ML20137F492
| ML20137F492 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 08/09/1985 |
| From: | Jens W DETROIT EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NE-85-0407, NE-85-407, NUDOCS 8508260231 | |
| Download: ML20137F492 (5) | |
Text
'
t?:yn) H. J:ns Vice President Nuc! ear Operahons Fermi-2 6400 North Dme Heuy
, g Newi srt, M.chgan 481F,6 4
(313) 586 4150 August 9, 1985 NC-85-0407 Mr. James G. Keppler Regional Administrator Region III U.
S.
Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Reference:
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
Subject:
Detroit Edison Response Inspection Report 50-341/85038 This letter responds to the item of noncompliance described in your Inspection Report No. 50-341/85038.
This inspection was conducted by Mr.
J.
Jacobson of NRC Region III on June 25 through 27, 1985.
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 satisfactorily responds to the non-compliance cited in the inspection report.
If you have questions regarding this matter, please contact Mr. Lewis Bregni, (313) 586-5083.
Sincerely
. [f4
/
cc:
P.
M. Byron G. C.
Wright USNRC, Document Control Desk Washington, D.C.
20555 AUG 15133S 9508260231 850809 PDR ADOCK 05000341 0
PDR I l Z C/
t
Mr. James G.
Keppler August 9, 1985 NE-85-0407 Page 2 bcca F.
E.
Agosti L.
P.
Bregni W.
F. Colbert O.
K. Earle R.
R.
Eberhardt W.
J. Glasser E.
P. Griffing S.
J.
Latone J. D.
leman R.
S.
Lenart J.
H.
Flynn/ Docket File (2)
R.
J.
Mbrkovich J.
R. Mullens W.
E.
Miller, Jr.
S.
H. Noetzel J.
A. Nyquiat G.
R. Overbeck T.
D.
Phillips J.
L. Piana J.
H. Plona T.
Randazzo J. S.
Rotondo F.
T. Schwartz P.
M Schwartz B.
J. Sheffel A. A. Shoudy L. J. Simpkin G.
M. Trahey B.
E.
Wickman W gele A.
E.
e Approval Control (136 NOC)
Region III Chron File NRC File Secretary's Office (2412 WCB)
Satellite Service Center
TIIE DETROIT EDISON COMPANY FERMI 2 NUCLEAR OPERATIONS ORGANIZATION RESPONSE TO NRC INSPECTION REPORT NO. 50-341/85038 DOCKET NO. 50-341 LICENSE NO. NPF-43 INSPECTION AT:
FERMI 2, NEWPORT, MICHIGAN INSPECTION CONDUCTED:
June 25 TilROUGII 27, 1985
(
l l
RESPONSE TO NRC INSPECTION REPORT 50-341/85038 i
Statement of_ Noncompliance _85038-01 l
l 10 CFR 50, Appendix B, Criterion IX as implemented by the Detroit Edison Quality Assuranco Program states in part that special processos be controlled using qualified procedures in accordance with applicable codes, standards and specifications.
Contrary to the above, the L. K. Comstock welding procedures do not incorporate the AWS D1.1 code requiroments to support a "proqualified" status and therefore are not properly qualified.
Corrective Action _Taken_and_Results Achieved AWS D1.1-75 requires that vertical.wolding progression be upwards and fillet welds up to and including 5/16" be wolded in a single pass to moot prequalified status.
If the wold proceduro doos not moet the prequalified requirements, then AWS D1.1-75 requires the proceduro to be qualified.
L. K. Comstock Welding Procedure WI-000-03001, including all applicable revisions, did not adequately addross vertical wolding progression or singlo/ multipass critorion as required for prequalified status por AWS D1.1-75.
No evidence that this procedure was qualified for those variables has boon found.
DER No-05-640 has boon initiated to document this deviation.
In accordance with Detroit Edison Specification 3071-120 under which L. K. Comstock performod work, the smallest fillet wold attaching structural stool to structural atool is 3/16 of an inch.
As such, the smallest fillot wold requiring ovaluation would be 3/16 of an inch.
In order to ovaluato the acceptability of the L. K. Comstock work, wold proceduro qualification tests por AWS D1.1 for single and multipass 3/16" fillet wolds on 1" plato have boon conducted I
and have boon found acceptable por Engineering Roscarch Report No. 03E78-40.
Those qualification tests woro performed in accordance with L. K. Comstock proceduro WI-000-03001 in the horizontal, vertical up, vertical down, and overhoad positions.
Sinco the test results woro acceptablo, wolding performed at Formi 2 in accordance with L. K. Comstock Wolding Proceduro WI-000-03001 is judgod to be acceptablo, e
1 i
i
RESPONSE TO NRC INSDECTION REPORT 50-341/85038 Corrective Action Taken and_Results Achieved (Cont'd)
In addition, in order to verify that the wolds would have been performed in the vertical up position, a review of all L. K. Comstock Wolder Qualification Records was conducted by Nuclear Quality Assurance and documented on Surveillance Report No. 5-MA-85-298.
Six (6) of the seventy seven ( 77)
Welder Qualification Records did not state that the test was conducted in the vertical up position.
However, the L. K.
Comstock QA/QC Manual, section 4.7.5, paragraph 3,13 requires that Quality control verify that Welder Qualifications Tests be performed in the vertical up position.
Based on this review of Comstock Welder Qualifications and QA/QC manual, it appears that Comstock was complying with the vertical up requirement of AWS D1.1 for prequalified status, even though this requirement was not oxplicitly included in the subject welding proceduro.
Corrective _ Action to Prevent Further Noncompliance During the on-site proceduro review cycle for the original and subsequent revisions of L. K. Comstock Welding Procedure W1-000-03001, the lack of vertical progression and singlo/
multipass criteria was not detected by the reviewers.
In order to verify the adenuncy of welding performed by other sito contractors, a review of their prequalified wold proceduros for those attributes is being conducted.
Dato_When Full Compliance Will_.o Achieved B
l Evaluation of L. K. Comstock Procedure WI-000-03001 has boon completed, and work dono in accordance with this procedure is considered to be acceptablo.
The review of other contractors' procedures for vertical progression and i
singlo/ multipass requirements will be completed by August l
16, 1985.
Any corrective actions resulting from this review i
will be completed by September 16, 1985.
l
[
2
-