ML20080S237
| ML20080S237 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 02/09/1984 |
| From: | Wells D DETROIT EDISON CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20080S233 | List: |
| References | |
| QA-84-0081, QA-84-81, NUDOCS 8402280568 | |
| Download: ML20080S237 (14) | |
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N Donald A. Wells Myggegagy Ansurave lg
$}c 7"ls*22e February 9, 1984 OA-84-0081 Mr. C.E. Norelius, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Ccmnission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Amendment to Response on Noncompliances at Enrico-Fermi Unit 2 - IE Report 50-341/83-20
Dear Mr. Norelius:
This letter amends the previous response to the itens of noncanpli-ance described in your IE Report No. 50-341/83-20. This inspection of Enrico Fermi Unit 2 construction site activities was performed by Messrs. P.M. Byron and M.E. Parker on September 1-30, 1983.
The items of noncanpliance are discussed in this reply as required by Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
The enclosed amended responses are arranged to correspond to the sequence of itens cited in the body of your report. The number for the items of noncanpliance and the applicable criterion are referenced.
We trust this letter satisfactorily answers the concerns raised in your report. If you have questions, please contact Mr. G.M. Trahey, Assistant Director - Project Quality Assurance.
.Very truly yours, h e nV lR DAW /EHN/pn cc: Mr. Richard DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Cannission Washington, D.C.
20555 Mr. Paul Byron, Senior Resident Inspector U.S. Nuclear Regulatory Ccmnission 6450 North Dixie Highway-Newport, Michigan 48166 i 'l
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THE DEIROIT EDISON COMPANY PROJECT QUALITY ASSURANCE ENRICO FERMI 2 PROJECT Amended Response to NRC Report No. 50-341/83-20
' Docket No.' 50-341 License No. CPPR-87 Inspection at: Fermi 2 Site, Newport, Michigan
-Inspection Conducted: September 1-30, 1983 Approved by:
T.A. Alessi, Director Project Quality Assurance Date:
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Amended Response to NRC Inspection Report No. 50-341/83-20 i
l Statement of Nonecrnpliance, 33-20-01 10CFR50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instruction, procedures,'or drawings... and shall be accmplished in accordance-with these instructions, procedures, or drawings."
- DECO Startup Instruction 8.4.2.03, Supplanental Testing, Paragraph 4.3.2. requires prerequisites or precautions to be reverified after test stop/ restarts.to ensure the test may be resumed safely.
Contrary to the above, the inspectors observed on September 17,
'1983, that not all of the required prerequisites were reverified for
.the performance of Test Supplement #4,' dated September 14, 1983, of PREl'.C1100. 001..
Corrective Action Taken and Results Achieved Supplanental Test #5 was issued which provided a fomal signoff of Prerequisites 3.1, 3.2, 3.3, 3.4, 3.5, 3.7, 3.8, 3.9, 3.10, 3.11, 3.12, 3.13, 3.15, 3.16, 3.17 and 3.18.
This formal hverification of prerequisites was cmpleted on September 18, 1983, four days after Supplemental Test #4. All prerequisites were met as stated and were formally verified.
Corrective Action Taken to Avoid Further Noncampliance Startup Instruction S.I. 8.4.2.03, Supplemental 'Ibsting is being revised to require that all applicable prerequisites be verified prior to starting / restarting any supplemental testing.
Date When Full-Cmpliance hill be Achieved Startup will be in full empliance and training to all personnel will be accmplished by February 15, 1984. -
s-Amended Response to NRC Inspection Report No. 50-341/83-20 Statment of Nonempliance, 83-20-02a 10CFR50, Appendix B, Criterion VIII, states in part, " Measures shall be established for the identification and control of materials, parts, and cmponents... These measures shall assure that identifi-cation of the item is maintained... These identification and con-trol measures shall be designed to prevent the use of incorrect or defective material, parts, and cmponents."
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Section 4.7.2 of the DECO Startup Manual requires temporary nodifications contained in approved procedures to be tagged and recorded during periods extending beyond one shift.
Contrary to the above, the licensee's measures did not assure that identification was maintained. The inspectors observed approximately 15 determinated wires which were neither tagged nor identified in the HPCI Pump Rom, Relay Roms, and Remote Shutdown Panel during HPCI preoperational testing.
Corrective Action Taken and Results Achieved The following determinated wires were not tagged or identified in the HPCI Pump Rocm and Relay Rom.
Item #1 - HPCI condensate pump wires were determinated. The pump was physically removed by SCO by Punchlist card T0409 and sent off site to have motor leads extended by the vendor.
The pump was re-installed, electrically tenninated by Punchlist card T0155, and CAIO tested by 7.8 #3044E on October 22, 1983. There is no requirement for tmporary modification on equignent removed for construction / rework functions. This equignent was not involved in the por-tions of the preoperational test which were performed on that date. The work was listed in the " Test Release Package" as an exception.
Item #2 - HPCI vacuum pump wires were determinated. The pump was physically rmoved by SCO on Punchlist card T0409 and sent off site to have motor leads extended by the vendor. The vacuum pump was re-installed, electrically terminated by Punchlist card T0156, and CAIO tested by 7.8 #3044E on October 22, 1983. There is no requirement for temporary modification on equignent renoved for construction / rework functions. This equignent was not involved in the por-tions of the preoperational test which were performed on that date. The work was listed in the " Test Release Package" as an exception.
It s #3 - Two wires were.determinated in cabinet E4150-C002. Dis-crepancy was corrected via NCR #83-896 and Punchlist card T0169 which reoved the wires of concern. ________
Amended Response to NRC Inspection Report No. 50-341/83-20 Corrective Action Taken and Results Achieved, 83-20-02a (cont'd)
Item #4 - Exposed thermocouple wires from electrical cabinet E41-C002.. Discrepancy was corrected via NCR #83-896 and Punchlist card T0169. Thermocouples were not involved in tn portions of the preoperational test being perfonned at that time.
Item #5 - Two wires in panel Hil-P620 were determinated. Cables were found to be spare cables and tagged as such on the night of-September 16, 1983.
Item #6 - HPCI flow controller on Div. II Remote Shutdown Panel was disconnected. The flow controller is scoped to the C3500 system and was not involved in any portion of the E4100 preoperational test. The cables have been reconnected.
Corrective Action Taken to Avoid Further Monecupliance Revision 2 to Interim Temporary Modification Procedure 12.000.25T, approved Nov mber 22, 1983, was written to address identification and tagging of lifted wires / leads. This revision provides a lifted wire control sheet and provides identification of wires / leads by a yellow information tag. It can be noted that Revision 2 to 12.000.25T was being prepared at.the time this noncampliance was identified and was not a result of this finding.
PPM Procedure 7.27 " Project Housekeeping", Revision 1 was issued January 30, 1984. This revision has included the requirement that all determinated electrical wiring shall be tagged for identifica-tion and jurisdiction. This procedure applies to all site contrac-tors. In addition, SCO Procedure 13.1 " Surveillance Coordination" was issued January 26, 1984, and requires Project Complation Organi-zation (PCO) inspectors to perform surveillances to ensure ccmpli-ance with the tagging requirements in PPM 7.27.
Date When Full Ccmpliance Will be Achieved Full ccmpliance has been achieved..______
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Amended Response to NRC Inspection Report No. 50-341/83-20 Statement of Nonempliance, 83-20-02b DECO Quality Assurance Procedure 8.0.1 states, " Written procedures shall be implemented for identification and control of material, parts, and cmponents to assure use or installation of correct and accepted items only."
- Contrary to the above, on September 7,1983, the inspectors observed
~ three wire baskets which contained Balance of Plant and DA Ievel 1 (Divisions 1 and 2) cable. - None of the baskets or cable was identi-fled,' with the exception of three cables taped together with a scrap tag. The baskets were located outside the DECO Electrical Warehouse and were among many covered wooden boxes which were being stored.
Corrective Action Taken and Results Achieved The specific baskets in question were tagged as having scrap material.
Corrective Action Taken to Avoid Further Noncmpliance Procedure'12.000.55 has been trodified to indicate that all scrap containers should be clearly labeled " Scrap - Not for Plant Use."
. All Nuclear Procurement warehouse personnel have been notified of this requirment.
In addition, PPM Procedure 7.27 " Project Housekeeping" has been revised to be more specific in housekeeping inspection requirements.
PPM Procedure 7.38 " Storage and Handling of Materials" has been revised to better identify the status of material in tmporary storage.
Date When Full Compliance Will be Achieved Full compliance has been achieved. - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
Amended Response to NRC Inspection Report No. 50-341/83-20 The following discussion addresses Statements of Noncmpliance 83-20-03b and 83-20-03c.
Statement of Noncompliance, 83-20-03b Section 5.4 of ANSI N45.2.2 requires material OC inspection person-nel to designate all material inspected as either " Acceptable" or
" Unacceptable" and to tag the material. In several areas throughout the site, " Accept" tags were not placed on cmponents such as 8-inch elbows and unistrut bundles.
Statement of Noncernpliance, 83-20-03c Section 5.3.2 of ANSI N45.2.2 requires all nonconfonning materials to be identified with a " Hold" or " Reject" tag and, when practical to be placed in a segregated area or removed frcm the project site to prevent inadvertent installation or use. A Class 1 valve was located in the warehouse with an " Accept" tag attached that had "OC HOLD" written on the tag, and four other safety-related itms had both " Accept" and " Hold" tags on them.
Corrective Action Taken and Results Achieved The inspection period for this report was the month of September 1983, when we were in the early phase of transition frcm the Pro-ject to Nuclear Operations control of rnaterial. The inspection occurred when we were seeking to identify material brought into the warehouse frm vendors. This material had not been empletely identified and was not being maintained in a defined holding area.
The rnaterial was received, in sme cases, with tags on either the container or pallet indicating a " hold" and " accept" condition. It is recognized that this situation does not fulfill our ccumitment to the NRC for warehousing. Consequently, we plan remedial action in the short run to clearly identify material in the transition process and to not issue any such material until and unless it is cleared of all hold tags by Quality Assurance. All instances of multiple tags or those not specifically identifying material for acceptance and hold conditions are being corrected. All tags on pallets will be removed unless they particularly relate to the material on then and such material is not subject to additional itms being added to the pallet.
Corrective Action Taken to Avoid Further Nonempliance The long run corrective action will be to only receive and maintain properly tagged material in the warehouse under our control which is obtained and processed according to our procedures and newly developed OC requirements.
Date When Full Ccxnpliance Will be Achieved Full compliance will be achieved by March 1, 1984
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Amended Response to NRC Inspection Report No. 50-341/83-20
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Statement of Nonempliance, 83-20-03e
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. Section 6.1.2 of ANSI N45.2.2 requires Level D storage areas (out-t door) to be well drained, but an outdoor storage area was observed in which approximately ten sections of Class 1 square tubing were partially subnerged in water.
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. Corrective Action Taken and Results Achieved
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French drains were installed in several storage areas. One storage
.. area was elevated with additional rock material. All storage areas were inspected to insure that in pase.of heavy rains that all material was on dunnage and out of standing water.
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Corrective Action Taken to Avoid Further Noncmpliance s_
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,L To avoid.noncmpliances similar.to the example cited, each external
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storage area is inspected, at least every other day by Detroit Edison andbytherespons(blecontractor.'
' on a broader basis *, PPp Pr'qMure 7.27 " Project Housekeeping" is o
being revised to be more specific in housekeeping inspection s
requirements. PPS^ Procedure 7.38 " Storage and Handling of
- Materials" is be3r:9 revised to betttx 1dentify the status of material ~in tmporary storage.
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Date When Full Compliance Will be Achieved, 1,
The external storage area inspection activity is in place. The pro-cedure revisions have been issued.
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Amended Response to NRC Inspection Report No. 50-341/83-20 Statement of Nonempliance, 83-20-03f Sections 2.72 and 2.73 of ANSI N45.2.2 recuir.: material classified to Level B and C storage to be protected frcm airborne particles.
On the Level B and C warehouses, the truck entrance doors are allowed to remain open during working hours and several cmponents were observed with cracked open containers and excessive dust.
These items included valves, portland cement, pump shafts, and standby gas treatment filters.
Corrective Action Taken and Results Achieved During the time the inspection was conducted, Nuclear Administration was in the process of transitioning control of material in the ware-houses.
In the course of the transition, there was considerable traffic in and around the warehouses. Also, the warehouse doors were, by necessity, left ooen for extended periods to accamodate the reloca-tion of material and to cool the warehouses. These two factors con-tributed to the excessive dust observed.
Since then, the transition has been canpleted. The items o'oserved are currently under review and will be cleaned up and brought under the Nuclear Procurenent storage progra:r., or will be dispositioned elsewhere.
Corrective Action Taken to Avoid Further Noncmpliance The normal practice, now, is to have the main doors open only when loading or unloading, and housekeeping is being emphasized.
Recognizing that instances may occur when the doors are open for extended periods, a noveable barrier is being used to control entrance to the warehouse.
In addition, paving of the areas around the warehouse this surnuer coupled with the fact that traffic and access is now restricted, will reduce the generation of dust.
Detroit Edison believes these actions will preclude this condition fran recurring, and will continue to monitor these warehouses to ensure canpliance.
Date When Full Canpliance Will be Achieved Review, clean up and dispositioning of items transitioned to Nuclear Procurenent will be canpleted by March 1,1984.
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J Amended Response to NRC Inspection Report No. 50-341/83-20
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i Statstnt of Nonempliance, 83-20-07a
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10CFR50, Appendix B, Criterion VI, states in part, " Measures shall be established to control the issuance of documents... These mea-sures shall assure that documents, includjng changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed."
2 DECO Operational Quality Assurance Manual, Program Policy 6, Section m
1, states in part, "heasures shall be established to control the preparation, revision, issuance and use of documentation which prescribes activities effecting quality to asstre that they are g
reviewed for adequacy, approved for release by authorized personnel, E
and are distributed in a timely manner to the location where the prescribed activity is performed."
DECO Quality Assurance Manual, Section 5.0.1, states in part,
" Written procedures shall be impimented...to assure documents, including changes thereto, prescribing activities effecting quality E
have been reviewed for adequacy and approved for release by authorized personnel, and are properly distributed and used at the work place where these activities are performed."
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Contrary to the above, the inspectors found that Arbinistrative R
Procedure 12.00t,.27, Material Receiving, Inspect. ion, and Status Revision 4, which was approved on June 21, 1983, references pro-P cedures which were made inactive on October 26, 1982, and which were subsequently cancelled on July 11, 1983.
e grrective Action Taken and Results Achieved Detroit Edison Administrative Procedure 12.000.27 has been revised
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and the cited references 3.7.10 and 3.7.11 have been corrected.
Corrective Action Taken to Avoid Further Nonccxtpliance 7
POM Procedure 12.000.07 " Plant Operations Manual Procedures" places y
the responsibility for ensuring correct use of references in pro-cedures on the Section Heads.
Plant Order EFP-1053 was issued and approved by the Superintendent E
Nuclear Production on February 2, 1984. This Plant Order endorses L
the requirments of POM 12.000.07 and directs all Nuclear Produc-tion personnel that are involved in reviewing procedures to care-fully examine proposed procedures or revisions, including correct references.
The Plant Order further directs Nuclear Administration to review procedures for correct use of references. Detroit Edison believes that this directive provides sufficient checks and additional assurance of correct references in procedures.
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twended Response to NRC Inspection Report No. 50-341/83-20 Date When Full Carpliance Will be Achieved, 83-20-07a Full compliance has been achieved. ___
Amended Response to NRC Inspection Report No. 50-341/83-20 Statement of Nonempliance, 83-20-07b Contrary to the above, the licensee's contractor, Daniel Interna-tional Corporation, cancelled Adninistrative Procedures AP-IV-13, titled Cable Pull Cards, and AP-IV-14, titled Traveler Control, on July 14, 1983. The superceding procedures to cover the same work activities hact not been issued as of Septaber 20, 1983.
Corrective Action Taken and Results Achieved Daniel International Corporation Administrative Procedure AP-IV-13
" Cable Pull Cards" had been re-instated pending iccue of PPM 7.36.
PPM 7.36 was subsequently approved January 6, 1984, and is the superceding procedure for AP-IV-13.
Procedure AP-IV-14 " Traveler Control" will not be superceded by a Detroit Edison PPM procedure. Each contractor or Detroit Edison organization performing work that requires a traveler has an approved procedure.
Corrective Action Taken to Avoid Further Noncmpliance Detroit Edison Infonnation Systms has been notified to not cancel Ibniel procedures without the initials of the Edison Procedures Coordinator. The Procedures Coordinator will not initial procedures until a review of both the superceded and superceding procedures is emplete and discrepancies resolved.
,Date When Full Cm pliance Will be Achieved Full cmpliance has been achieved.
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4 Amended Response to NRC Inspection Report No. 50-341/83-20 Statment of Nonccupliance, 83-20-07c Projects Procedure PPM 2.14, Distribution Control, dated October 21, 1982, Section 6, requires each reproduced document to be appropri-ately stamped. POA letter dated November 12, 1982, requires all procedures or revisions issued after Novcraber 12, 1982, to be stamped " Controlled". The inspectors found four procedures and/or revisions in the QC Receipt Inspectors PQAP Manual (Controlled Manual No. 132) which were issued after November 12, 1982, and which were not stamped " Controlled".
Corrective Action Taken and Results Achieved P
A cmplete review was made by a member of the EF2 Document Control Organization of each POAP Manual, including the one used by the Receiving Inspectors. During this review, all PQAPs that were not j.
already stamped " Controlled" were so stamped.
Corrective Action Taken to Avoid Further Noncompliance The administrative controls in place should assure no recurrences of this problem.
The general comnitments by Edison made to the NRC by telephone involve procedure review, special audits, and personnel training as part of the corra tive action program. Concerning the violations de m ed to be the responsibility of Procurement QA, several actions have been taken or are in progress. Specifically, discussions with the Receiving Inspector established that they know and understand the requirments. New procedures are being published to facilitate the transition frcra the Construction to the Operations phase. These procedures will be presented, one at a time, in formal training sessions and will be impletranted immediately following the meeting.
Receiving Inspection and warehousing will be audited placing emphasis on equipnent maintenance and identification and any itms identified in this NRC audit.
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Date When Full Ccxrpliance Will be Achieved Full cmpliance has been achieved.
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.o Ammded Response to NRC Inspection Re' port tb. 50-341/83-20 Itans 83-20-05.and 83-20-08.are listed as unresolved items in Inspection Report 83-20.. Detroit Edison will pursue closure of these items with the resident inspectors and is withdrawing our previous response given-in EF2-66487, of Decenber 19, 1983.
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