clarify the technical justification for the' disposition -

of DDR E-ll430, Detroit Edison is providing additional information about Edison Specifications 3071-142 and 3071-226., For perspective and convenience, this information is preceded _by the appropriate portions of the' original response:

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.e Mr. James G. Keppler November 27, 1984 EF2-70046 Page 2 DDR No. E-11430:

(a)

The disposition of DDR E-ll430 required that the actual embedment of the sawed.off anchor bolts be determined by ultrasonic testing.

The "use as is" disposition was technically justified by a comparison.of the UT results and Specification 3071-142, Building Work for Residual Heat Removal Complex, which was in effect when the switchgear was installed.

As discussed below, the_UT results were mistakenly evaluated against the more stringent anchor bolt embedment requirements of Specification 3071-226.

(d)

The'results of the UT test f.emonstrated that the anchors had. a 3 inch minimus embedment versus 2-1/8 inch embedment required at the time of installation by Specification 3071-142.

However, the dispositioning engineer compared these results with the more stringent requirements of Specifi-cation 3071-226 and concluded'that the install-ation was inadequate.

To facilitate the con-struction and testing schedule, the exterior anchors were reinforced with an additional four anchors in the disposition of the DDR.

Later, Design Calculation D.C. 2618, Rev. A, confirmed that the original installation was sufficient to meet design criteria without modification.

To-this: response, Detroit Edison wishes to add:

The original criteria'for wedgeLanchor installation prior to the !ssuance'of Edison Specification 3071-226, t

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-was provided in Edison Specification 3071-142 and was-E acceptable for_ wedge anchor installations since they fwere based _on UL approved' test reports provided1by the vendor..These same test reports:were the basis of the Edison ~Specificationi 3071-226 anchor installation and capacity criteria.- Therefore, wedge anchor instal-

'J lations meeting'the requirements of either specifi-cation are acceptable.

It should be noted:that; wedge anchors were used rarely prior-F

-to1the issuance of Edison Specification 3071-226.

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Mr. James G. Keppler November 27, 1984 EF2-70046 Page 3 Finally, in the Reference 2 response to Noncompliance 50-341/83-31-18A, Nonconformance Report (NCR) 83-1285 is incorrectly identified as NCR 83-1252.

If you have_ questions regarding this matter, please contact Mr. Lewis Bregni, (313) 586-5083.

Sincerely, Ad 1

cc:

P. M. Byron R. C. Knop W. Kropp J. Muffett USNRC Document Control Desk Washington, D.C.

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