ML20116N273

Responds to Violations Noted in Insp Rept 50-341/85-11. Corrective Actions:Walkdown of Drywell Conducted to Identify Spacing Violations for Anchor Bolts & Acceptance Documented in Design Calculations

ML20116N273
Person / Time
Site:	Fermi
Issue date:	04/18/1985
From:	Jens W DETROIT EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
EF2-70452, NUDOCS 8505070092
Download: ML20116N273 (9)

Text

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~ Coyne H. Jems Vice President t.

Nuclear Operatwis

.. e Fermi 2 6400 North Dixie Highway

'h lQAF"h Newport, Mchigan 48166

.h Ivvl 1 - m3) s88-4150 April 18, 1985 EF2-70452 Mr. James G. Keppler

. Regional Administrator

. Region-III U.-S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Reference:

Fermi 2 NRC License No. NPF-33

Subject:

Detroit Edison Response Inspection Report 50-341/85011 2

This letter responds to the items of noncompliance described in.your Inspection Report No. 50-341/85011.

This inspection was conducted by Messrs.

P.

D. Kaufman and J.

W.

Muffett of NRC Region III on February 19 through 22 and March 4, 1985.

The items of noncompliance 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 items cited in the body of t.he inspection report.

.The appropriate criterion and the number identifying the' item are referenced.

We trust this letter satisfactorily responds to the Lnoncompliances cited'in.the inspection report.

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

Sincerely, cc:,

P..M. Byron fy{

4Xh N. J. Chrissotimos USNRC,? Document Control Desk Washington; D.C.

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'Mr.' James G. Keppler

' April 18, : 1985 EF2-70452 Page 2

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E. Agosti Y. N.'Anand R. W.

Barr A.'F. Colandrea W.

F.'Colbert O. K..-Earle W. J.

Fahrner.

N. - J. Glasser W. - R. Holland S. J.'Latone R. S. Lenart

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K; Lim P. A.'Marquardt/ Docket F11e.(2)

J.-F.

Malaric W. E. Miller, Jr.

R. ~ C. Moore S. H.-Noetzel J. A..Nyquist-G. R. Overbeck T. D.

Phillips

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R.-Preston L. E. Schuerman F. ' T. Schwartz D. L. Schweikhart L. J. Simpkin D. Spiers W. M. Street G. M. Trahey R.'.A. Vance A. E. Wegele M. ' S. Williams Approval. Control (136 NOC)

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1 THE DETROIT EDISON COMPANY

. FERMI 2 NUCLEAR OPERATIONS. ORGANIZATION RESPONSE TO NRC INSPECTION REPORT NO..' 50 -341/85011.

DOCKET NO...50-341-LICENSE NO. NPF-33 INSPECTION AT FERMI 2,-NEWPORT,-MICHIGAN INSPECTION ' CONDUCTED:

FEBRUARY 19-22, AND.

MARCH 4, 1985 e

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RESPONSE TO NRC INSPECTION REPONf NO. 50-341/85011 Statement of Noncompliance 85011-01 10 CFR 50, Appendix'B, Criterion XVI, as implemented by Detroit Edison's Quality Assurance Manual, Enrico Fermi Power Plant, Unit.2, Policy 17.0,-Paragraph 17.0.1, requires that appropriate and prompt corrective action be taken when conditions adverse to quality are identified.

Contrary to the above, Item #42, relating to spacing of concrete anchors, of the March 26, 1981, 50.55(e) DECO defi-iency report was inadequately dispositioned in that:

a.-

Numerous deviations of the minimum anchor bolt spacing requirements, as-outlined in. DECO's Project Specifica-tion 3071-226, had not been observed or documented during the Sys. tem Completion Organization's anchor violation surveillances..walkdown of the site.

i b.

Deficiencies of anchor bolt spacings were documented on Anchor Bolt Surveillance Reports but were not ade-quately justified or documented as technically accept-able in any qualification calculations.

Corrective Action Taken and Results Achieved a '.

Although not explicitly stated in our report on 10 CFR 50.SS(e). Item 42, the scope of the Anchor Bolt Surveillance ~ Report ( ABSR) ~ walkdown was not ' intended to provide a complete (100%). check for anchor. bolt spacing violations.

Evaluation'of approximately 800 violations on a case-by-case basis had resulted in no rework of installed anchor bolta.to alleviate.the violations.

When the inspectors identified some anchor bolt spacing violations which had not been documented, the following actions were taken:

1.

Because the drywell had not been included in the previous walkdown, a walkdown was' conducted to identify any violations that might exist there.

Seven violations were identified, analyzed and found to be' acceptable.

2.

A generic calcule. tion was performed to show that, for'the length of anchor bolts specified for Fermi 2, significant spacing violations'could be accepted.- The calculation assumes several differ-i ent' severe spacir.g violations.as worst case exam-

-ples.and demonstrates that acceptable capacity and ductility' remain.

This is accomplished by calcu-lating the effects of reduction'in shear cone l

area.

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RESPONSE TO NRC' INSPECTION REPORT 50. 50-341/85011 t

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. Corrective A' tion-Taken and Results Achieved (Cont'd) c I

The results of'this study have been documented in 1

Design. Calculation.(DC #3200).

This provides 4

I reasonable assurance that-all practical cases of

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.anchorfspacing violations-(including any that may 7

not have-been picked up during walkdowns) are

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enveloped-by the severe case check.

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5All the'decumented deficiencies have been evaluated on a case-by-case basis and the acceptance results have been~ documented ~in desi'gn calculations.

' Corrective Action - Taken -to Prevent Further Noncompliance

'TheLfollowing steps are being taken to prevent recurrence of

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such violations:

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A review of the anchor spacing violations

' identified during the-recent.walkdowns revealed' i^

that most of.these violations e:tisted before the j

walkdown performed in response to-our 10 CFR 50.55 (e); Item 42. 'Therefore:the controls established to monitor and provide justification.of such violations have-been reasonably effective'since-that time.

2.

To reinforce the corrective actions for 10 CFR 50.55(e).ItemL42, a guide checklist to document and r'esolvejancho: spacing violations'is being

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added to Specification 3071-226. - nie pertinent f~

checklist' item will.be added to checklists"that already exist, -for. example, Jthe hanger ' inspection i

checklist'will.have expansion 1 anchor spacing requirements,added to the expansion anchor:

section.

13. -

With the. reduction inathe. number of contractors

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.onsite,,the responsibility for' design of' expansion anchors has been consolidated.

This~responsi-4 bilityfnow rests withtthe Architectural-Civil

'h ',4 Lcurrently supported by=Sargentiand'Lundy.-

" Design Groupfand )he Engineering-Mechanics' Group, 14.

'A standard. design methodology;willLbe developed'to

W m document' expansion > anchor design criteria'for

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Jplant; wide"use.

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Y RESPONSE.TO NRC INSPECTION REPORT NO. 50-341/85011

s Date When Full Compliance Will Be Achieved LThe guide' checklist will:be added to Specification 3071-226 by.May.15, 1985.

The standard anchor design methodology

.will be in place by June 15, 1985, at which time Detroit Edison will be'in full compliance.

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s RESPONSE TO.NRC INSPECTION RSPORT NO. 50-341/85011 1

Statement of Noncompliance 85011-02 10 CFR 50,_ Appendix Bi Criterion III, as implemented by Detroit-Edison's-Quality Assurance Manual. Enrico Fermi

. Power Plant, Unit 2, Policy 3,-Paragraph 3.0.1, requires that plant design be apprcpriately controlled in process, j

and its adequacy be verified and documented.

Contrary to the above:

t a.-

The. average ultimate tensile loads were lowered fdr Phillips Wedge anchors by DECO Project Specification 3071-226, Revision F,. and no engineering justification or. design evaluations were conducted to verify that previously designed anchors were acceptable-to the lower allowable loads.

b.

. Special installation torque and tension notes weren't being-added1 to the ' installation drawings as required by Project' Specification 3071-226 and DECO drawing 5C721-2002.

c.

A reconciliation calculation related to Design Change Request P-5299, Revision B, utilized incorrect load values from superseded Revision E of Specification 3071-226.

Corrective Action Taken and Results Achicved Specification. 3071-226 was revised via Design Change Notice l.

(DCN) No. 10677 dated July 2, 1984, to reduce the allowa-ble i

tensile capacitier, for 3/8",

1", and 1-1/4" Phillips wedge anchor bolts designed using the higher (Table I-B)~ average

' ultimate tension loads.

This change was made retroactive to

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October, 1982.(the date that Table.I-B wasladded to Specifi-catibn 3071-226)' so_that existing anchor' bolts had to be reviewed and verified as acceptable for the revised allowable loads.

However, at the time of the_ inspection, no calculations had been performed showing that;the. installed

anchor bolts were acceptable, and the higher values were still being1used in-design.

Furtherithe inspectors noted that:the(special installation requirements associated with

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the. us.e of Table I-B - tensile capacities were' not always specified on.thefdesign drawings.

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~5 1 RESPONSE'TO-NRC INSPECTION REPORT NO. 50-341/85011 Corrective Action Taken and Results Achieved (Cont'd)

In response toothis item of noncompliance, the following-Ecorrective actionsLwere taken:

1.-

DetroitEEdison Design Calculation No. 974, Revision C,Lwas prepared, justifying the slightly lower (5%). allowable loads (Specification 3071-226

. Table I-B Revision F values) for~3/8",

1" and 1-1/4" Phillips wedge anchor bolts on a generic basis for allJ installed -anchors designed with the higher Table I-B. allowable values.

The reconcili-

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ation calculation for Design Change RequestLP5299 Revision.B (cited as item c. above) is covered by this generic calculation.

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2.

In response to Item b.,

seventy-five (75) hanger calculations were reviewed to determine whether or not.the high'er1(Table I-B)' tension allowable loads were used in the design, which would require the addition of special installation notes to the drawings.

The Main Steam'and Feedwater systems were selected for this sample since they have a larger number;of supports using'the higher. bolt allowable value.

Also, spring and' constant support hangers were excluded from the sample due to the infrequent.use of the higher bolt allow-ables.

In all cases-which'used the Table I-B h

allowable loads, either the special installation requirements were specified on theLdesign drawings (l'O supports) or the special-installation require-ments were not necessary-(2 supports).

Accordingly,-

no additional. review.for these requirements is'

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necessary.

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Corrective Action Taken To Avoid Further Noncompliance In order.to avoid further noncompliance, the~following j

. actions are being taken:

I a.

'The' Director ofl Project Design lre-emphasized the

. importance'offaddressing' design criteria changesiin a timely manner in-a' design discipline supervisors

' meeting..'The proper manner'ofl addressing theselchanges

.was also stressed.

'b.-

EDP-2356 is-being prepared, revi' sing drawing 5C721-2002 to clarify the-special installation' torque and tension s

test requirements forLanchor: bolts designed using the Table ~I-Bl allowable-loadings.: The-standard sheet used

'with pipe support nketches,to specify special'installa-

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tion requirements ~was revised toJrefer-to:the drawing' 1.

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4 RESPONSE TO NRC INSPECTION REPORT NO. fig-341/85011 L

Corrective Action Taken To Avoid Further Noncompliance (Cont'd)

for installation data.

These changes consolidate all anchor bolt installation data in a single controlled document.

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The load table will be removed from the standard sheet

'and the user will be directed to Specification 3071-226 g-for current capacities.

This will assure that the

-design. input information is compatible with Specifica-tion 3071-226.

-Memorandum F2E-85-0301 was also written-to remind the Edison

support-designers, design discipline supervisors and (active) A/E project nanagers of the reduced allowable anchor bolt loadings in Table I-B of Specification 3071-226, Revision F,.and.EDP-2556 establishes an effective-date for

.using the new loads iri design.. These documents also empha-size the need to specify special installation requirements where necessary for bclts designed using Tablo I-B allowable loads or to document in the hanger calculations why these special-installation requirements are unnecessary.

Date When Full Compliance Will Be Achieved Full compliance will be achieved by May 15, 1985.

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