ML20237D013
| ML20237D013 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/16/1987 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Sylvia B DETROIT EDISON CO. |
| References | |
| NUDOCS 8712220313 | |
| Download: ML20237D013 (2) | |
See also: IR 05000341/1987033
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DEC i 61987
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Docket No. 50-341
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The Detroit Edison Company
ATTN:
B. Ralph Sylvia
Group Vice President
Nuclear Operations
6400 North Dixie Highway
Newport, MI 48166
Gentlemen:
Thank you for your letter dated November 13, 1987, informing us of the
steps you have taken to correct the violations at the Fermi 2 facility
which we brought to your attention in our letter dated October 16, 1987.
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After review of your response and telephone conversations between
Mr. S. Reynolds of our staff and Messrs. S. Cashell, S. Frost, J. Hughes and
R. May of your staff on December 2, 3, 4, 7, and 9,1987, it was determined
that the following needs to be addressed:
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1.
Results of the evaluation of the effect that never performed and past-
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due preventive maintenance (PM) activities have on the reliability
and operability of affected systems.
2.
What actions you have taken to reduce the backlog of past due Priority A
PM activities.
3.
What actions you have taken in the area of justification for postponed
PM activities, in that the evaluation documented on the " Incomplete PM
Form" will be based on defined engineering criteria; recognizing that the
evaluation should include the affert on the operability and reliability
of the component and associated systems.
Mr. Cashell of your staff stated that the above would be formally addressed
and a response prepared by December 31, 1987.
In addition to the above, an update of your response to violation 87028-04,
including the corrective action taken to prevent the failure to identify
components as Technical Specification related, is expected by December 31,
1987, as you previously committed.
Sincerely,
..:l C:, n ' !" J. J. ::
8712220313 071216
ADOCK 05000341
0
H. J. Miller, Director
Division of Reactor Safety
See Attached Distribution
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Detroit Edison Company
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DEC i 61987
Distribution
cc: Lewis P. Bregni, Licensing
P. A. Marquardt, Corporate
Legal Department
cc w/ltr dtd 11/13/87:
DCD/DCB (RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
Ronald Callen, Michigan
Public Service Commission
Harry H. Voight, Esq.
Michigan Department of
Public Health
Monroe County Office of
Civil Preparedness
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Septenber 17, 1987
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NIC-87-0171
U. S. Ibclear Regulatory Commission
Attn: Document Control Desk
Washington, D. C.
20555
References: 1) Fermi 2'
hTC Docket No. 50-341
NIC License No. NPF-43
2)
IE Inspection Report No. 50-341/87033,
dated August 19, 1987
Subject:
Response to Notice of Violation
50-341/87033-01 and -02 A, B, C & D
Reference 2 identified violations concerning inadequate design control
and procedural error. Detroit Edison concurs with the violations as
stated. The enclosed response provides the actions taken and those
which will be taken to prevent violations of this type from occurring
in the future.
We trust this letter satisfactorily respords to your correrns. Please
contact Mr. L. Bregni at (313) 586-4072 if you have any further
questions.
Sincerely,
N.T ,
-L~
F. E. Agosti
Vice President,
Nuclear Engineering and Services
Enclosure
cc: Mr. A. B' Davis
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Mr. E. G. Greenman
Mr. W. G. Rogers
Mr. J. J. Stefano
USNIC Region III
40
-07092EOGsB 870917
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ADOCK 05000342
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Enclosure to
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lac-87 0171
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RESPONSE 'IO hTC INSPICTION REPORP 50-341/87033
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Statement of Violation 87033-01
10CFR50, Appendix B, Criterion V, requires that activities affecting
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quality shall be accomplished in accordance with prescribed
procedures.
Contrary to the above, Stone and Webster, as a standard prmtice, has
not evaluated expansion anchor spacing violations in accordance with
the methodology prescribed in Specification No. 3071-226, Revision G,
July 15, 1985.
This is a Severity Level V Violation.
Corrective Action Taken and Results Achieved
A standard methodology for evaluating anchor spacing violations was
developed ard is contained in Detroit niison Specification No.
3071-226, Revision G, Appendix C.
It was developed based on specific
Fermi installation requirements and material properties, ard was
intended to provide a systematic approach for addressing anchor bolt
spa:ing violations. Design Calculation No. 688, Volume III, Revision
0, the original calculatico performed by Stone & Webster to address
anchor bolt spacing violations did not utilize this standard
methodology. DC 688 has since been revised utilizing this standard
methodology, including both the design checklist and the violation
documentation checklist. The revised calculation, DC 688, Vol. III,
Revision A reaffirms the acceptability of the anchor bolt spacing
violations evaluated.
As noted in the inspection report, the methodology originally
utilized by Stone & Webster to evaluate the anchor spacing
violations, although not consistent with Spec. No. 3071-226, was at
least as conservative as the standard methodology described in Spec.
Ib. 3071-226.
Corrective Action Ta};pn to Prevent Further Violations
Memorandum NE-PJ-87-0492 was issued to the Nuclear Engineering groups
and supporting Architect / Engineering firms involved in concrete anchor
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design to emphasize the requirements for utilizing the standard design
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methodology in Specification 3071-226, Appendix C, including the use
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Enclosure to
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NEC-87-0171
Page 2
Corrective Action Taken to Prever.t Further Violations (Continued)
of the design checklist and the spx:ing violation evaluation
checklist, as applicable. This action has been taken to prevent
future violations of this type.
In addition, Detroit Edison will reconfirm that the UFSAR is correct
with respect to calculational methodologies and computer programs
utilized in support of Fermi 2.- This review and confirmation will be
completed prior to the next annual update of the Fermi 2 UFSAR.
Date of Full Compliance
Full conpliance will be achieved prior to submittal of the next annual
update of the Fermi 2 UFSAR which is presently scheduled for
March 20,1988.
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Enclosure to
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imC-87-0171
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Statement of Violation 87033-02 (A, B, C & D)
10CFR50, Appendix B, Criterion III, requires that the design bases are
to be correctly translated into design docunents.
Contrary to the above, the design bases were not correctly translated
into design documents in that:
A)
In Calculation DC No. 974, Revision C, the torque
requirement for 11/4 inch diameter wedge anchors was
calculated using the shear capacity of the bolt instead of
the tensile capacity.
B)
On Drawing 5C721-2002, Revision I, the mininum edge
distance for 11/4 inch diameter wedge anchors was
incorrectly specified as six irches.
C)
In Specification No. 3071-226, Revision G, Appendix A, the
definitions for " manufacturer or supplier" and " seller or
distributor" were incorrectly stated.
D)
In Calculation DC No. 4479, Revision A, the following
errors were identified:
1)
Moment calculations for Masonry Wall Nos. 219 and 234
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were incorrect.
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2)
Bending stress calculations for Masonry Wall Nos. 219
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and 234 were incorrect.
3)
Design assumptions for Wall No. 219 are acceptable,
but justifications nust be made so that the calculated
moments and stresses reflect the actual boundary
condition.
4)
The door frame in Masonry Wall No. 219 was assuned to
be a simply supported member resisting seismic loMs.
However, the door frame was not analyzed to assure
that it could withstard the calculated seismic loa 3s.
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5)
Seismic shear stress was not considered in the design
evaluation.
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6)
The ratio of the horizontal to the vertical dinension
for Masonry Wall Nos. 216, 218 and 221 was not
consistent with the design fornula. Accordingly, the
calculated natural frequency was incorrect.
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Enclosure to
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NFC-87-0171
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Page 4
Statement of Violation 87033-02 (A, B, C & D) (Continued)
7)
The use of the zero period a:celeration (ZPA), based
on the calculated frequency of 12.91 HZ, was
inappropriate.
8)
Section 6-6 on Drawing 6C721-2608 was not deleta3 on
Revision H as stated in Revision G and DCN 10831.
This is a Severity Level IV Violation.
Corrective Action Taken and Results Achieved
A)
The installation torque requirements in DC No. 974 were
calculated to ensure that, under the maxinum allowable tension
load, no anchor slippage would occur. The torque range
specified was utilized for both Hilti Kwik bolt ard Phillips
wedge anchors.
Design calculation No. 974, Revision C, has been revised for
11/4 inch diameter wedge anchors utilizing the allowable
tension load of 9450 lbs. rather than the allowable shear loa 3
of 8920 lbs. Substituting the tension loa 3 value (9450 lbs.)
for the shear load value (8920) in DC No. 974 Revision D yielded
no change in the specified allowable range of torque values for
11/4 inch diameter wedge anchors.
B&C) As Built Notice (ABN) No. 7719-1 was issued August 17, 1987 to
correct the minimum edge distance requirement for 11/4 inch
diameter wedge anchors, on drawing SC721-2002, to 61/4 inches,
and to correct the definitions in Specification No. 3071-226,
Appendix A, related to " Manufacturer or Supplier" and " Seller or
Distributor."
Additionally, an evaluation was ma3e in Revision D of Design
Calculation No. 974, dated August 11, 1987, to support the
generic acceptance of 11/4 inch diameter wedge anchor
installation with 6 inch minimum edge distance to account for
those bolts for which 6 inch mininum edge distance may have been
utilized.
D)
Design Calculation No. 4479, Revision A, was generated in
April,1987 to evaluate the masonry wall non-conformances
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identified in Deviation Event Report No.86-167, ard to assess
the walls' susceptibility to failure in the interim until all
non-conformances ha3 been corrected. These non-conformances
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NBC-87-0171
Page 5
Corrective Action Taken and Results Achieved (Continued)
have since been corrected via EDPs 6816 ard 7784. Three
As-Built Notices have also been issued to document the field
condition of these walls (ABNs 6719-1, 7714-1 ard 7871-1) .
Fermi 2 is in conformance with the design bases as described in
the UFSAR.
Design Calculation No. 4479, Revision A, has been revised to
correct the specific errors identified in the inspection report
as follows:
1)
Homent calculations for Wall No. 234 have been revised to
correct the moment directions (page E-6 of DC 4479, Rev,
B) .
Wall No. 219 has been reevaluated in a different manner in
which the relative stiffness of all the connecting elerrents
at the top of the wall are cot.sidered. The reevaluation
demonstrated that the Forwny anchors ut>ed for these
connections are able to absorb the anticipated vertical
movement and therefore, the connection at the top of the
wall is assumed to be maintained. Using this approa:h,
calculation of bending moments and stresses is no longer
necessary since the original design boundary corditions do
not change.
2)
Stress calculations for Wall No. 234 have been revised to
correct the errors noted (page E-6 of DC 4479, Rev. B) .
As noted in 1) above, bending moment and stress
calculations for Wall No. 219 are no longer necessary,
since the reevaluation of Wall No. 219 shows that the
original design boundary conditions have not changed.
3)
Additional explanations have been added on pages 7, 7a, 8
and 8a of DC 4479, Dev. B to substantiate the acceptability
of the boundary conditions assumed for Wall No. 219.
4)
The revised evaluation of Wall No. 219 has shown that the
top connection will not be lost during an earthquake, ard
therefore, the original boundary corditions assumed in DC
No. 841 are valid. These original boundary corditions did
not utilize the door frame for lateral load support.
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Page 6
Corrective Actio1 Taken and Results Achieved (Continued)
5)
A generic shear stress evaluation was added on page E-12,
of DC No. 4479, Rev. B for the two (2) different types of
twrtar used in the block walls. The evaluation shows that
shear stress in the worst case will not exceed 21.5% of the
shear strength.
6)
The ratio of the horizontal to the vertical dim sions of
the walls has been corrected on pages E- 8 and E-9 of DC No.
4479, Rev. B for Walls 216, 218, 221.
7)
The provisions of IEEE standard 344-1975 specify a factor
of 1.5 tu be used to account for m1tifrequency exitation
and mltinode response when utilizing Static Coefficient
Analysis. The same standard allows Zero PerioS
Accelerations (ZPAs) to be used if dynamic analysis shows
that an item is rigid, with no resonances in the response
spectrum amplification range.
Design Calculation, No. 4479, Revision B, utilizing dynamic
analysis, concludes that all walls are rigid with no
resonances in the response spectrum splification range,
with the exception cf Wall No. 216. Therefore, ZPAs were
used for all walls except Wall No. 216 which has been
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determined to have a natural frequency of 19.8 CPS (page
C-9) . A factor of 1.2 is justifier 1 for this wall since its
natural fregaency is very close to the ZPA plateau of the
response rpectrum. It shwld be noted that the use of a
different factor, in this case, does not alter the
conclusion of the analysis for Wall No. 216.
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8)
As-BuGt Notice No. 7710-1 has been issuer * to remove th6
section mark 6-6 from drawirg 6C721-26C8.
An independent third party review of DC 4479, Revision B, has been
performed by an outside consultant. The review, which utilized
alternate methods to evaluate the reasonry walls, confirmed the
conclusions in DC 4479, Revision B.
All walls analyzed in DC 4479,
Revision B, have been shown to be able to withstand the Fermi design
basis earthquake with the exception of Wall No. 216, which cou13 not
be analytically proven to be able to survive the design basis
earthquake. However, it is the Consultant's opbilon that Wall No. 216
would not collapse as a result of the design basis earthquake. This
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independent third party review is documented in report No.
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Corrective Action Taken and Results Achieved (Continued)
HA-08/87-610, Revision 1 which has been transmitted along with Design
Calculation, DC No. 4479, Rev. B to Mr, Liu of your staff.
Finally, Detroit IMison verified that no safety-related conponents
have ever existed within the failure zone of influence for Wall No.
216. Engineering Design Package No. 7784, which was inplenented in
August 1987, brought this wall up to its original design cordition by
the addition of external steel angle reinforcement.
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Corrective Actions Taken to Prevent Further Violation
A)
Nuclear Engineering procedure No. 2.5.2 " Design Calculations"
Revision 1, dated July 10, 1986, incorporates a verification
checklist requirement for all design calculations. The
checklist requires that the verifier answer specific detailed
questions related to design calculations.
This revised design verification process, currently in effect,
should prevent oversight errors such as the one described in the
inspection report.
B&C) Tbsse errors occurred during the incorporation of Engineering
Design Package No. 2356 onto drawing 5C721-2002 and
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Specification No. 3071-226 prior to November of 1985. As of
November 1985, all change paper incorn ation work has been
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performed by Stone & Webster, the on- a e Architect / Engineering
firm, in accordance with procedures No. NE-2.14 and !OP-21.
Audits are performed periodically by Detroit Edison's Quality
Assurance personnel to assure that the task is being performed
properly and in conformance with the specified procedures, e.g.,
Audit No. A-EA-S86-41.
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D)
Deviation Event Report (DER) No.87-228 was written to document
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the errors identified in DC 4479, Revision A.
Corrective action
required for disposition of the DER includes preparation of a
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list of design calculations prepared by the originator of
DC 4479, and all design calculations prepared, checked or
verified by the verifier of DC 4479, Revision A, since
March 1, 1985.
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NBC-87-0171
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Corrective Actions Tak3n to Prevent Further Violation (Continued)
A representative sample of this list will be reviewed by a third
cognizant Engineer in the Arch / Civil group of Plant Engineering
or by an outside consultant. Based on the results of this
review, additional reviews, checks or other appropriate actions
will be taken, as needed.
A memorandum will be issued to appropriate Nuclear Engineering
personnel stressing the importance of careful and accurate
engineering design and verification efforts. The memoranduin
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will emphasize attention to detail and the inportance of not
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compromising quality for expediency.
Date of Full Comnliance
A)
Full compliance has been achieved.
B&C) Full compliance has been achieved.
D)
Corrective actions identified in " Corrective Actions Taken and
Results Achieved" above, have been completed. Corrective
actions to prevent further violations will be completed by
December 31, 1987.
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