e Donald A. Wells veaprow n A m en, Edison EEEE5== · 2020. 2. 11. · Statement of Open Item, 82-10-01, Section II, Item B-2 Contrary to proposed change 46 FR 34595 which rcodifies

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Donald A. Wellsveaprow n A m en,13 t h 23 7 M t

Edison EEEE5==<

October 22, 1982EF2-60504

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Mr. C.E. Norelius, DirectorDivision of Engineering and Technical ProgramsU.S. Nuclear Regulatory Ccumission

|Region III799 Roosevelt Road4Glen Ellyn, Illinois 60137

Subject: tbncompliance at Enrico Fermi Unit 2 Construction Site - IE Report50-341/82-10

Dear Mr. Norelius:

This letter responds to the items of noncompliance and open items describedin your IE Report 50-341/82-10. This assessment of Enrico Fermi Unit 2Site Construction activities was performed by the Construction AssessmentTeam of NRC Region III on June 21 - July 2, 1982, at the site.!

Items of nonempliance are discussed in this reply, as required by Section2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of FederalRegulations. In addition, responses to open items identified by the Con-struction Assessment Team are included.3

The enclosed response is arranged in sequence of itms cited in the body ofyour report. The finding and section numbers are referenced.

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We trust this letter satisfactorily answers the concerns raised in yourreport. We will be glad to discuss any further concerns you may have.

Very truly yours,

DAW /DF/pn,

cc: Mr. Richard DeYoung, DirectorOffice of Inspection and EnforcementU.S. Nuclear Regulatory CmmissionWashington, D.C. 20555

Mr. Bruce Little, Senior Resident InspectorU.S. Nuclear Regulatory Ccmmission6450 North Dixie HighwayNewport, Michigan 48166

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'IIIE DEIROIT EDISON COMPMW

QUALITY ASSURMEE DEPtWIMDIT

ENRICO FERMI 2 PROJa.T

Pesponse to NRC Report No. 50-341/82-10

Docket No. 50-341 License No. CPPR-87

Inspection at: Fermi 2 Site, Monroe, Michigan

Inspection Conducted: June 21-July 2,1982

Noted By: h II/&/>76;;LD. Ferencz, Ac 19 SupervisorConstruction lity Assurance

Approved By: /T.A. Alessi, DirectorProject Quality Assuranw

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Response to NRC Inspection Report No. 50-341/82-10 (82-10-01)

Statement of Open Item, 82-10-01, Section II, Item B-2

Contrary to proposed change 46 FR 34595 which rcodifies 10CFR50.34, 50.54 and50.55, Chapter 17 of the FSAR was not updated, and subnitted to the NRC. TheOA Program and Fermi organization underwent a major revision in March,1980,without such change being described in an amendment to the FSAR Chapter 17.1.

Corrective Action Taken and Results Achieved

Chapter 17.1 is not required as part of the FSAR. Although it was subnittedin 1974, it was not reviewed by the OA Branch of NRR. In fact, the branchchief specifically stated that it should not have been included as part of theFSAR. Therefore, as far as NRR is concerned, Chapter 17.1 has no status, andit has not been our intention to revise it unless so required by NRR.

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Statment of Nonempliance, 82-10-02, Section II, Iten B-3

In March, 1980, the Fermi Quality Assurance functions were reorganized integrat-ing the Detroit Edison and Daniel International site personnel into one organ-ization. The Quality Assurance manual dated April 27, 1977, and revised Dec-,mber 5, 1978, was not revised prior to the reorganization. The manual revi-sion was subsequently cmpleted and approved on June 28, 1982, 27 months afterthe reorganization. The implementing procedures had been revised to reflectthe changes, however, that is a reversal of basic OA philosophy with regard to

; document priorities. This is considered to be an iten of nonempliance withCriterion II of 10CFR50, Appendix B.

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'Ihe Manual revision has been completed. It is now issued and distributed toi all assigned manual holders.

Corrective Action Taken to Avoid Further Noncmpliance

The Edison OA Manual, Section 1.3.4 states, in part, "The OA Manual is.. .'

subject to periodic review by the POA Director, at least once per year."

An action item will be placed on a cmputerized tracking system to assurethat future periodic OA Manual reviews are perforned.

Date When Full Cmpliance Wil_1 be Achieved

Full ccupliance has been achieved. This its is ready for NRC review. Docu-mentation and other information is available at the Enrico Fermi 2 site.

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Statment of Open Itm, 82-10-03, Section II, Item B-4

The Enrico Fermi 2 Quality Assurance Manual, Section 2 states, "'1he ProjectQuality Assurance Director (PDAD) who reports on project-related matters tothe Project Manager, is administrative 1y responsible to the Director of theQuality Assurance Departnent and obtains direction frm him on OA policy mat-ters." This appears to have been stated incorrectly, and is not the actualpractice at Fermi. This statment needs clarification to assure organiza-tional freedm to fully rneet Cirterion I of 10CFR50, Appendix B. This is con-sidered to be an open item. A written response is requested frm DetroitFelison on this item.


The Enrico Fermi 2 Quality Assurance Manual, Section 2.1.2.5 has been revised(Revision 6) and now states:

"The PDA Director reports administrative 1y to the Manager - Quality Assurance,but on project-related matters, he reports to the Manager of the Project...with the Assistant PDA Director, he provides administrative and technicaldirection to POA." It should be noted that after reorganizing in 1980, theDirector of the OA Department also assumed the position of Director of ProjectOA.

Date When Full Carpliance Will_ be Achieved

Full carpliance has been achieved. This item is ready for NRC review, andthe information is available in the Quality Assurance Manual, OAP-2, Revi-sion 6.

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Respcose to NRC Inspection Report No. 50-341/82-10 (82-10-04)

Statement of Nancmpliance, 82-10-04, Section II, Item D-1

Contrary to 10CFR50, Appendix B, Criterion II and Enrico Fermi 2 QualityAssuranw Manual, Section 19.0.3, a review of the overall Fermi DA Programhas not been performed. A procedure to control this activity was not inplace, nor had such a review been scheduled or perforned since the beginningof the Fermi Project.

Corrective Action Taken and Results Achieved'

A contract has been awarded to Management Analysis Corporation to perform aFermi 2 On program assessment.

It should be noted that practices such as (1) audit reports to alison man-agenent and (2) periodic meetings with managenent, including the alisonpresident provide feedback regarding OA program status. Also, programassessment reviews have indeed been perforced in the past: (1) DanielInternational corporate officials reviewed various aspects of the programin 1974. (2) In 1977, Theodore Berry and Associates was selected by theMichigan Public Service Ccmnission to perform an assessment of the marngingof the cmpany which included the Fermi 2 project Iranagement and DA. (3)Managenent Analysis Corporation perforned a total project assessment ofFermi late in 1979. 0A was part of the review. This assessnent resultedin a recomerxlation to restructure the OA/DC organizations, which Edisonhas since accmplished.


An action item will be placed on a cmputerized tracking system to assurethat future periodic program assessnents are performed.

Date When Full Cmpliance Will be Achieve _d

The planned program assessnent will-begin in October,1982.

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IResponse to NRC Inspection Report No. 50-341/82-10 (82-10-05)

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i Statenent of Nonccrrpliance, 82-10-05, Secticm II, Item D-2

| Contrary to 10CFR50, Appendix B, Criterion XVIII and the Enrico Fermi 2Quality Assurance Manual, Section 19, no audits were scheduled or conducted;

| of the Fermi Site audit program or the Troy Architect-Engineer atxlit program.Audits in these areas of the OA Program have not been done since the Fermi*

!Project began.

Corrective Action Taken and Results Achieved |

Construction OA and Design OA - Troy sections were audited by Project GAstaff in August and October, 1982, respectively. It should be noted thatprior to March,1980, Daniel OA organization conducted the site audit pro-gram and Edison OA, in turn, audited Daniel OA.

Corrective Action Taken to Avoid Further Nonccupliance

Future atxlit schedules will include all elenents of the Fermi 2 Quality Assur-

ance organizations.

Date When Full Ccr:pliance Will Be Achieved

Full ccupliance has been achieved.

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Response to NRC Inspection Report No. 50-341/82-10 (82-10-06),

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Statement of Nonempliance, 82-10-06, Section II, Item D-4'

i Contrary to the requiremnts of 10CFR50, Appendix B, Criterion V; and theEnrico Fermi 2 Ouality Assurance Manual, OAP No. 9, Project Quality Assur-

; anoe Procedure 9.112, Revision 0, did not include a requirenent per Regula-

| tory Guide 1.146 (which endorses ANSI N45.2.23-1978) that Icad Auditors beadministered an examination prior to certification. In addition, a IcadAuditor certification was issued without the backup documentation on fjleat the site.,

| Corrective Action Taken ard Results Achieved :

; Project Quality Assurance Procedure 9.112 is being revised to meet thej requirenents of ANSI N45.2.23-1978. The qualificaticn/ certification files! for personnel who function as Icad Auditors are being reviewed to assure

that objective evidence is available to substantiate certifications. Todate, no major problems have been identified concerning the qualificationsof personnel who have perforned as Icad Auditors for the Fermi 2 project.i


Inplenentation of the revised procedure will provide the basis for cmpli- .ance with regulatory requirenents. !

'Date When Full Cmpliance Will be Achieved

The revised procedure is expected to be approved and issued, and Icad Audi- :tor qualification /wrtification files will be updated per this revision byDemmber 20, 1982.

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Statement of Open Item, 82-10-07, Section IT, Item E

Project Quality Assurance Procedure 9.347, Trend Analysis System, Rev. O, wasfound to be weak with regard to the assignment of tine constraints on analyz-ing data or issuing reports to trigger corrective action. Also, Nonconfor-mance Reports (NCR's) are not covered by the procedure. Section 3.0 refersto trending only "onsite contractors" and does not include Edison activities.


Project Quality Assurance Procedure 9.347 is being revised to include assign-nent of time constraints on analyzing data and issuing reports for correctiveaction. It will also include coverage of nonconformance reports (alisonactivities).

Corrective Action Taken to Avoid Further Nonempliance

Revision of Procedure 9.347 and its implenentation is expected to preventrecurrence.

Date When Full Canplianm Will be Achieved

Revision to Procedure 9.347 is expected to be emplete by December 6,1982.

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Statement of Nonccupliance, 82-10-08, Section II, Item E-3

Contrary to 10CFR50, Appendix B, criterion XVI and the Enrico Fermi 2 Qual-ity Assuranm Manual, Sectica 17, nutcrous Deviation Disposition Requests(DDRs), audit firxlings, and surveillance findings have not been disposi-tioned on a tinely basis. Therefore, corrective actions have not beenpra pt.


POA is ccnducting a study which will establish tin time limits for closingquality related items such as DDRs, Nonconformance Reports (NCRs), AuditFindings and Surveillances.

A program for management of items by exception (items exceeding the estab-lished limits) will be incorporated into PDA procedures and implementedfollowing appropriate training.

Corrective Action Taken to Avoid Further Noncccpliance

The open item tracking and follow-up (managenent) program will be reviewedand evaluated nonthly by Project OA management for effectively reducing thenumber and duraticn of open itans exceeding established limits.

Date When Full Ccnpliance Will be Achieved

Expected date of full compliance is December,1982.

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Response to NRC Inspection Report No. 50-341/82-10 (82-10-09),

Statenent of Nonecupliance, 82-10-09, Section II, Item F-1

Ccntrary to the requirenents of 10CFR50, Appendix B, Criterion V, and theEnrico Fermi 2 Quality Assurance Manual, Section 9.0.1, Wisner and Decker'sProcedure WB-O-113, Rev. 5, assigns responsibilities and provides admini-strative direction, but does not provide appropriate quantitative or quali-tative acceptance criteria with regard to how surveillances are to be con-ducted or what the scope of the surveillance program is to be.

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: The scope of Wismer and Becker's Procedure WB-O-113 was revised to ade-quately describe what is covered by surveillances and surveillance reports,and the nethcds by which surveillances are to be conducted. It is inappro-priate to include any form of acceptance criteria in the' surveillance proce-dure, because criteria for an activity being surveyed are included in writteninstructions associated with activity.

Corrective Actica Taken to Avoid Further Nonccupliancea

Quality Centrol personnel and personnel in charge of approving and process-4

ing surveillance reports have been instructed, through formal training, as tc|! the requirenents of the approved, revised procedure. In addition, contrac-

tor's surveillance reports are routinely reviewed by Project OA for adequacy.'

Date When Full Cccoliance Will be Achieved

Full conpliance has been achieved.:

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Statenent of Nonempliance, 82-10-10, Section II, Item F-2

Contrary to the requirements of 10CFR50, Appendix B, Criterion XV and theEnrico Fermi 2 Quality Assurance Manual, Section 16.1.5, during a review ofsurveillance reports, the inspector found five cases in which a site con-tractor, Wisner and Becker, improperly reported nonconformances affectingplant hardware on surveillance reports rather than on DDRs, thereby avoid-ing the required licensee engineering review of the nonconformance.


Wismer and Becker has revised their surveillance reporting procedure to,

clarify the criteria for use of surveillance and DDR reports for identified i

.nonconformances. The revised procedure has been reviewed and approved byProject DA. Surveillance reports issued prior to the procedure revisionare being reviewed for ccupliance to the revised procedure. Instances ofmiaMplication of the surveillance report will be corrected by ' issuing aDDR to cover the associated nonconforr.nnae.


A. WB-O-113, Rev. 5, was revised, and Rev. 7 was approved on October 5,1982. This procedure now adequately describes items which are to bereported on surveillance reports.

B. Quality Control personnel and personnel in charge of approving arxl pro-cessing surveillance reports have been instructed through formal train-.ing as to the requirements of the revised and approved procedure.

Date When Full Cmpliance Will be Achieved

Full empliance should be achieved by November 10, 1982.

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Response to NRC Inspecticn Report No. 50-341/82-10 (82-10-11)

Statement of Nonempliance, 82-10-11, Section II,' Item G

Contrary to' 10CFR50, Appendix B, Criterion II and the Enrico Fermi 2 Qual-ity Assuran Manual, Section 1.4.7 and Section 1.5.4, the Reactor Build-ing, Dry-wll, Auxiliary Building, and the general site areas outside build-ings weru littered with garbage, scrap lumber, rags and other debris. Twounattended containers of a flamable liquid were also observed in the Dry-well and Reactor Building. Pipe caps were noted to be missing on smeinstrunent racks.


1. A Site Administrative Pro dure, AP-V-16 " Project Housekeeping" wasapproved on October 8,1982, to improve routine housekeeping activities,and to establish responsibility for inplementing the requirenents ofthe procedure.

2. Weekly housekeeping neetings are being held by the Edison Project Super-intendent to discuss progress and identify any problem areas. Theseneetings are attended by representatives frcm all contractors involvedin a major work effort.

3. All buildings and areas outside buildings have been cleaned and arebeing maintained daily.

4. Project GA is incorporating housekeeping into its surveillan proce-dures. Construction, maintenance and operations activities will beincluded in the scope of this effort.

Corrective Action Taken to Avoid Further Nonemplian

Further noncmpliance will be avoided by implementation of Procedure AP-V-~16; the concerted project wide effort to inprove nethods md practices; andthe Project OA surveillance program.

Date Nhen Full Capliance Will be Achieved

The action described above has been partially inplenented. Full implenenta-tion is expected by December 6, 1982.

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Sta6mnt of Nonecmpliance, 82-10-12, Section III, Iten A-id

Contrary to 10CFR50, Appendix B, criterion V and Enrico Fermi II QualityAssurance Manual, Section 9.0.1, Detroit B31 son Project Procedures 3.20,3.21, and 3.22 ccntain significant mistakes and inconsistencies, includingincorrect referen s, and incorrect title, and incorrect instructions.


Project Quality Assurance performed a review of the subject proceduresJune 23, 1982. As a result of this review, Quality Surveillance FindingsS-062482-1, 2, and 3 were issued describing the following discrepancies:

A. Incorrect title.B. Lack of definition to Type I and II DCNs, DCRs, and ENRs.C. Incorrect references.D. Typographical errors.

On July 2,1982, the Detroit Edison Project Procedure Manual Coordinatorformally responded to the subject findings with satisfactory results. Prcy-cedures 3.20, 3.21, and 3.22 have been revised to reference project proce-dures " Appendix B" which defines Type I and Type II DCNs, DCRs, and FMRs.Revision also includes correction of incorrect title and apparent typogra-

phical errors, i.e.: the term DCR was used in lieu of FMR. Based uponacceptable review of Project Procedures 3.20, Rev. 4, 3.21, Rev. 4, and3.22, Rev. 3, Quality Surveillance Firrlings S-062482-1, 2, and 3 wereclosed August 3,1982.

Corrective Acticn Taken to Avoid Further Nonccmpliance

Responsible personnel have been in.structed to assure that all references,in narrative documents are specifically and accurately worded. The ProjectProcedure Manual coordinator has been instructed to carefully proofreadprocedures prior to formal review. In addition, the Construction QualityAssurance Secticn has been added to the review cycle for all new drafts and;revisicns of quality related project procedures in an effort to minimizethe frequency and magnitude of errors.

Date hten Full Ccapliance Will be Achieved

Full ccmpliance has been achieved.

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{ Response to NRC Inspection Report No. 50-341/82-10 (82-10-13)

Statment of Nonempliance, 82-10-13, Section III, It s A-3

Contrary to 10CFR50, Appendix B, Criterion III, design control measures cm-mensurate with the original design wc2.e not provided for design changes. OneENR (#S3940), for the installation of a site fabrication cable support rackon top of cabinet Hil-P613 did not indicate that possible changes in theseismic qualifications of the cabinet with the rack installed had been con-sidered. The ENR also failed to include quality assurance requirments forthe rack fabrication and installation. Several ENR's had been issued toreplace pump motor connection boxes with larger connection boxes. There wasno evidence that the installation of larger boxes received a review to con-sider the affect on seismic qualifications.


1. Change papers identified in the finding will be sent to Troy EngineeringCenter for review and approval per mmo EF2-59507.

2. Mmo EF2-58763 Supplement 1 has been issued to assure a proper and sys-tmatic approach to approval of seismic effects on Class IE equignent.All termination box and cable support changes not already reviewed willbe subnitted for review.

Corrective Action Taken to Avoid Further Nonempliance

Field Engineering Work Procedure (FEWP) Section I, Para.1.10, was revisedSeptember 28, 1982, to establish a procedure for each engineering disciplineto review design changes for seismic effects.

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Date When Full Compliance Will be Achievedi

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1. Review of all termination box and cable support changes not already review-'ed are expected to be reviewed by October 15, 1982.

2. All other required acticos have been empleted.|

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Statement of Open Item, 82-10-14, Section IV, Itan C

The L.K. Ca* stock O.C. Inspectors qualification records were reviewed for can-pliance to ANSI N45.2.6-1973 standards as referenced in Detroit Edison to NRRLetter EF2-55344 dated November 18, 1981. The following discrepancies werefound:

Number ofContractor Discrepancy Occurrences

LKC Visual exam ntissing 1LKC No basis for certification 1LKC Activities for which certified not indicated 3LKC Certification not dated 2LKC Certification not documented 1

During the assessment, the licensee was advised of the above qualificationrecords which contained discrepancies, and directed LKC to review and updatetheir entire DC personnel flies. The licensee has scheduled an audit of LKCOC personnel training and qualifications. This is an open iten which requiresa response by the licensee.


The QC Manager of L.K. Constock reviewed all OC Inspector's records on July27, 1982, and found that the DC personnel records that were missing were con-tained in other files in his office.

Fran his review of the forty-eight (48) files, he found the following:

1. Thirty-One (31) records were carplete.2. Fifteen (15) required six month reviews, which help to determine pay

raises.3. Two (2) inspectors required eye tests, which were given inmediately.

Corrective Action Taken to Avoid Further Nonca@liance

All OC personnel records will be reviewed for accuracy every six (6) nonths.

Date When Full Ca mliance Will be Achieved

Full carpliance was achieved by July 27, 1982.

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Statement of Open Itm, 82-10-15, Section IV, Item D

Interviews were conducted with selected quality control, quality assurance,engineering and managment personnel. Wismer and Becker Quality controlInspectors perceived a lack of management support for OC activities. Specificconcerns expressed by the Wismer and Becker inspectors included:

1. Wismer and Becker OC manager was not independent of influence by the Wis-mer and Becker Construction Superintendent.

2. Wismer and Becker OC supervision was not supportive; feedback to inspec-tors regarding concerns was not adequate.

Items 1 and 2 are considered to be open. A written response by the licenseeis required for Items 1 and 2.


The cause of the problems was determined by Wismer and Becker to be poor ccra-munication between Wismer and Becker's Project Quality Manager (PCM) and OCstaff personnel; lack of adequate explanation for "use-as-is" type disposi-tions on DDRs, Surveillance Reports, etc; and poor working conditions for OC,and ineffectiveness of Wismer and Becker's PCM in handling the problems.

Wismer and Becker's PCM started conducting weekly staff meetings personallywith all department personnel on July 7,1982.

Wismer and Becker's PCM started reviewing all DDRs and explaining "use-as-is"dispositions to the originator on June 25, 1982.

Training sessions are being conducted to explain Code and Specificationrequirments to all supervisors. It is felt that a better understanding ofcodes and specifications will aid the supervisors in handling concerns of theirpeople.

Supervisor Sminars for Wismer and Becker Quality Department supervisors wererestarte on August 5, 1982. These were being conducted monthly, but weredstopped in the spring. These seminars have provided good " rap sessions"between the PCM and supervisors.

Two new supervisors have been assigned to OC to assist in problem solving andsupervision of the DC department.

Wismer and Becker's Corporate Quality Assurance and Control Manager made avisit to the Enrico Fermi 2 site the week of July 26, 1982, and interviewedfifteen (15) of Wismer and Becker's first line OC inspectors representing alldisciplines. The purpose of this survey was to assure that Wismer and Becker'sDC personnel were not being intimidated, and that they have the necessaryauthority and organizational freedczn to identify quality prob 1ms, initiate,recomend, or provide solutions and to verify implementation of solutions. In

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the course of conversation with the inspection personnel, the following ques-tions were either directly addressed to the individual or the answers werearrived at by infonnal discussion with the individual.

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YES NO

1. Do you feel that your supervisor gives you the neededsupport and backup in your job? 15 0

2. Are your concerns answered to your satisfaction? 15 0

3. Do you feel that comunications between you and yoursupervisor could be introved? 10 5

4. Have you ever been pressured to accept sub-standardwork? 0 15

5. Are you satisfied with your job? 15 0

6. Do you feel you have the freedan to document or voiceany problan areas or discrepancies which you uncover? 15 0

7. Do you feel that W&B OC has ample authority to achieve15 0a quality product?

8. Do you feel that your DA/OC Manager is intimidated or0 15pressured by Project Managenent?

9. Do you feel that our Custuner, Detroit Edison, has theneeded assurance that Wismer and Becker is doing a

15 0quality job?

10. What suggestions could you give to improve ccmnunications and relationsbetween inspectors and their supervision? (Suggestions are documentedin Wismer and Becker's Report)

It is noteworthy that the results of this survey were positive in all respectswith the exception of comunications and feedback. In regard to question num-bar three (3), the majority of inspection personnel were of the opinion thatthe recently instituted staff meetings and job walks conducted by Hismer andBecker's PCM will help a great deal to achieve better comunications.

In regard to question number eight (8), the majority felt that the pressuresto get the job done were normal, and not necessarily different fran any otherjob site.

The cannents received frun the inspectors were arranged to preclude identity ofthe individual, but listed totally in order that each ccmrent may be evaluatedby the Project Quality Manager and acted upon as necessary.

A follow-up review was perfonned by the Corporate OA Manager of Wismer andBecker during the week of October 4, 1982. This further substantiates the posi-tive results of the July survey.

Corrective Action Taken to Avoid Further Ibncanpliance

The corrective action taken and results achieved, noted above should provide an

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Response to NRC Inspection Report No. 50-341/82-10 (82-10-15)i

adequate corrective action to alleviate this concern.

Date hhen Full Carpliance Will be Achieved

Due to the nature of this Open Itan, it will be on-going. For the record,though, full compliance is considered to have been achieved.

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Statement of Open Itan, 82-10-16, Section IV, Item D

1. Quality control Inspectors, in general, believed that procedures and check-lists were adequate--containing ay topriate guidelines and specifications.An exception to this was in the area of electrical conduit and supports.The L.K. Ccrastock inspectors stated that, in that area, sane procedurescontain conflicting specifications. Resolving the conflicts are tiJne con-suming and frustrating to the inspectors.

2. Opinions expressed by Wismer and Becker inspectors relative to the adequacyof interfaces were notif y different fran those expressed by DC inspectorsin other contractor organizations. Wismer and Becker OC inspectors statedthat they do not feel free to contact DECO organizations with OC concerns.

3. In addition, they stated that engineering and technical support within Wis-mer and Becker was frequently not adequate and not provided in a timelymanner.


Itan 1. L.K. Comstock's OC Procedures 4.3.6 and 4.3.7 have been revised toclarify the acceptance criteria, and the appropriate OC personnel havebeen trained on the new revisions.

Itans 2 and 3. Corrective Action Taken and Results Achieved are stated in theresponse to Item 82-10-15.

Corrective Action Taken to Avoid Further Noncanpliance

Item 1. The revised procedures make the acceptance criteria unarrbiguous, andshould alleviate the concerns expressed by Canstock personnel.

Itans 2 and 3. See Response to Item 82-10-15.

DO When Full Canpliance Will be Achieved

Full compliance has been achieved.

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Statanent of Open Itm, 82-10-17, Section V, Item A-4a

Softeners to protect the cable frun the cable tray metal ed9 were not inplace on Cable Trays IC-137, 1C-038, IC-047 and IC-035. Paragraph 5.20.11.4of Detroit Edison Cmpany (DECO) Specification 3071-33 requires the installa-tion of metal edge protector "calrepco" or equal approved by DECO, wherecables leaving or entering cabic trays are in contact with or may contact theedge of the tray channel flange. The cable jacket may be used as a softenerat tray rungs and around bends in the tray, and should be properly securedby ty-wrap or tape as necessary. The contractor developed Procedure 4.3.0,titled " Inspection of Installed Cabic and Associated Raceway" to reinspectthe installed cables. The reinspection was in progress at the time of thisassessment. Paragraph 3.4.0 of Procedure 4.3.0 requires verification thatcable softeners or other protection is in place. OC Checklist 40 is used todocument adverse findings.


The adequacy of the checklist No. 40 was reviewed by the L.K. Canstock (IEC)0.C. Supervisor, and it was felt to be adequate when used in conjunction withthe procedure and referenced documentation.

Corrective Action Taken to Avoid Further Noncompliance

The trays are scheduled to be re-inspected prior to January 10, 1983. Anytray that has not been inspected within 6 months of being turned over willbe walked down prior to turnover.

Date When Full Cmpliance Will be Achieveo

No corrective action was required. For the purpose of documentation, the dateof this response is considered appropriate.

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Statement of Open Item, 82-10-18, Section V, Item A-5

The Quality Control inspectors and their supervisor were not knowledgeablewith regard to the acceptance criteria in the DC procedures governing the DCinspection checklists. The L.K. Cmstock QC Supervisor stated that an indoc-trination refresher course will be given to the OC staff. This is consideredto be an open item. A response by the licensee is requested.


As a result of the Construction Assessment Team visit, fifteen (15) OC proce-dures have been re-written, and the DC personnel responsible for the areascovered by the revised procedures have been trained in those revised proce-dures. (All inspectors were not trained to all procedures.)


When a design change document is received the OC Manager /his designee routesthe data to all the supervisors who in turn assure that the responsible inspec-tors are aware of any/all changes. Additionally, although it isn't requiredor documented, any inspector who has not worked in a specific area for a rea-sonable length of time is re-indoctrinated to the latest requir ments.


The above action has been implemented and is on-going. For the purpose ofcmp 11ance, the date of this response is considered to be appropriate.

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Response to NRC Inspection Report Ib. 50-341/82-10 (82-10-19)

Statment of Nonempliance, 82-10-19, Section V, Item A-6

Contrary to 10CFR50, Appendix B, Criterion II and the Enrico Fermi II QualityAssurance Manual, Section 1.4.7 and Section 1.5.4, cmbustible material suchas paper, construction material such as mpty cable reel, and other debris wasobserved in cable trays OC-031 and OC-731 in the first floor of the ReactorBuilding, and in cable trays 2C-066 in the second floor of the Reactor Build-ing.

_ Corrective Action Taken and Results Achieved

1. A Daniel Administrative Procedure, AP-V-16 " Project Housekeeping" wasapproved on October 8,1982, to establish routine housekeeping activities,and the responsible positions for implmenting the requirements of theprocedure.

2. Weekly housekeeping meetings have been held by the Edison Project Superin-tendent to discuss progress and identify any problem areas. Those meetingsare attended by representatives frtxn all contractors involved in a majorwork effort.

3. All cable trays were inspected and cleaned as required. Beginning Septem-ber 27, 1982, L.K. Cmstock O.C. personnel have performed weekly inspec-tions of all cable trays.

Corrective Action Taken to Avoid Further Ibncmpliance

Further noncmpliance will be avoided by implementation of Procedure AP-V-16.


Full cmpliance with Procedure AP-V-16 will be achieved by December 1,1982

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Statement of Noncmpliance, 82-10-20, Section V, Its B-4

Its 1.3 on the checklist requires verification that the tray is anchoreddown...The inspector infonned the licensee that failure to inspect or documentthe inspection of these welds is an item of noncompliance with the require-monts of 10CFR50, Appendix B, Criterion X.


To detennine if the welds previously installed are adequate for Enrico Fenni 2a " Cable Tray Hold Down Weld" testing program was developed. A total of Onethousand eight hundred and eighty-nine (1,889) welds were inspected and cata-gorized. One hundred and thirty-seven (137) catagorized welds were examinedunder a load test. An analysis of the plans statistical results by ProjectQuality Assurance revealed acceptable confidence levels in the plan. Engineer-ing review of both the testing plan and the statistical analysis has concludedthat these welds (made prior to July,1982) are structurally acceptable.

Ref: Ictters EF2-59559, F2S82-4820, F2S82-4274


Detroit Edison Engineering issued a design revision for the amount of weldrequired to attach cable trays to a seismic support. All new welds must meetthe minimum dimensions of 1/8" size by 1/2" length. Engineering StandardSTD-EB-ll7.57 is discontinued and standards STD-EB-ll7.86, STD-EB-117.87 pro-vide attainable weld dimensions. Design Change Notice DCN-7564 clarifies thephysical characteristics of the weld by incorporating the American WeldingSociety's D1.1 criteria.


Full ocanpliance should be achieved September 20, 1982.

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Response to IEC Inspection Report No. 50-341/82-10 (82-10-21)

Statement of Open Itm, 82-10-21, Section V, Item B-4

A unique identification number was not assigned to each of the hangers of thesame style...The DII'o Project Manager, in a letter dated July 2,1982, direct-ed the Construction Project Manager to develop a procedure to supplementexisting procedures to provide evidence of inspection coverage on fabricationand installation. -Pending review of the revised procedure, this is consideredan open item.


Unique hanger numbers are assigned to each inspected cable tray support by theelectrical construction contractor, L.K. C mstock. All new installation workreflects this identification. Records generated prior to the incorporation ofindividual hangers in 1980, werc considered acceptable by the administrativecontrol of seismic support fabrication. To achieve better record retrievabi-lity the contractor will provide an index for each cable tray, identifying thehanger cmponent inspections. A retrofit records program will assign specifichanger numbers to these multiple inspection records to assist in their prmptretrieval.


The Cable Tray design now includes identification for each hanger. Inspectionrecords will be traceable to specific hangers through a system being incor .porated into contractor and POA procedures.


Implementation of the program has been initiated, and will continue throughcmpletion of installation and inspection of all cable tray.

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Response to NRC Inspection Report Ib. 50-341/82-10 (82-10-22)

Statment of Nonocxt.pliance, 82-10-22, Section VI, Iton A-2A

During examination of the Reactor Controls, Inc. weld rod issue station onJune 28,1982, the inspector noted that fifty (50) 1/8 inch E7018 carbon steelelectrodes were mixed in the No. 2 oven in the same cmpartment with E308Lstainless steel electrodes. The inspector infonned the licensee that thiswas an Ltm of nonccxtpliance with the requirements of Criterion IX af 10CFR50,Appendix B, and with Reactor Controls, Inc. Procedure No. WP-121A, Rev. 2,which prohibits the storage of stainless steel electrodes in ovens or con-tainers with other classifications of electrodes.


The E7018 carbon steel electrodes were reoved frm the oven during the NPCvisit.

It should be noted that no stainless steel weld rods were issued frm the Ib.2 oven since Septerrber,1981. Also, a review by RCI was performed in June,1982, prior to the NRC Construction Assessment Team visit, and at that timeno carbon steel rods were found in the No. 2 oven.

Corrective Action Taken to Avoid Further ?bncmpliance

1. All personnel involved in the weld rod control have been retrained, inaddition to the retraining, new tool rom men have been assigned for rodisnuance.

2. A rod oven surveillance sheet has been generated for the purpose of OCsign off for each oven.

In addition to the above steps being taken, Reactor Controls, Inc. has gene-rated a DDR W-8707, addressing the original nonccx:pliance.

Late When Full Cmpliance Will be Achieved

The corrective action has been taken, and verified on Quality SurveillanceReport #82433. This item is ready for NRC review, and the documentation andother information are available at the Enrico Fermi .2 site.

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Staterrent of Nonccepliance, 82-10-23, Section VI, Itm A-2bP

During examination of Walbridge-Aldinger Cmpany fabrication shop weld rodissue station, and the iron worker's issue station in building No. 49, the finspector noted that the thermcmeters used at these two stations to check the aholding ovens were not identified by tags or stickers, and that neither had acalibration record. The inspector was informed that neither thermmeter had 'been calibrated, and that neither was in the calibration program. This is an'its of nonccrip11ance with Criterion XII of 10CFR50, Appendix B.


On July 21, 1982, the Finish Construction / Maintenance QA (FC/M QA) Section ofProject OA had two (2) thennmeter numbers, 183009 and 183010, calibrated inaccordance with Project OA Procedure 9.150, Rev. 3, for use in verifying weldrod oven tmperatures.

After thermcmeters were calibrated, they were used to verify the temperaturesof weld rod ovens No. 2 and No. 5. The ovens were found to be within therequired range outlined in AWS Dl.1-75, Section 4.92.

On July 21, 1982, Walbridge-Aldinger C(upany (WAco) ordered three (3) Therno-meters for use in verifying weld rod oven temperatures. These were assignednumbers WA001, WA002, and WA003, and turned over to FC/M-QA on July 24, 1982,to be entered into the calibration program in accordance with POAP 9.150, Rev.3. 'Ivo (2) thentcmeters, WA001 and WA002, were in turn issued on August 4,1982, by K/M-OA to WAco at weld rod issue stations, building No. 49 - ovenNo. 5 and building No. 45 - oven No. 2, respectively in accordance with POAP9.150, Rev. 3, and WCo Procedure hM-IV for use in verifying weld rod oventemperatures.

Calibration documentation appears on the Daniel M&TE issue record log, and theFermi 2 metrology certificate of calibration. These documents are maintainedby m/M-OA.

The action taken has satisfactorily resolved the deficiency.


It has been determined that the cause of the problem was due to the thermo-meters, used for ver3'; iti;o of weld rod oven temperatures, not being incor-porated into master 9 1. aation index, and a scope describing the types ofinstruments /too*a er was not issued to WACo for incorporation into WACo's ,procedures as 14p o 3. k r POAP 9.150, Rev. 3.

WACo's procedures shall be revised to include requirements of M&TE used byWCo in performing safety related construction activities. ,


The corrective action has been taken and verified on Quality Surveillance

Report #82437. This item is ready for NRC teview, and the documentation andother information are available at the Enrico Fermi 2 site.

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Response to NRC Inspection Report No. 50-341/82-10 (82-10-24)1y

| Statment of Nonempliance, 82-10-24, Appendix, Item 7b

| Contrary to the requirments of 10CFR50, Appendix B, Criterion XV and the! Enrico Femi 2 Ouality Assurance Manual, a corponent for the RPV head insula-.

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'l _ tion support frming was released for shipnent to the site, following final; inspection by the Edison Purchasing Department, although a Deviation Disposi-,; tion Request on the itm generated by Warren Service Center was not yet dis-

positioned by Fdison Engineering. This cmponent was, in turn, received on4 cite, and both the equignent and documentation were accepted based on the; 3dison Purchasing Department inspection.

' /Corrective Action Taken and Results Achieved

The subject DDR (N6116-1) is now closed, and a copy has been incorporated in>'the documentation package. All reaining documentation for material received

1'' frm Warren Service Center was reviewed per sits procedures to verify caa-'

pleteness.

Corrective Action Taken to Avoid Further Noncompliarice

Site receiving inspection personnel were retrained on the need to verify that<complete documentation is received before acceptance of the material on site.

Date When Full Cmpliance Will b Achieved

Full compliance has been achieved.

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Documents

e Donald A. Wells veaprow n A m en, Edison EEEE5== · 2020. 2. 11. · Statement of Open Item, 82-10-01, Section II, Item B-2 Contrary to proposed change 46 FR 34595 which rcodifies