ML20098E811

Responds to NRC Ltr Re Noncompliances Noted in Insp Rept 50-341/84-09.Corrective Actions:Personnel Instructed on Necessity of Maintaining Proper Document Control & Document Change Control

ML20098E811
Person / Time
Site:	Fermi
Issue date:	09/11/1984
From:	Jens W DETROIT EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
EF2-69703, NUDOCS 8410010402
Download: ML20098E811 (9)

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'. Wayne' H. Jens -;

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September-11,:1984

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-EF2-69703 j

\\ PRINCIPAL ST)tFF i

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fMr. James G. Keppler

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S..-Nuclear Regulatory Commission SG/i

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. Dear-Mr.- Kepplers.

-References; ' Fermi 2 NRC Docket-No. 50-341

Subject:

Noncompliance at' Fermi 2 Inspection Report 50-341/84-09 w-b s

This letter responds to'the items of noncompliance

. described in your Inspection Report No.'50-341/84-09.

This inspection was performed by Messrs.

P.

D.,Kaufman,.

R.

L.-Cilimberg, J.

Muffett, D.

E.

Keating-and I. T. Yin for 23 days from April 9,-1984 through July 2, 1984.

.The items of noncompliance arc discussed in this reply as J

required by Section 2. 201 of the NRC's " Rules of Practice'.','

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Part 2, Title 10, Code'of Federal-Regulations.

The enclosed response.is arranged to. correspond to the

'J sequence of items cited in the body of your report.

The-

number for the items.of nonco'mpliance and the applicable criterion are referenced.

We trust this letter will satisfactorily respond to the

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noncompliances cited in your report.

'If you"have questions regarding this matter, please contact Mr. Lewis P.

Bregni, (313).586-5083.

Sincerely, cc:

Mr..P.

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Byron

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Mr.

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D.^ Kaufman Mr. - R. C. Knop Mr. J. Muffett SEP141982 f4

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-THE DETROIT EDISON COMPANY.

FERMI 2 NUCLEAR OPERATIONS ORGANIZATION

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Response to NRC' Report No. 50-341/84-09 License No. CPPR-87 Docket-No.- E J 3 41 Inspection att. Fermi 2,. Newport Michigan, and Stone and L

Webster Offices, Cherry Hill,' New Jersey

' Inspection Conducted:

23 days from April.9, 1984 through July 2,_.1984 u-P e

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.c TRESPONSE TO-NRC INSPECTION REPORT No. 50-341/84-09

$ Statement ~of' Noncompliance 8 4- 09-01, Criterion VI 10CFR50, Appendix B, Criterion VI, as(implemented by DECO l Quality? Assurance _ Manual, Section 5.0.l' requires that docu-(ments<be'. adequately; controlled,_and to assure documents, including changes thereto,. prescribing activities affecting

. quality.be reviewed for, adequacy and approved for release by

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' authorized personnel,.'and; properly distributed.-

IContrary to'the above, Engineering Mechanics Technical l Su'pplements 'CHOC-EMTS-10-1, Fillet Weld ^ Design Criteria for (Pipe' Supports, was revised by Stone and; Webster Engineering Corporation interoffice memorandum' dated October 19, 1981,

.and Engineering Mechanics Division memorandum

'CHOC-EMDM-81-27, Design Criteria for Detroit Edison Company Category I, II, and III' Pipe Supports, was being altered by

' Detroit Edison Company-Tel-Con-Note dated December 2, 1983.

The' subject interoffice. memorandum and tel-con did not receive the same level of review or-approval as the proce-

'dures they revised nor were they controlled in accordance with Detroit' Edison Company's Quality Assurance Procedure Manual, Section 5.0.1.

Corrective Action Taken and Results Achieved Both Cherry Hill Operations Center (CHOC) EMTS 10-1 (currently-superseded by CHOC EMDM 82-39) and CHOC EMDM L

81-27 have been revised to incorporate all changes thereto which had=been promulgated by methods such as tel-con notes, memoranda, and letters.

These documents have been reviewed for adequacy,-approved for release by authorized personnel,

-and distributed properly.

In addition,. Stone and Webster Michigan Incorporated (SWMI) has performed an evaluation of all the Fermi 2,(N( Level 1 large bore pipe support calculations in the SWMI scope of work and determined that the reported condition did not adversely. affect the structural and functional adequacy of these pipe' supports.

Corrective Action Taken to Avoid Further Noncompliance

'The noncompliance resulted from a training (as opposed to a programmatic) deficiency.

In order to provent recurrence of

.the reported conditions, SWMI's Engineering Manager has issued instructions to appropriate personnel emphasizing the necessity of maintaining proper document control and docu-ment change control.

In addition, as noted in the inspec-tion report, Detroit Edison has informed other Fermi 2 contractors of the proper method for revising procedures.

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RESPONSE ' TO '_ NitC : INSPECTION. REPORT ' No. 5 0-3 41/8 4-09

'Date When Full Compliance'Will'be Achieved IThe-corrective actionsi-identified above have been:

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' RESPONSE TO NRC. INSPECTION' REPORT'No. 50-341/84 4

' Statement of ' Noncompliance '84-09-02, Criterion'V' 10CFR50,- Ahpendix B, Criterion V, as implemented by DECO

'QualityJAssurance Manual, Section 9;0.1,-requires that acti-s vitiescaffecting quality be prescribed by written"instruc-5tions, procedures or: drawings, and accomplished in accor-Jdance with these documents.

Contrary..to the above, the following examples of failure'-to Efollowfwritten procedures were-identified:

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There;was;no. evidence of'a Design ~ Change. Request revi -

sio'n to DCR No.-P-6289 which documents the offsetting

> of a structural member attachment point to the base-

-plate,'since the 1/8 inch relocation.tolercrAa was

. exceeded.1 ' A TX:R = is required by Wismer & Becker Proce- -

dure WB-C-114 if the 1/8 inch tolerance is. exceeded.

"b l A) weld was'not performed on pipe support.E41-3167-G17 beca'use'a WorktAssignmentsSheet/MaterialLNotice (WAS/MN),'as required by DECO Procedure FEWP-9, was not prepared by the Field, Engineering Group.

c.-

Stone.& Webster Procedure CHOC-EMDM-81-27 requires that

_ pipe supports be designed to a deflection criteria,

,however some supports have been designed-to a stif fness criteria.

d.

'Some minimum fillet weld sizes were not consistent with the. Seventh Edition - ASIC Manual-1970, as required by Stone & Webster's pipe support calculation' reference-cover sheets.

e.

~ A ' stress intensification factor of 1.3 ' for all fillet welds, as specified by Stone & Webster Procedure 1CHOC-EMDM-81-27, is not being' applied to the fillet weld calculations.

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Other calculational deficiencies and inadequacies were observed in.large bore pipe support designs.

These were also caused by Stone & Webster personnel failing to follow design procedures.

Corrective Action Taken and Results Achieved a.-

Design Change Request No. P-6289, Revision H, dated May 22, 1984, was written to document the offsetting of the structural member attachment point to the baseplate. In addition,.the design calculation for support -

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LRESPONSE?TO NRC INSPECTION REPORT No. 150-341/84-09 n

E11-3177-G23 was revised to reflect the offset of-the structural'. member and to verify-(that the existing.

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' baseplate is; structurally acceptable.

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Infaddition,.this support characteristic.was included

in

theiscope"of'the: hanger reinspection program dis-lcussedLiniSectionzIV of the inspection report.. Devia-

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- tions identified!in this program did not affect the structural ~and functional integrity.of the pipe sup--

port.,Therefore, this item is not considered to be a

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; generic, problem.

On e tember'2, 198', due to the stress report as-built b.'

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Lreconciliation,.DCR P3773, Rev.

E,' was-written to

. revise the. weld-on. support E41-3167-G17.

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~ paper 1 work (i.e.,1 WAS/MN) to have construction.com-

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pleted1was not issued promptly.

Edison' had previbusly = identified ' the possibility that

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2this'could occurJand had instituted an activity.to uncover missing items.

This process involves compart.ng the hanger' control system (HCS) computer printout against all " issued for construction" DCRs, DCNs,

~ hanger sketches.and WAS/MNs.

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~The above activity identified that the.WAS/MN had not been issued._ However,-before the necessary paper could

'get issued, the NRC inspector discovered this item. The

' field work for*this item.was finished on April 23, 1984 and was_OC accepted April 26, 1984.

c.-

Detroit. Edison, in a letter to SWMI dated August 31, 1982l(EF2-59,637) stated that SWMI need not be con-

.cerned with pipe support deflection where support Latiffness is input in the pipe stress analysis calcu-lations.

Detroit Edison further stated that SWMI should ensure that support stiffness be maintained or

' increased if a support were to require modification.

This direction was followed by SWMI.

However, the letter was not incorporated into CHOC EMDM-81-27.

As indicated in the reply'to Noncompliance 8 4-09-01 above, CHOC EMDM 81-27 has been revised to incorporate this change.s d.-

Minimum fillet weld sizes for the (SWMI) Fermi 2 large

- bore pipe supports meet the requirements of CHOC EMTS 10-1 which is referenced in the SWMI pipe support cal-

~ 'culations.

As mentioned in Noncompliance 8 4 01,

'CHOC'EMTS 10-1 was changed by means of an interoffice memorandum to adopt the Eighth Edition of the AISC m,

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... Ng RESPONSE TO NRC INSPECTION REPORT No. 50-341/84-09 Manual'with regard to the minimum fillet weld sizes specified in Table 1.17.2A.

Detroit Edison processed FSAR Change Notice No. 8 4-328, dated May 16, 1984, to indicate clearly that the Eighth Edition of the AISC Manual may be used for pipe support designs.

Further, on the subject of minimum fillet weld sizes, it should be noted that Wismer and Becker procedure WPS-7002, Interim Change 537, also specifies minimum fillet weld sizes.

Some of these are less than those in AISC Table 1.17.2A.

However, in accordance with the provisions set forth in the AISC commentary, these minimum weld sizes are acceptable based upon weld qualification tests.

The required tests were per-formed in accordance with AISC and AWS requirements, and the results (acceptable minimum weld sizes) were documented in WPS-7002.

This procedure change was processed in accordance with Edison's procedures and subsequently promulgated.

WPS-7 002 is referenced in CHOC EMDM 81-27.

SWMI has evaluated all of its Fermi 2 QA Level 1 large bore support calculations and determined that these supports comply with minimum weld size requirements.

e.-

The 1.3 stress intensification factor specified in paragraph 4.9. 4 of CHOC EMDM S1-27 has been deleted in the current revision of this EMDM.

It was an overly conservative and unnecessary requirement which should have been removed from the EMDM when first recognized as such.

The SWMI Engineering Manager has issued instructions to appropriate personnel emphasizing the need for issuing procedure changes in a timely manner.

f.

Detroit Edison directed SWMI to perform a special evaluation to verify that Fermi 2 large bore pipe sup-port designs comply with applicable codes and design criteria and are structurally and functionally ade-quate.

When technical /procedureal concerns were iden-tified, they were addressed and evaluated for specific and generic impact.

Initially, the evaluation entailed an extensive review of a random sample of 125 of the Fermi 2 large bore pipe support calculations prepared by SWMI.

These 125 pipe support calculations repre-sented a cross section of the various types of sup-

ports, i.e.

support design elements, computer programs, personnel, offices involved in developing the calcula-tions, and the dates the calculations were prepared.

The cross section provided a statistically valid basis for determining the acceptability of the pipe supports.

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..RESPvNSE TO:NRC INSPECTION' REPORT.No.- 50-341/84-09:

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During the:-evaltiation,.every potential _ engineering' con-I cern observed by the evaluation team was reported as an-acti~on item.to.SWMI= Management.. SWMI then performed an evaluation':of the affected pipe support calculations to

determine. if the. support design.was acceptable.. SWMI alsol evaluated other pipezsupport calculations,2 as i-nec'essary,.to determine'if the, reported condition

," existed ~elsewhere 'and,? if so, whether the. supports were i

f still acceptable. cThis process, led!to the evaluation

'of f the : remainder;(approximately 11600).of the large bore

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pipe supportsfatcFormit2.

The-evaluation team verifled and closed out' each. of L the' action items'.: The.affected

. calculations _and procedures have been revised or

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kamendedLas; appropriate.

' l n: summary '

I This(evaluation demonstrated.that the large

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.. bore, pipe _ supports _are structurally and je 1_

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,1 functionally adequate.

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the1 action. items.were thorough and covered A

a11 large bore pipe support ' calculations.

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Therefwere no hardware mo'difications result-l ing from-the.evaluati'on and engineering

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identified as.incompleteitechnical.and

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' administrative direction, and insufficient -

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' attention --to detail in-the development of. the

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' calculations by the SWMI' preparers.-

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Corrective Action'Taken to Avoid Further Noncompliance s

3 e (Appropriati_e~ngineering management action with respect to

-calculation preparers-and.' supervisors was considered neces--

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sary.JAs::Esuch,,S&W CHOC-committed to provide additional

> training for SWMI calculation preparers and supervisors to

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Ere-emphasizelthe?need;for-compliance with procedures and M-

'accuracysin-the' preparation'of' calculations.

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a RESPONSE TO NRC INSPECTION REPORT No. 50-341/84-09 l-m In addition, S&W CHOC Engineering Assurance will perform an additional review of all new OA Level I pipe support calcu-

-Q lations.

To assure the effectiveness of the corrective 1E actions, Detroit Edision will review a sample of SWMI calcu-

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lations. This effort will continue until renewed confidence is achieved.

Date When Full Compliance Will be Achieved 7,

7, SWMI has notified Edison that the training mentioned above h

will be conducted and completed in Septembe 1984.

The review of new calculations by Edison and S1 will continue

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until renewed confidence is achieved.

All other actions y

identified above have been completed.

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