ML20237D013

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-341/87-33.Listed Actions Should Be Addressed & Update of Response to Violation 87028 Expected by 871231

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

Text

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l DEC i 61987

j Docket No. 50-341

The Detroit Edison Company

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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:

i 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

PDR ADOCK 05000341

0 PDR H. J. Miller, Director

Division of Reactor Safety

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Detroit Edison Company 2 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 j

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Septenber 17, 1987 1

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

Mr. E. G. Greenman

Mr. W. G. Rogers

Mr. J. J. Stefano

USNIC Region III

40

-07092EOGsB 870917

PDR ADOCK 05000342 J' i

G PDR

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l RESPONSE 'IO hTC INSPICTION REPORP 50-341/87033

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Statement of Violation 87033-01

i 10CFR50, Appendix B, Criterion V, requires that activities affecting

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

l design to emphasize the requirements for utilizing the standard design

l methodology in Specification 3071-226, Appendix C, including the use

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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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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:

i 1) Moment calculations for Masonry Wall Nos. 219 and 234

l were incorrect.

l 2) Bending stress calculations for Masonry Wall Nos. 219

and 234 were incorrect.

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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.

l 5) Seismic shear stress was not considered in the design

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evaluation.

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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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

I 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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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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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

l 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.

As-BuGt Notice No. 7710-1 has been issuer * to remove th6

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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

I 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 j

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

l Specification No. 3071-226 prior to November of 1985. As of

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November 1985, all change paper incorn ation work has been

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. &

l 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 <

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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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  !

will emphasize attention to detail and the inportance of not  !

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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