IA-87-413, Outlines Plan for Review & Evaluation of Issue Specfic Action Plan Results Rept Isap VII.a.6 (Rev 1), Exit Interviews
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Docket Nos.: 50 445 -
and 50-446 MEMORANDUM FOR: 8. Grimes, Director Division of Quality Assurance, Vendor and Technical Training Center Programs, IE E. Johnson, Director Division of Reactor Safety h
and Projects, Region IV' R. Ballard, Chief Engineering Branch Division of PWR I.icensing-A, NRR F. Rosa, Chief Electrical, Instrumentation and Control Systems Branch Division of PWR I.icensing-A, NRR FROM: Vincent S. Noonan Director PWR Project Directorate No. 5 Division of PWR t.icensing-A, NRP
SUBJECT:
EVAL.UATION Of COMANCHE PEAK ISAP RESVI.TS REPORT ISAP No. VII.a.6 (Rev. 1)
Title:
Exit Interviews The plan for NRC review and evaluation of this ISAP Results Report is as outlined below. Section numbers refer to sections of the NRC evaluation to be produced by those persons identified below:
1.ead Project Manager: C. Trammell lead Technical Reviewer: C. Fale Section Title Person 1.0 Introduction C. Pale 2.0 CPRT Approach C. Pale 3.0 Evaluation 3.1 Evaluation of CPRT C. Pale Approach 3.2 Evaluation of ISAP C. Fale Implementation 4.0 Conclusion C. Pale O)u SJ ( ky@tt B'27
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1 Person IF contact as recuired: D. Workin Region IV contact as required: I. Barnes NRC Consultant: J. Malonson, Teleydne Schedule: (Date of receipt of report - November 19, 1086)
March 27, 1987:
Idertify any additional information needed to Copenche Peak lead pro.iect manager.
May 13, 1987:
Evaluation inputs as shown above completed and siened out by E. Rossi (NRR), E. Johnson (Region IV) and B. Grimes (IE) as appropriate.
Applicants ' Answers to Board's 14 Ouestions" will be distributed when received and should be reviewed in conjunction with this res report.
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Ving . No , r PWP ro.iect ' rectorate No. 5 D'ivision of R I.icensing-A cc: J. Keppler t.. Chandler !
P. Denton G. Mizuno J. Taylor R. Bachmann R. Vollmer A. Vietti-Cook R. Martin, R-IV T. Novak C. Tramell E. Rossi I. Parnes, R-IV G. Bagchi J. Scinto D. Jeng
- l. Shao D. Norkin J. Calvo J. E. Knight D t.anders, C. Hale i Teledyne C. Grimes !'
P. McKee l
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SAFETEAM March 26, 1987 .
March 25, 1987 March 11, 1987 February 24, 1987 February 9, 1987 DATE: February 2, 1987 TO: M. J. Gavin, Contract Administrator, SAFETEAM FROM: Gary Bailey, [ L4 J - 2 5 - g7 SAFETEAM Investigator
Subject:
Report for Concern #6269 S CONCERN Automatic Radiation Monitors (ARM's) and Portable Radiation Monitors (ARM's) were not located in the correct locations.
REPORT The N.R.C., during a youtine inspection in February of 1983, recommended several ARM's be relocated. After completion of the work, the N.R C. reinspected the location in Inspection Report 50-341/84-43 (closed) No. 341-83-03-01. The report states:
The inspectors verified during a plant tour that components of three area radiation monitoring systems he,d been relocated to optimize performance of their design function, in accordance with Engineering Design Package (EDP)1311, as described in Inspection Report 50-341/84-27. This included:
relocation of the detector for area radiation monitor (ARM)
N-109 located in the northeast corner room in the sub-basement of the reactor building; relocation of the beacon for ARM N-112 located in the tip room on the first floor of the reactor building;.and relocation of both the detector and beacon for ARM N-132 located near the blow-out panels on the first floor of the auxiliary building. This item is considered closed.
Regarding the current status of the ARM's system, SAFETEAM contacted the Supervisor Radiological Engineering. He stated that the Area Radiation Monitoring Systems (ARMS) are located per the commitments made to the NRC through the Final Safety Analysis Report (FSAR).
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i" REPORT 6269 9
'12.1.4.2 Criteria for Location A total of 48 monitors are provided at various locations inside the reactor, auxiliary, radwaste, service, on-site '
storage, and turbine _ buildings. The detectors are located in areas where:
- a. Personnel perform regular. duties in areas where radiation is present. These duties are performed once per day or more frequently
- b. Personnel perform infrequent duties, but where there is's high probability that significant changes in radiation levels could occur.
- c. Personnel perform infrequent duties, or where there is ,
a low probability that significant changes in radiation i levels could occur, but where surveillance is desired.
The general locations, ranges and alarms of the area monitors are given in Figures 12.1-11 and 12.1-12. The locations were chosen so that a clear indication of radiation levels and radiation trends in occupied areas are given. Figures 12.1-2 through 12.1-7 show these locations, which may be changed, based on operating experience.
SAFETEAM spoke with a Bealth Physics (HP) supervisor concerning locations of portable ARH's. He stated, two types of portable monitors are available on site for use. They are the Particulate Iodine Noble Gas Monitors (PING) and the Eberline A.H.S. 3 monitors. These monitors are used for information only monitoring, usually in areas where people are performing maintenance or outage work in the RCA. Their positions are determined by HP supervision to assure additional worker safety.
The use of these portable monitors is above and beyond Federal and site regulations governing radiation exposure limits. ;
Positioning is totally controlled by the HP department evaluations.
As the FSAR states, the ARMS locations are well thought out and engineered. Also stated is that changes can and will be made to ARMS as required by the continuous changing needs of the plant and personnel. At this time, all permanent ARMS devices are properly positioned in accordance with regulatory requirements, and approved by the NRC.
GB/dic NB Gavin comments incorporated into report.
NB Steering Committee comments incorporated into report.
NB Steering Committee comments incorporated into report.
NB Steering Committee comments incorporated from 3/11/87 review meeting.
NB Steering Committee comments incorporated from 3/26/87 review meeting.
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c 26, 1987 Mar'h '
SAFTT1EAM March.16,'1987 ,
'DATE: February 4, 1987
, TO: M. J. Gavin, Contract Administrator, SAFETEAM FRON: Joe Grohal$M"> 3-WB7 BAFETEAM Investigator Sub3ect: Reoort for Concern #6269 Q 00NCERN Numerous rejectable welds in and around the penetration seals were accepted by.QC inspectors under pressure and protest.
Later NDE " doctored" up x-rays of the welds so that document inspection and reviews would show acceptable welds.
REPORT The investigator has substantiated concerns of this nature have previously been investigated and addressed by SAFETEAM (reference SAFETEAM concerns #28 11-16-83, #441 1-23-84
'and concern #487 1-23-84).
Concern #441 addresses the concern of " doctored" up x-rays. In an attempt to radiogrcph the jet pump diffuser to adapter weld on jet pump positions #2, #7, #11, and #18. Oversize film was used l and e shop tailpipe to diffuser weld was also inadvertently radiographer. Upon developing the film, a decision to trim the unwanted portion was made. The inadvertently radiographer weld showed porosity. The Concernee states that the film was trimmed to' hide unacceptable welding. The welds inadvertently j radiograph 43 were performed in the shop by General Electric and required a dye penetrant and visual examination only. The shop welds met all requirements and it was inappropriate to impose RT acceptance criterion after the fact. To further assure acceptability of the welds in question, the licensee had the film read and evaluated using ASME Section III-1975. The report
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states that porosity exists on all views of the welds; however, the porosity is within acceptance standards. The NRC Inspector also evaluated the film and verified acceptability.
Investigation substantiated the alleged cutting of the film.
l This event is thoroughly identified in site NRC and SAFETEAM documents. Quality Assurance / Control has resolved and reviewed l
E all questions surrounding this event, including the acceptability of the porosity to_the applicable code. Based on the licensee's action, numerous Deviation Disposition Requests, Nonconformance Report 84-0759, 84-1113, and NRC inspection findings, this item is considered closed.
JG/dic l NB Steering Committee comments incorporated into report.
NB Steering Committee comments incorporated from 3/11/87 review meeting. .
NB Steering Committee comments incorporated from 3/26/87 review meeting.
.' March 26, 1987 March 12, 1987 DATE: February 4, 1987 TO: M. J. Gavin, Contract Administrator, SAFETEAM FROM: Paul Kubiak,;w1t 3
- ci SAFETEAM Investigator '
SubAect: Report for Concern #6269 K OONCERN Documentation which was rejected from the vault because of missing signatures and other defects was being falsified by personnel who sign other people's names and/or their own name without verifying the work was complete.
t REPORT In accordance with established procedures 11.000.49
" Document Control and Records Management," 11.000.135 " Nuclear Operations File Manual," and ISWI 00.40.69A " Vault Operations -
On Site," Information Systems personnel are only required to perform an administrative review upon the receipt of Quality Assurance records. The administrative review consists of ensuring the records are legible' and identifiable on the transmittal.
BAFETEAM interviewed the Supervisor of Information Systems, Supervisor - Records Management and the Document Control Work Leader. These individuals were in agreement that the administrative review was not intended to reject documentation on the basis of falsified signatures or other technical inadequacies of the records being transmitted to Information Systems.
Technical reviews are completed by the record originator before they are transmitted to Information Systems for vaulting.
PK/dle NB Steering Committee comments incorporated from 3/11/87 review meeting.
NB Steering Committee comments incorporated from 3/26/87 review meeting.
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February 19, 1987 -
DATE: February 6, 1987 TO: M. J . Gavin ,
Contract Administrator, SAFETEAM FROM: Joe Grohal,93D 3-z kr7 SAFETEAM Investigator
Subject:
Report'for Concern #6269 R OOHCERN Concernee expressed welding practices (i.e., down-hill welding, are strikes, improper repair techniques) were common place.
REPORT The investigator has found concerns of this nature have previously been investigated and addressed by SAFETEAM (reference SAFETEAM Concerns #118 12/15/83. W421 11/10/83, #203 5/12/83).
Concern #118 addresses in part the concern " backup on old welds is inadequate." This statement may once have been true but is no longer true. All of the old welds made prior to March 31, 1978 have been reinspected and tested to assure adequacy and quality.
The investigator contacted the Director Nuclear Quality Assurance who. expressed, as stated, this concern does not indicate unacceptable practice other than perhaps " improper repair techniques." " Downhill" welding is allowed by code and practiced in certain applications. " Arc strikes" can and do ocent when welding is being performed. The QA program and codes and standards applicable to Fermi safety related items provide for evaluation and repair or rework of are strikes when it is determined that their presence and magnitude are detrimental.
Any and all repair techniques associated with safety related items are approved by persons with technical competency and authority to do so. Implementation of approved repair to welds and are strikes are subject to inspection by qualified and, where required, certified, independent personnel.
The Director NQA concluded, as was the case with other concerns. l safety related welding activities at Fermi are subject to audit, l surveillance and inspection by the Detroit Edison Quality Assurance organization and other third parties such as the Authorized Nuclear Inspector, NRC, etc. The results of these overview activities do not support the concern that poor welding practices were " common place."
L JG/dle l
NB Steering Committee comments incorporated into report. l l
NB Steering Committee comments incorporated from 3/11/87 review meeting.
NB Steering Committee comments incorporated from 3/26/87 review meeting.
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March 26, 1987 $AFETEAM March 13, 1987 ,
February 19, 1987 - -
1 DATE:. February 7, 1987 -
TO: H.'J. Gavin, Contract Administrator, SAFETEAM ,
FROM: Gary Bailey, d L,8, 3-tC't7 SAFETEAM Investi, gator
Subject:
Report for Concern #6269 H CONCERN The vent monitor system in the On-Site Storage Facility roof was not properly installed or connected.
A REPORT SAFETEAM contacted the Supervisor Radiological Engineering regarding this allegation. He stated that low level ,
l' solid radioactive waste is stored in the On-Site Storage l Facility. Although the building is Non-Q (non-safety related),
periodic surveillance is maintained on the ventilation exhaust radiation monitor.
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Channel checks are performed on the Noble Gas Activity Monitor and the Sampler Flow Rate Monitor daily. The Iodine Sampler and Particulate Sampler have weekly surveillance. Source checks are l performed every 4 weeks and function test every 13 weeks. The !
system is calibrated every 78 weeks. j SAFETEAM obtained surveillance and calibration results performed on the vent monitoring system dated in 1985 and 1986. Random selections were reviewed. Only 2 of these tests had minor discrepancies. PN-21's were generated to resolve these discrepancies. The remainder of the tests were acceptable.
Since the system is Non-Q, construction records are kept only for completeness. The Ventilation Exhaust Radiation Monitor in the On-Site Storage Facility has been performing quite efficiently the last 2 years. Constant surveillance is required by the FSAR to assure effective monitoring of exhaust ventilation in the future.
GB/dic NB Steering Committee comments incorporated into report.
NB Steering Committee comments incorporated from 3/11/87 review meeting.
NB Steering Committee comments incorporated f rom 3/26/87 review meeting.
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,j. l l March 26, 1987 mg March 25, 1987 . -
DATE: February 7, 1987 '
l TO: M. J. Gavin, Contract Admi.nistrator, SAFETEAM ,
1 FROM: Judy S. Salajan,. i SAFETEAM Investig%. & tor 3 -14.P 7
]
Subject:
Report _for Concern #8269 AA i
CONCERN There was frequent cheating on qualification tests by Quality Control Inspectors. {.
l REPORT The qualification and certification of inspection personnel associated with Fermi 2 are subject to audit, surveillance, and inspection by the Detroit Edison Quality Assurance Organization and third parties such as the Nuclear Regulatory Commission. These overview functions have not identified the subject of this concern.
A review of BAFETEAM files identified several concerns that are related to qualification of QC Inspectors. Only one could be interpreted as cheating on a qualification test. This concern
(#120 C) and response states:
concern: Re QC...anyone can be insp., there should be a standard training program, but Comstock has none, test is a joke (to get certified) true-false, and a few fill-ins for ,
which they give answers on a card). Thinks this program 1 might do some good. ,
response: Personnel who are hired into the L. K. Comstock organization as potential quality control inspectors are placed in a standard training program prior to being certified as a QC inspector. They are provided with manuals, specifications and codes pertaining to their inspection specialty. Additional on-the-job training is also provided prior to certification. There is no timetable for the individual to become proficient enough to take the certification test. It is done on the individual' own ability, and only when they feel that they are ready to attempt the certification test, will it be administered.
Testing is done on an individual basis with only the QC supervisor and the candidate present. After the testing is completed, the candidate has the opportunity to discuss any questions, whether they were answered correctly or not. At Page 1 of 2 e
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REPCRT 6269 AA no time are answers provided prior to testing. The tests are revised periodically based on the number of people who have received that particular set of questions in a specified field.
At the time of this investigation, the Detroit Edison supervisor overseeing the LKC QC operation and the LKC QC manager found no problem whatsoever in the qualification area. In addition, the SAFETEAM contracted five former.L.
K. Comstock Quality Control inspectors who have left the project within the last six months. The unanimous statement was that it was a very good training program, far superior to the companies and projects they are presently affiliated with. At no time were they ever given answers to any test or qualification portion of the program.
In conclusion, no objective evidence was found to substantiate this concern.
JBS/dic NB Steering Cormittee comments incorporated from 3/11/87 review meeting.
NB Steering Committee comments incorporated from 3/26/87 review meeting.
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March 26, 1987 m March 16, 1987 DATE: February 9, 1987 j TO: M. J. Gavin, Contract Administrator, SAFETEAM FROM: Phillip N. Cagle, yttN !
SAFETEAM Investi stor l i
Subject:
Retort'for Concern #6269 W l
CONCERN Radioactive waste systems and/or the waste disposal )
systems were not built to procedures. i t
REPORT SAFETEAM has previously addressed this area of concern. l The prior concern stated that six rooms in the Radwaste building )
were constructed without fully complying to Procedure 3.21 1 (DCR's). There was no prior Engineering approval.
The Walbridge-Aldinger Company was contracted to do this project and to also supply Field Engineering with as-built drawings upon j completion of the work. A Subcontract Release was reviewed and 1 authorized by appropriate personnel. l l
It should be noted that the Radwaste building is outside the i scope of the Fermi 2 procedures (because it is Non-Q) as defined i by QAP-1, Revision 6, Section 1.5.6.1. Per the Final Safety j Analysis Report (FSAR) Chapter 3, Section 3.2.1 and project Q list there are no QA level 1 systems contained in the Radwaste complex.
In a written response to SAFETEAM from the Director of Nuclear ,
Quality Assurance the following was stated: In reviewing PPM l 3.21 provision is given to commence construction without approved change paper under certain conditions. These conditions are:
Per Section 4.9 " Construction or maintenance work may be expedited before final approval of the DCR. However, no work can proceed without Edison's verbal concurrence, except in the Radwaste and On Site Storage buildings." Per Section 5.6 "the construction representative who gives authority for work to .
Proceed can allow work to proceed without requesting Edison's concurrence only on Type II DCR's in the Radwaste and On Site Storage buildings." Per Section 4.8 of PPM 3.21, Revision 7 the i subject additions to the Radwaste building would be Type II DCR's.
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REPORT 6269 W On August 3,1984 the Radwaste building (Startup System V21-000) was transferred from SCO's jurisdiction to the jurisdiction of Nuclear Operations. As a result of this transfer any further changes made to the Radwaste complex must be accomplished via an Engineering Design Package (EDP) per POM 12.000.64, or via a Field Configuration Change Package (FCCP) per POM 12.000.79.
Both of these procedures require prior approval of at least Nuclear Engineering for EDP's or the Technical Engineer in the case of FCCP's. Furthermore, Nuclear Operations' commitment to quality and configuration control is documented in NOP-115
" Configuration Management Program" and further manifested by the creation of the Management Control Board (NOP-301).
The additional rooms have been addressed on As-Built Notice 3656-1, Revision D. Engineering has reviewed and approved these rooms. The affected drawings have also been updated to incorporate the new configurations.
In conclusion, this is the only concern that SAFETEAM was able to identify in the Radwaste area.
PNC/dic NB Steering Committee comments incorporated from 3/11/87 review meeting.
NB Steering Committee comments incorporated from 3/26/87 review meeting.
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Much 26, 1987 uFETu u March 18, 1987 .
DATE: February 9, 1987 TO: M. J. Gavin, -
Contract Administrator, SAFETEAM FROM: Phillip N. Cagle, 3 & 8 *7 SAFETEAM Investig tor Sub3ect: Eeuort for Concern #6269 O CONCERN There are numerous material traceability deficiencies that were improperly resolved in the field and not recorded on Nonconformance Reports for resolution.
REPORT SAFETEAM contacted the Director of Nuclear Quality j Assurance with this concern. The Director stated that materials I used for construction or repair of safety related items were !
subject to either source, receipt, and/or field inspectior by l qualified and certified independent personnel. These activities l are conducted to verify conformance with established technical requirements. Any deficiencies identified, either during the source, receipt, or field inspection activities, were required to be identified and controlled to prevent their inadvertent installation or use.
In addition, material associated with safety related pressure boundaries were subject to specific material traceability requirements which were verified by organizations responsible for their installation or use and were subject to overview by the Detroit Edison cuality Assurance Organization prior to acceptance of the installed system for use.
The audit, surveillance, and inspection programs, including Nuclear Quality Assurance, Nuclear Regulatory Commission personnel and other third parties, have provisions to address the -
subject.of control of procured items. Any deficiency'of a programmatic nature would have been identified through these activities and resolved. No significant program deficiency has been identified in this area.
SAFETEAM also contacted a responsible person in the Nuclear Quality Assurance auditing group. RHe stated audits are performed every two years to ensure material traceability is being maintained. Material control is an ongoing audit line item.,
PNC/dle NB Steering Committee comments incorporated from 3/11/87 review meeting.
NB Steering Committee comments incorporated from 3/26/87 review meeting.
Sb1
. March 13, 1987 i carrecau j DATE: February 10, 1987 {
M. J. Gavin, I TO: ;
Contract Administrator, SAFETEAM 1 FROM: Mike Porsche,M P 3~#6~#7 l SAFETEAM Investigator Subiect: Report for Concern #6269 B CONCERN The anchor bolts and tray supports in the Q and N cable tray rooms are severely damaged, however, the problem was improper 3y dispositioned "use as is."
REPORT SAFETEAM talked with Lead Engineer Arch / Civil and the Supervisor - Mechanical / Civil Projects and Plant Engineering.
They stated during construction Field Engineering - Arch / Civil received numerous DDR's and NCR's documenting problems with cable tray hangers in the "Queenie" and Nancy" areas of the plant (cable spread room and relay room, respectively).
These documents were reviewed individually by Project & Plant Engineering to determine a proper disposition. Many of the dispositions stated "use as is." These dispositions were based on technical justifications stated in the Nonconformance document. This process assured that the nonconformance was resolved and that the deviation would not affect the ability of the hangers or anchorages to resist the design basis loads during the life of'the plant.
BAFETEAM has investigated your allegation and has determined that since it is general in nature, SAFETEAM would have to have some specific information to carry this any further.
MP/dic <
NB Steering Committee comments incorporated from 3/11/87 review '
meeting.
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' February' 24, 1987 DATE: February 10, 1987 TO: M. J. Gavin, Contract Administrator, BAFETEAM FROM: Paul.Kubiak,Rs* usy SAFETEAM Investigator Sub3ect: Reoort for Concern #6269 J CONCERN Document control and protection measures were consistently ignored during the final stages of construction resulting in large amounts of missing, lost or destroyed documentation.
REPORT During the final stages of construction, Management Analysis Company (MAC) conducted an independent third party audit for Detroit Edison-Company. The purpose of this audit was to-assess the effectiveness of the QA program's implementation, as evidenced in the quality records that have been generated over the course of the project. The audit was conducted from February 27, 1984 through April 13, 1984. MAC performed the audit by reviewing the Detroit Edison Company commitments as defined in the FSAR and the QA Program Manual; by defining a population ,
against which samples of ~ quality documentation could be selected; j by selecting a ~ random sample of procurement and installation document packages; by selectively biasing the samples to include a review of the documentation for the Core Spray System; by reviewing quality documentation against the requirements for documents in QA' manuals, procedures, purchase orders and vendor document lists; and by reviewing documentation of corrective measures. The MAC audit identified a number of findings and made several recommendations. . For tracking purposes the findings were given the audit number A-QS-P-84-23. The recommendations were
, transcribed verbatim onto Quality Surveillance Reports. These actions are documented in site letters QA-84-1830 and QA-84-1833. !
The MAC audit concluded by stating, "An adequate QA program was and is in place at Fermi 2. This is evidenced by the presence of adequate work instructions and inspection procedures and the fact that quality documentation audited is generally acceptable."
l-L Subsequent to the MAC audit, the Duke Power Company performed the Independent Final Construction Assessment of Fermi 2 during the period of June 4, 1984 through July 13, 1984. All critical. parts of the plant were covered as described in the assessment plan which was submitted to Detroit Edison Company and the US NRC prior to the audit. This audit is referred to as the CAT audit.
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.. .G REPORT 6269 J The CAT team made a review of the MAC audit as part of the overall program to determine the readiness for operation of Fermi
- 2. All the records which the CAT team seJ ected for review were found. Although it was noted that records retrievability of some records was slow, the CAT report identified that, "The records appeared to be complete and accurate. No errors or missing records were identified." The CAT report identified that the MAC audit apparently did a complete and comprehensive audit of the records. It was also noted in the MAC report that they had some problems with rec'ords retrievability, but once the records were found, they appeared to be complete and accurate. The CAT report concluded if Detroit Edison acts upon all the recommendations made by the MAC audit, the records for Fermi 2 should be at an acceptable level.
SAFETEAM verified closure of the audit findings and surveillance reports.
Quality Assurance Audits A-QS-P-86-03, A-QS-P-85-24 and A-QS-P-84-25 conducted af ter the CAT audit addressed several :
different areas of Information Systems. These audits did not specifically identify problems of missing lost or destroyed ,
documentation.
PK/dle NB Steering Committee comments incorporated into report.
NB Steering Committee comments incorporated from 3/11/87 review meeting.
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March 26, 1987 Fobruary 18, 1987 DATE: February 11, 1987 9
TO: M. J. Gavin, Contract Administrator, SAFETEAM FROM: Gary Bailey, 6,l.6 3 ~ 2 4~ ~ 87 SAFETEAM Investigator i
Subject:
Report for Concern #6269 I -
CONCERN Calibration and certification of certain pieces of '
health physics test equipment was not done properly, but no corrective action was taken: (
- c. Multimeter (TEK), 5017 serial #B029542.
- d. Main frame (LEK) TM504 serial #B0314.
- e. Power Supply (TEK) PS 501-1 serial #B056021. ] >
- f. Vacuum Tube Voltmeter (B&K) VL11-177 serial #E21160.
g.
Electro Static Voltmeters EISD-710 serial #ES-12653.
ESD-7x serial #ES-12469.
- h. Flukes 8021 B serial #2775316, 8021 B serial #3045323.
- i. Oscilloscope (TEK) 455 serial #B072395.
EEEDRI SAFETEAM contacted the RadChem Engineer from Radiological Engineering, regarding this allegation.
The records for the test equipment described in the concern were traced back to the date of purchase which in all cases was during )
or before 1982. All of the test equipment were certified by the !
original manufacturers or a representative in accordance to l manufacturer's specifications. The test equipment is maintained in conpliance with POM Procedure 61.000.40 (General QC for Health Physics Measuring and Test Equipment) which is a safety related procedure. Our records provide complete calibration information from 1983 to present for the equipment in the concern with the exception of the following:
The Flukes digital voltmeter, 8021 B, SN2775316, was retired in 1984. The Eberline Electronic Pulser MP-1, SN588 is on loan for use by the training group and is not used for calibrated purposes.
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REPORT 6269 I A similar allegation was reviewed by NRC Inspectors in April, 1986, and their 6/4/86 report found, "The allegation was not l substantiated."
In summary, we are unable to validate any existing violations associated with this allegation.
GB/dle NB Gavin comments incorporated into report.
NB Steering Committee comments incorporated from 3/26/87 review meeting.
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Mar'ch 13, 1987 March 4, 1987 SA N l DATE: February 12,-1987 ,
i TO: Mike Gavin, Contract Administrator FROM: Paul Kubiak,pcst.uc 3
SAFETEAM Investigator
SUBJECT:
Reeort for Concern #6269 P OONCERN Significant amounts of the electrical cable pulling work was done using unapproved design drawings, resulting in separation violations and other indeterminate conditions in the ,
1 electrical area.
REPORT SAFETEAM referred this concern to the Acting Supervisor, Electrical / Instrumentation and Control, Projects & l Plant Engineering (P&PE). P&PE stated the cables which were !
necessary for the continual operations, status, and maintenance of the, plant have been installed utilizing approved cable p'ull cards specifying their routes, not design drawings. These cable !
cards require approved design documentation and/or approved work packages. Cable which is designated for use under the cable pull card system is completely traceable for all of its areas of use. !
The adequacy of the current and past policies, practices, and I procedures have successfully passed audits by the NRC, Duke Power l Construction Assessment Team (CAT Team) and the Quality Assurance Organizations.
BAFETEAM verified electrical installations have successfully j passed audit by Duke Power Construction Assessment Team (CAT !
Team), the NRC and the Quality Assurance Department. The Duke )
Power Company Construction Assessment Team conducted their audit during the period of June 1984 through aid July 1984. The assessment was primarily on hardware with a limited review of records in certain defined areas. The assessment led to 24 recommendations. Detroit Edison's responses to these recommendations are identified in " Fermi 2 Response to Recommendations From the Duke Power Company Final Assessment of Construction." BAFETEAM contacted Licensing to determine which NRC inspections were applicable to this concern. Licensing identified six NRC inspections which addressed electrical installations. BAFETEAM then verified that all six NRC reports have been closed out. BAFETEAM then reviewed the Detroit Edison l Fermi 2 Integrated Document Tracking Open NQA Findings Report i j
dated 2/9/87. No items addressing cable separation or other indeterminate conditions in the electrical area were observed. l I
PK/dic
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NB Steering Committee comments incorporated into report.
l NB Steering Committee comments incorporated from 3/11/87 review l
meeting.
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- Maich 26, 1987 umu .
' March 20, 1987 March 5 1987 DATE: February 13, 1987 TO: .
M. J. Gavin, Contract Administrator, SAFETEAM FROM: Gary Bailey, SAFETEAM Investigator Subiect: Report for Concern #6269 N CONCERN Startup testing was done' in a manner which ignored the step-by-step procedures including hold points that did not comply with quality requirements and did not record the system failures on controlled documentation (NCR's, etc.).
l EEPORT SAFETEAM gathered information regarding this allegation l from various external, independent inspection groups including numerous NRC reports, and from QA internal' audits.
' Two Quality Assurance audits were reviewed by SAFETEAM. Report WA-QS-P-85-26 was titled " Quality Assurance Audit of Startup Test Results Packages." The scope of the audit was to verify the adequacy and implementation of the Startup Test Results Package Preparation and Reviews. The process included review of procedure implementation and records related to the Startup Test Results Packages. The procedural requirements used to formulate the checklist were derived from POM 12.000.91T, Revision 0, " Test Results Packages Preparation / Review."
The Test Result Packages are utilized by the S/U Engineer and On Site Review Organization to evaluate and resolve any testing problems encountered, and to aid in the review process then determining if systems are ready for operation by Nuclear Production. i During this portion of the audit, interviews were conducted with four Plant Support Engineers, one Lead Plant Support Engineer, i and the Technical Administrative Coordinator relative to their procedural responsibilities in conjunction with the following four then uncompleted systems:
- 1. Radwaste/HVAC (V41)
- 2. Offgas (N62)
- 3. Traversing incore Probe (C5116)
- 4. Circulating Water Natural Draft Cooling Towers (W2500)
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. REPORT 6269 H During the audit, the four then uncompleted packages were reviewed in process during various stages of completion and the cognizant personnel were noted to be performing their duties and carrying out their responsibilities as required by procedure.
The audit disclosed that the implementation of POM12.000.91T is satisfactory in all of the areas audited. There were no audit findings or observations documented.
The responsibilities of personnel during various stages of test results package preparation were noted to be carried out as required.
The second audit reviewed by SAFETEAM was titled "Startup Reporting of Testing Incidents and Experiences." The scope of this audit included the manner in which Startup controls the reporting of Test Incidents and Experiences.
The Startup Director /Startup Engineer is responsible for ensuring the timely preparation of Incident and Experience Reports, assigns Action Items as required, specifies additional distribution of reports, reviews all reports for proper and adequate corrective action, and determines whether the experience / incident should be scheduled as a Test Review Committee (TRC) agenda item.
A review of 36 Experience Reports issued between 1983 and 1984 and of the only Incident Report (83-04A) processed during the same period revealed that all personnel were performing their duties as required by SI 7.6.4.01. Reports were being issued, i reviews performed, signatures applied, adequate distribution was being made, and appropriate actions were taken as required.
The audit disclosed that the implementation of SI 7.6.4.01, Revision 6, is satisfactory. No Audit Finding Reports (AFR's) were issued as a result of the audit.
BAFETEAM spoke with the Director of Nuclear Quality Assurance regarding " ignored" Start-up Pre-Op hold points. He stated: The Detroit Edison QA organization conducted an extensive overview of safety related testing, including audits and surveillance of the ;
testing program, and participated in the review of test I procedures and completed test packages. I In addition, a review of QA organization records for audits and surveillance findings for this time period (assumed to be 1983 and 1984) did not identify a frequency of missed or by-passed QA Hold Points associated with testing, which would indicate that a significant problem existed.
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REPORT 6269 N -
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'l The overview and participation by the QA organization and review 4 of findings for the period noted above led QA to the conclusion i that inadvertently missed hold points would not have a '
significant affect on the quality of testing activities.
BAFETEAM reviewed the Construction Assessment Team (CAT)
Evaluation of Fermi 2, however an evaluation of areas specifically involving this allegation was not performed.
In addition, eleven NRC Inspection Reports relating to the allegation were reviewed by SAFETEAM. To reproduce all the notices of violations produced by the NRC and Detroit Edison's response to these violations would prolong this report beyond it's summarized intent. Below is a list of all NRC Inspection Reports used in this response:
NRC Inspection Report Numbers
- 84-21-04 884-11-04 884-28-01 #84-28-02 #84-29-01
- 84-29-02 884-30-01 #84-36-01 #84-36-02 #84-36-09 ,
- 84-37-01 In reviewing the NRC Inspections many reports were acceptable; others identified discrepancies.- These various discrepancies were identified to Detroit Edison concerning Startup and Pre-Operation adherence to procedures and identification of deficiencies and deviations. Any violations which required a written response from Detroit Edison have since been addressed and closed. Most required corrective action to be taken. All of the " Actions to be Taken" have been implemented. Full details of these inspection can be found in the referenced NRC Reports above.
In summary, Startup and Pre-Operation violations of the
" reporting of failures" and "the following of quality requirements" have long been identified and acceptably resolved.
GB/dle NB Steering Committee comments incorporated into report.
NB Steering Committee comments incorporated from 3/26/87 review meeting.
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March 26, 1987 EAFETEARE ;
l March 13, 1987- ,
March 2, 1987 February 25, 1987 l DATE: February 13, 1987 i
TO: Mike Gavin, Contract Administrator FROM: Paul Kubiak, m en,,
SAFETEAM Investigator 4
SUBJECT:
Recort for Concern #6269 F i CONCERN The number of cut or severed rebar resulting from anchor placement throughout the plant indicates that FSAR commitments are not being met. ,
REPORT Corrective Action Request CAR-84-008 identified a deficient condition in the control of cutting reinforcing steel.
After reviewing Nonconformance Reports, audit findings, surveillance findings and a 10CFR50.55(e) report, Quality Assurance determined an adverse , trend existed and CAR-84-008 was issued on November 7, 1984. ,
Site Letter NM-85-260 dated August 9,1985 describes how engineering resolved the deficient condition identified in CAR-84-008. As a result of this CAR, Nuclear Engineering performed an evaluation of each contractor's process f or cutting rebar. It was determined 1323 possible reporting discrepancies existed. The evaluation resolved 1279 (97%) of these reporting discrepancies with'no adverse impact on the structural integrity of any structure. The status of the remaining 44 possible reporting discrepancies (3%) was indeterminate. Engineering could not verify that the 44 reports were ever written.
Evaluation of the corresponding structural calculations, and given results of past evaluations of cut rebar reports, Nuclear Engineering concluded the possible 44 reporting discrepancies would not have an adverse impact on the structural integrity of the involved structures.
In order to prevent recurrence of the same problem, procedure 38.000.02, " Wedge Anchor Installation, Removal, and Repair," and procedure 38.000.12, " Concrete Coring Procedure" were initiated.
They replaced old procedures and required the cut rebar request to be returned to engineering for prompt evaluation. This was combined with consulting the design engineer before cutting rebar. The Design Engineer will assess the impact of the report in conjunction with all other cut rebar reports on file. This l
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new system and the actions taken by engineering will ensure that the adequacy of the reinforced concrete structures will not be compromised.
The 10CFR50.55(e) report which was addressed in CAR-84-008 was tracked by the US NRC as item #341/79-12-EE. This item i identified a design deficiency report on reduced reactor j auxiliary building floor and capacity because of cut rebars due to anchor installations effecting structural integrity. These j floor slabs were analyzed by design engineering. All slabs were i found to be capable of supporting the original design load except )
the 4" roof slabs at elevation 697'-6". These slabs were reinforced in accordance with construction drawing 6C721-2350, Revision O. The closure of this 50.55(e) is identified in US NRC Inspection Report #50-341/83-19(DE), dated September 12, 1983.
PK/dle NB Gavin comments incorporated into report.
NB Gavin comments incorporated into report.
NB Steering Committee comments incorporated from 3/11/87 review meeting.
NB Steering Committee comments incorporated from 3/26/87 review meeting Page 2 of 2
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," March 28, 1987 sAFETEAu March 13, 1987 DATE: February 18, 1987 To: M. J. Gavin, Contract Administrator, SAFETEAM l FROM: JudyS.Salajan,Q'1"#f7 SAFETEAM Investigator I
Subject:
Reeort for Concern #6269 2 l
CONCERN Management in operation and construction of Fermi 2 facility shows little managerial integrity and consistently shows
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signs of breakdown. i I
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REPORT Fermi 2 management consistently got high marks from the NRC for.the construction of the plant. According to their most recent letter, approval was granted to operate the plant up to 50% power. Fermi 2 continues to get good comments on the management and operation of the plant.
The operational performance of Fermi management is judged by several groups, including Detroit Edison's Board of Directors, the NRC. The NRC's comments are a matter of public record and i available for your review. The Detroit Edison Board of Directors (
review the performance of the plant on a monthly basis.
JSS/dle HB Steering Committee comments incorporated from 3/11/87 review meeting.
NB Steering Committee comments incorporated from 3/26/87 review meeting.
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I M2rch 26, 1987 l
March 11, 1987 i February 20, 1987 DATE: February 18, 1987 TO: M. J. Gavin, Contract Administrator, SAFETEAM FROM: Gary Bailey, 6,4,5 .3-26-87 SAFETEAM Investigator
Subject:
Renort for Concern #6269 T CONCERN Detection instruments do not function in numerous areas, in some instances, resulting from poor engineering design on location.
REPORT SAFETEAM contacted the System Engineer who worked with the microwave installations regarding this allegation.
The microwave detection system is one of several security systems in the protected area of the plant. Because this system is safeguarded only general statements can be used in the response.
Procedures will be referenced where complete detailed information can be obtained on a "need to know" basis.
The microwave detection system functions along the perimeter of the protected area. Stringent sensitivity tests are constantly being performed on the microwave system per Security Procedure Implementation Plan 14.
The System Engineer stated the microwave system works quite well now. In the past a problem with this system was encountered in the area of Warehouse B and Building 44.
The microwave system is designed to be used in the open. It was not designed to be used near buildings or other structures.
Unfortunately because of the layout of the protected area, Engineering was required to install the microwave detectors along 1 the length of Warehouse B and up over Building 44. Originally i Building 44 was intended to be temporary.
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The microwave system had to be used in various configurations for which it was not designed. Because of this, research and development time became lengthy.
As the system stands, it now covers most of the length of Warehouse B, across part of the roof on Warehouse B, and over the l roof on Building 44. Precautions had to be engineered into the Page 1 of 2 1
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.' REPORT 6269 T 'l i
system to prevent water, ice and snow from splashing on the {
buildings as well as actual building expansion and contraction setting off false alarms.
All details and drawings for this project are contained in DCP 1855. The entire project took approximately 1 1/2 years to complete ending in June 1986. The system is now completely )
functional and meets all federal and site regulations and l requirements. l l
GB/dle j l
NB Gavin comments incorporated into report.
NB Steering Committee comments incorporated into report.
NB Steering Committee comments incorporated from 3/26/87 review meeting.
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. March 26, 1987 SAFETEAM
. March 19, 1987 f 1 ',
DATE: February 19, 1987 ,
TO: M. J. Gavin, Contract Administrator, SAFETEAM ,
FROM: Judy S. Salajan, % . 5 2G-F7 l SAFETEAM Investigator Subiect: Reoort for Concern #B269 Y !
I OONCERN Floor drains around the containment are faulty, allowing for leaks of_the radioactive water into Lake Erie. No original blueprints of the floor drain system could be located.
REPORT SAFETEAM obtained information regarding this concern i from RadChem Engineering. The floor and equipment drains for the basement and first floor of the reactor containment building and auxiliary building are located on blueprint #7H721-2219. Two drains in the rail car airlock discharge to the storm-sewer system and associated piping are shown on prints 6M721-2741,
" Storm Sewer System Diagram-Unit No. 2" and 6M721-2125, " Yard Piping-Plot No. 1-Northeast Corner Unit No. 2."
RadChem Engineering informed SAFETEAM that last December RadChem personnel recognized that these two drains in the rail / truck airlock posed a potential release path from secondary containment in light of the fact that Technical Specifications require only one of the two sets of the airlock doors remain closed. A drawdown test proved these drains do not pose a secondary containment violation. However, the drains were temporarily plugged and Deviation Event Report 86-224 dated January 16, 1987 l was prepared to initiate engineering evaluation and permanent l corrective action. !
A task force composed of specialists from the Engineering, Maintenance, Operations, RadChem, and Training groups has been established under the auspices of radiation chemistry to study j all release pathways. A report from the task force is expected to be complete in the second quarter of 1987. !
JSS/dle NB Gavin comments incorporated into report.
NB Steering Committee comments incorporated from 3/26/87 review i l meeting. l l
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r March 13, 1987 SAFETEAM DATE: February 21, 1987 To: M. J. Gavin, ~
Contract Administrator, SAFETEAM FROM: Paul Kubiak,wt3.u.n SAFETEAM Investigator subject: Report for Concern #8269 G CONCERN Access to the turbine crane is unrestricted from a radiological perspective.
I-REPORT This concern was referred to the RadChem Engineer. He responded by identifying at the present time, access to the . j Turbine building crane is not restricted because there is no radiation hazard associated with operation of the crane. The turbine and the steam reheaters are surveyed on a weekly basis or
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after a power increase in accordance with Procedure 63.000.10,
" Radiological Survey Techniques." If the area should be classified as a radiation area, it will be posted as required by ,
Procedure 61.000.15, " Health Physics Postihg."
Up until now this area has not been a radiation area and crane access has not been restricted. Should the area become a .
radiation area, the stairway to the crane will be posted and access controlled by Health Physics in accordance with procedures. If the space above the turbine should become a high radiation area, additional controls will be established. Should levels reach one (1) R/hr in the general area, a locked gate will be installed on the stairway.
PK/dle NB Steering Committee comments incorporated from 3/11/87 review meeting.
B47
DATE: February 23, 1987 gaprnguW
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TO: M. J. Gavin, Contract Administrator, SAFETEAM FROM: PhillipN.Cagle,MgS )
SAFETEAM Investigator
Subject:
Report for Concern #6269 U l
CONCERN Radioactive materials have not been handled according to the NRC's requirements of 10CFR20.205.
REPORT SAFETEAM interpreted the concern to be in direct correlation with the loss of several bug sources. Because the concern was not specified, SAFETEAM has addressed the loss of the bug sources.
SAFETEAM contacted the Director of the Rad Protection Group, Robert R. Eberhardt, with this concern. The Rad Protection Group {
responded with a written response that states: i Seven (7) small radioactive sources (six were 9 microcuries at the maximum and one was 22 millicuries) could not be accounted for in the month of June 1983. Investigations by the RadPro Department revealed that six sources were included in a January 10, 1983 radwaste shipment without i specific references to the sources in the shipping papers.
The seventh source was in a radwaste drum but had not yet been shipped. The matter was reported to the NRC on June 7, 1983. In their review the NRC Inspector found that, "The problem apparently originated from a f ailure to transpose all information from the record of contents maintained on the waste barrel." In his report of November 23, 1983 (50-341/83-26) the Inspector also noted that actions had been taken to prevent a recurrence.
The corrective actions taken in 1983 were reviewed by NRC Inspecbors on June 4, 1986. They found that:
' Procedure 67.000.21, Accountability of Radioactive Sources, has been strengthened so that 100% inventory of licensed sources is required every six months and verification of five percent of these inventories is made by the Health Physics Supervisor-Operations. The latest radioactive source inventory indicates all 204 licensed sources are accounted for. The Inspector reviewed selected procedures to ensure there was adequate control and accountability of radioactive sources. No problems were found."
PNC/dle J