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. . U.S. NUCLEAR REGULATORY REGION III Report No. 50-341/83-05(DPRP) Docket No. 50-341 License No. CPPR-87 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name: Enrico Fermi Nuclear Power Station, Unit 2 Inspection At: Fermi Site, Monroe, MI Inspection Conducted: January 1 through February 28, 1983 //[/ g Inspectors: li.t t hrd- -a d w u@ ' H. M. Wescott # B 4?!ng& d 9 Approved By: J.E.Konkln, Chef / a ' Projects Section 2 Inspection Summary Inspection on January 1 through February 28, 1983, (Report No. 50-341/83-05 (DPRP)) Areas Inspected: Action on Previous Inspection Findings; Followup on IE Bulletins; Followup on IE Circulars; Followup on 50.55(e) reports; Pre- operational Testing; Independent Inspection; and Plant Tours. The in- spection involved a total of 252 inspector-hours onsite by three NRC inspectors, including 46 inspector-hours onsite during off shifts. Results: Of the seven areas inspected, three items of noncompliance were identified in two areas: Failure to follow procedures, inadequate .eview of procedure changes and inadequate ider.tification and control measures (Paragraphs 6 and 7). h.[hhDC d 0

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U.S. NUCLEAR REGULATORY

REGION III

Report No. 50-341/83-05(DPRP)

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

Licensee: Detroit Edison Company2000 Second AvenueDetroit, MI 48226

Facility Name: Enrico Fermi Nuclear Power Station, Unit 2

Inspection At: Fermi Site, Monroe, MI

Inspection Conducted: January 1 through February 28, 1983

//[/ gInspectors: li.t t

hrd- -ad w u@ '

H. M. Wescott # B

4?!ng& d9Approved By: J.E.Konkln, Chef / a'

Projects Section 2

Inspection Summary

Inspection on January 1 through February 28, 1983, (Report No. 50-341/83-05(DPRP))Areas Inspected: Action on Previous Inspection Findings; Followup on IEBulletins; Followup on IE Circulars; Followup on 50.55(e) reports; Pre-operational Testing; Independent Inspection; and Plant Tours. The in-spection involved a total of 252 inspector-hours onsite by three NRCinspectors, including 46 inspector-hours onsite during off shifts.Results: Of the seven areas inspected, three items of noncompliancewere identified in two areas: Failure to follow procedures, inadequate.eview of procedure changes and inadequate ider.tification and controlmeasures (Paragraphs 6 and 7).

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DETAILS

1. Persons Contacted'

*T. Alessi, Director, Project QA*F. Agosti, Assistant Manager, Startup TestingH. Arora, Startup Engineer

*W. Everett, Assistant Project Superintendent, ConstructionW. Fahrner, Manager, Fermi-2 ProjectD. Ferencz, Supervisor, Construction QA

*E. Griffing, Plant SuperintendentA. Godoshian, Systems Completion DirectorW. Holland, Vice-President, Fermi-2 Project

*S. Leach, Senior Administrator SecurityR. Lenart, Assistant Plant SuperintendentT. Minton, Startup Director

*T. Nickelson, Startup Engineer*G. Newton, QA Supervisor, Operational Assurance*S. Noetzel, Site Manager*G. Trahey, Assistant Director, Project QA

* Denotes those attending monthly management meeting.

2. Licensee Action on Previous Inspection Findings

(Closed) Open Item (341/82-10-15) Wismer and Becker (W/B) QC InspectorsPerceived Lack of Management Support for QC Activities. W/B QC inapectorconcerns were identified during the'NRC Construction Assessment Teaminterviews with site contractors' QC Inspectors. The QC inspector con- |

cerns related to inadequate and untimely response from W/B QC supervisionand engineering. .The inspector has completed review of licensee responsein this matter. Action taken by W/B to alleviate QC inspector concernsincluded; W/B PQM weekly meetings with all department personnel, revisionof W/B procedures, reassignment and indoctrination of QC supervisors and,

providing explanations for all DDRs dispositioned "use as is". Correctiveaction taken appears adequate. This item is considered closed.

3. IE Bulletin Followup.

For the IE Bulletins listed below the inspector verified that the Bulletinwas received by licensee management and reviewed for its applicability tothe facility. If the Bulletin was applicable the inspector verified thatthe written response was within the time period stated in the Bulletin,that the written response included the information required to be reported,that the written response included adequate corrective action commitmentsbased on information presented in the Bulletin and the licensee's response,that the licensee management forwarded copies of the written response tothe appropriate onsite management representatives, that information dis-cussed in the licensee's written response was accurate, and that corrective jaction taken by the licensee was as described in the written response.

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IEB 72-03 (0 pen) Limitorque Valve Operator Failures. The licensee didnot have documentation which confirms that the subject switches have beenreplaced. The inspector considers this item to be open.

IEB 73-01 (Closed) Faulty Overcurrent Trip Delay Devices in CircuitBreakers for Engineered Safety Systems. The Bulletin referencedWestinghouse circuit breakers. This Bulletin is not applicable to Fermiwhich has all ITE circuit breakers. Random inspections by the inspectorhave revealed no Westinghouse circuit breakers. This item is consideredclosed.

IEB 73-05 (0 pen) Manufacturing Defects in BWR Control Rods. The in-spector was unable to locate a GE response to a DECO request for assurancethat the quality problems described would be corrected prior to fabrica-tion of the DECO control rods.

IEB 74-01 (Closed) Valve Deficiencies. An engineering review revealedthat none of the valves which were described in the Bulletin were scheduledto be used at Fermi.

IEB 74-04 (Closed) Malfunction of Target Rock Safety-Relief Valves.An engineering review determined that Fermi has two-stage Target Rocksafety-relief valves rather than the three-stage valves which incurredthe problem. This item is considered closed.

IEB 74-06 (0 pen) Defective Westinghouse Type W-2 Control Switch Component.The inspector was unable to locate either an engineering review or aresponse to the NRC.

IEB 74-08 (0 pen) Deficiency in ITE Molded Case Circuit Breakers, TypeHE-3. There was no response to the NRC. DECO concluded with ITE thatincorrect test procedures gave the described deficiencies. Four circuitbreakers (15A, 30A, 60A, and 90A) were tested at the DECO relay lab. Thetest results were satisfactory when performed with the proper test pro-cedures and it was concluded that the breakers were acceptable for use.

IEB 74-09 (Closed) Deficiency in the GE Model 4KV Magne Blast CircuitBreakers. An engineering review concluded that there are no GE circuitbreakers less than 15KV at Fermi. The inspector has not seen any GEcircuit breakers less than 15KV during random tours of the site. Thisitem is considered closed.

IEB 74-10A (Closed) Failures in 4-inch Bypass Piping at Dresden 2. Fermiremoved the affected piping. This is addressed in 5.2.3.2.1 of the FSAR.This item is considered closed.

IEB 74-12 (Closed) Incorrect Coils in Westinghouse Type SG Relays. Fermidoes not use Westinghouse type SG relays. In addition, DECO has a test-ing program which requires verification of relay types and coils whenapproved for service prior to preoperational testing. This item is con-sidered closed.

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IEB 74-13 (Closed) Improper Wiring in General Electric Motor ControlCenters. Fermi uses ITE motor control centers. Engineering reviewindicates that GE Vulkene "600" cable was not used in safetyrelatedbreaker-starters. The inspector considers this item to be closed.

IEB 74-15 (Closed) Misapplication of Cutler-Hammer Three-PositionMaintained Switch, Model No. 702507. DECO investigation revealed theaffected C-H switch was not specified or installed in existing equipmentnor was it planned to be used on safety-related systems. This item isconsidered to be closed.

IEB 74-16 (Closed) Improper Machining of Pistons in Colt Industries(Fairbanks-Morse) Diesel Generators. Fairbanks-Morse corrected thedescribed deficiencies by intensified inspections and a design modifica-tion which were included in the Fermi diesels. The inspector reviewedFairbanks-Morse documentation. This item is considered to be closed.

IEB 75-01 and 75-01A (Closed) "Through-wall Cracks in Core Spray Pipingat Dresden-2." Fermi made changes to reduce the susceptibility to ISSC. These changes are summarized in 5.2.3.2.1 of the FSAR and 5.2.32 ofthe SER. This item is considered closed.

IEB 75-04 and 75-04A (0 pen) " Cable Fire at Browns Ferry Nuclear PowerStation." Fermi's response to this bulletin will be included in theirAppendix R submittal. This bulletin remains open pending NRR review andapproval of the Appendix R submittal.

IEB 76-01 (Closed) "BWR Isolation Condensor Tube Failure." This bulletinis closed as Fermi 2 does not utilize Isolation Condensors.,

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IEB 77-01 (Closed) " Pneumatic Time Delay Relay Setpoint Drift." Therelays were inspected and found to be manufactured in 1974. Two relayswere found with no production number. These were replaced. The actiontaken appears to be in accordance with the licensee's letter EF2-37,322dated July 27, 1977, to RIII. This bulletin is considered closed.

| IEB 77-08 (Closed) " Assurance of Safety and Safeguards During an| Emergency - Locking Systems." The inspector reviewed the following:

a. DECO Letter, EF2-39,817 dated February 21, 1978, stating that Stoneand Webster had been notified that all electrically operated doorlocks be provided with manual override.

! b. DECO letter EF2-39,865 dated February 28, 1978, stating that doors| used for emergency egress will be provided with mechanical override,l loss of power to be restored via diesel generator, doors to vital

areas are to be checked every eight hours.|

| The licensee's action appears to be in accordance with their letter toRIII, EF2-41,087, dated March 1, 1978. This item is considered closed.

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IEB 78-14 (0 pen) " Deterioration of Buna-N Components in ASCO Solenoids."The inspector reviewed DECO letter EF2-60021 dated September 22, 1982,stating that purchase order has been written to obtain rebuild kits forthe subject solenoids. This item remains open pending the licensee pro-.viding documentation indicating that the solenoids have been rebuilt.,

IEB 79-11 (Closed) " Faulty Overcurrent Trip Devices in Circuit Breakersfor Engineered Safety Systems" Deco letter EF2 -46,898 dated June 19, 1979,to RIII states that Fermi-2 does not use Westinghouse low-voltage power'

circuit breakers. This item is considered closed.

No items of noncompliance or deviations were identified.

.4. IE Circular Followup

For the IE Circulars listed below, the inspector verified that the Circularwas received by the licensee management, that a review for applicabilitywas performed, and that if the circular were applicable to the facility,appropriate corrective actions were taken or were scheduled to be taken.

IEC 76-01 (Open) " Crane Hoist Control-Circuit Modifications." The in-spector was unable to locate documentation to support review. This itemremains open pending a review of the' documentation by the inspector.

IEC 76-02 (Closed) " Relay Failures--Westinghouse BF (ac) and BFD (de)Relays." The licensee's review revealed there are no Westinghouse BF orBFD relays in Class IE systems. This item is considered closed.

IEC 76-03 (Closed) " Radiation Exposures in Reactor Cavities." The li-; censee's review determined that the problem described could not occur in! a BWR. The review additionally revealed two other mechanisms by which

high radiation transients could exist in the drywell. Measures have been'

taken to minimize this transient. This item is considered closed.

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| IEC 76-04 (Closed) " Neutron Monitor and Flow By-Pass Switch Malfunctions."| GE supplied improved neutron monitoring switches in response to their

Service Letter SIL III, Revision 1, dated August 29, 1975. This item is<

considered closed.I

No items of noncompliance or deviations were identified.,

S. Review of Licensee Action on 19 CFR 50.55(e) Reports

; 10 CFR 50.55(e) report dated October 28, 1982, NRC No. 80-07, LicenseeNo. F-32. Failure of ITE/ electro switch undervoltage relays used in>

diesel generator 480V load shedding system.

| This item remains open pending the licensee's installation and successfultesting of.the replacement relays.

10 CFR-50.55(e) report dated December 10, 1980, NRC No. 80-10, Licensee'sNo. 35. Inadequate pipe clearance for QA level I piping and equipment.

.The inspector reviewed the following:,

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a. Letter F2S80-0314, Revision A, dated February 18, 1981, DECO to siteSuperintendent establishing pipe clearances,

b. Letter EF2-52,051, dated January 20, 1981, Deco to Director of FieldEngineering directing and establishing pipe clearance criteria.

c. Letter dated December 18, 1980, DECO to Director of Field EngineeringAction plan to establish priority for review and modify large boreand SRV piping.

! d. Check lists for various systems with corrective action where required.

The licensee's action appears to be in accordance with their final reportto RIII EF2-49,876, dated January 7, 1981, with the attached deficiency

, report. This item is considered closed.

10 CFR 50.55(e) report dated December 29, 1980, NRC No. 80-11, Licensee'sNo. F-36. Transverse in-core probe instrument tube design deficiency.The inspector reviewed the following:

a. DECO final report to QA dated January 6, 1982, on TIP Guide Tubesstating that tests were performed on four test samples simulatingaxial compression forces expected under LOCA conditions. Three test

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pieces did not leak, one developed a very small leak at the flarejoint. In no instance did the tube wall fail,

b. Photos of test technique.

The licensee's action appears to be in accordance with their finalreport to RIII, EF2-55873, dated January 11, 1982. This item is

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considered closed.'

! 10 CFR 50.55(e) report dated June 26, 1981, NRC No. 81-07, Licen'ee'ssNo. 45. Rockbestos coaxial cable problem. The inspector reviewedthe following:

a. Rockbestos qualification of firewall III class IE electrical cablesdated June 7, 1978. The purpose of the test program was to documentthat the cable will function during a LOCA as prescribed by IEEE-383-74.

b. DECO letter to supervising engineer, EQ-64, dated April 13, 1982,;

| stating the reasons for using the existing cable were:i

(1) Unavailability of an acceptable alternate with required electri--

cal characteristics.

(2) The SRM circuits are no IE.

(3) Triple shielded cable is required per GE in order to allow properSRM operation. Second generation cable should be used whentested and available.

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c. DECO letter to QA, EF2-59252, dated September 9, 1982, recommendingthe use of Rockbestos cable RSSS-6 series 100 through 112.

The licensee's action appears to be in accordance with their final reportto RIII, EF2-60507, dated November 16, 1982. This item is consideredclosed.

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'10 CFR 50.55(e) report dated December 7, 1981, NRC No. 81-11, Licensee'sNo. F-49. Deficiency in Control Data Corporation Computer Program. Theinspector reviewed the following:

|a. Control Data Corporation letter to supervisor of construction, dated

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December 29, 1981, stating that the NRC was provided the following: 1

(1) A list of CDC users who were notified.

(2) Description of three errors in the V.I.O. |

(3) A copy of the Baseplate User Manual.

b. Attachment to the final report to RIII, EF2-57,705, "Enrico FermiPower Plant - Unit 2 deficiency report errors in computer programused to design QA level 1 pipe supports." It was concluded investi-gation that the original design of the supports that could have beenaffected by this design deficiency and finding that none of thesesupports required modifications, that QA level 1 support integritywas preserved.

The action taken by the licensee appears to be in accordance with |

their final report to RIII, EF2-57467, dated April 15, 1982. Thisitem is considered closed.

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10 CFR 50.55(e) report dated February 18, 1982, NRC No. 82-08, Licensee'sNo. F-57. RHR piping design deficiency.

| This item has been turned over to the Material Testing Branch and| will be reviewed at a future date. This item remains open.

10 CFR 50.55(e) report dated February 22, 1982, NRC No. 82-09, Licensee'sNo. F-58. Cracking of diesel general fuel oil storage tank concretemounting pedestal. The inspector reviewed the following:

(a) NCR 82-029 dated February 20, 1982, and NCR 82-026 datedFebruary 19, 1982.

(b) DECO letter F25-82-0428 dated February -25, 1982, stating thatthe pedestal repair and modification had been visually inspectedand found satisfactory.

The inspector visually examined the pedestal repair and modificationand found that certain hold-down nuts (tank feet to pedestal) had

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been tightenet such as not to allow thermal movement of the tank onthe sliding joint. This was discussed at the exit meeting held on' January 26, 1983. It was suggested that these nuts be loosened andlocked in place to allow movement due to temperature changes. The,

licensee stated that a means would be provided to lock the nuts inplace.

This item remains open pending corrective action by the licensee.

10 CFR 50.55(e) report dated February 22, 1982, NRC No. 82-10, Licensee'sNo. F-59. Emergency diesel generator relay failures.

]The inspector reviewed the following:

(a) NCR 82-025 dated December 18, 1982, with Appendix A descriptionof proposed corrective action.

(b) DECO Operational Assurance PQA 82-167, dated March 10, 1982,approving NCR 82-025.

(c) Startup Form 7.8 (Revision 1) indicating the dates the relavswere tested with QC hold point for re-inspection.

' The action taken by the' licensee appears to be in accordance withtheir final report-to RIII,.EF2-60512 dated November 19, 1982. Thisitem is considered closed.

10 CRF 50.55(e) report dated April 1, 1982, NRC-No. 82-16, Licensee'sNo. F-65. Tubing within instrument rack routed incorrectly. The inspector

: reviewed the following:

; (a) DDR(MP) 8067, dated March 23, 1982, describing problem. Disposi-tion complete and approved on April 27, 1982.

(b) Report of defects and noncompliance problem on instrument paneli H21-1420 lines to V8-2213 and V8-2214 were reversed.I

(c) Wismer and Becker operations process traveler, rework of rack,dated March 25, 1982.

The inspector visually examined the rework. The action taken by the4

licensee appears to be in accordance with their final report to RIII,EF2-61527, dated December 23, 1982. This item is considered closed.

6. Preoperational Testing,

The inspectors reviewed the partial results of the two preoperational tests,-PRFT B1113.001, Revision 2, " Reactor Vessel. Flow Induced Vibration Test"

(FIVT) and PRET B3100.001, Revision 1, " Reactor Recirculation System".The recirculation pump coast down section of the recirculation test andthe data from the FIVT were reviewed.

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The inspector has several concerns regarding the adequacy of review ofTest Change Notices (TCNs) and the adherence to procedures.

Section 8.3.1 of the'Startup Manual (SUM) requires the review of each test. procedure to determine that the test procedure is complete, accurate, andup-to date. Section 8.3.3 of the SUM requires that the review of a TCNshall be.the same as that given any procedure revision which receives thesame review and approval process as the original' procedure received. Whileperforming the FIVT, TCN 455,was written to modify the test procedure.- Item 1 of TCN 455 deleted steps 6.1.2.4 through 6.1.2.7 and 6.2.1 through6.2.6 with the explanation that they were contained in an attached RCI pro-. cedure. The deleted procedural steps reverified the valve line up, filledthe-vessel, installed the steam separator, and head, sampled the coolant,filled and_placed the RHR system into operation, placed the RWCU systemin operation and heated the vessel. The RCI procedures only cover theinstallation of the separator and head and installation of the dryerlifting eyebolts. Step 2 of the TCN added two of the steps which weredeleted in Step 1, the valve lineup reverification and the vessel fill.The two steps were placed back into the procedure.with no reason for thereinsertion of the deleted steps. Review of the RCI procedures revealedthat none of the deleted steps were contained in the RCI procedure. Thesteps deleted by TCN 455 rendered the FIVT procedure incomplete and in-adequate, contrary to the requirements of Section 8.3.1 of the SUM.This is considered as item of noncompliance (341/83-05-01).

Sections 4.5.4 and 8.3.3 of the SUM state that the TCN shall only be usedwhen the changes are small in number. TCN 442 added 3 1/2 pages of pro-cedure, TCN 449 added ten pages of procedure, TCN 455 deleted 2 1/2 pagesof procedure,. TCN 456 added 34 major procedura1 ' steps plus sub-steps, andTCN 484| cancelled part of TCN 442 and added 21/2 pages of procedure.The inspector does not consider the above' changes to be small in number.This is considered to be an item of noncompliance (341/83-05-02a).

The inspectors are concerned about the control of testing. Program Policy5 of the Operations Quality Assurance Manual requires that activities

; affecting quality shall be prescribed by appropriate documented instruc-| tions and procedures and shall be accomplished in accordance with those

documents. A review of the FIVT test procedure and the Test AnalysisReport revealed that reactor-level, pressure, and temperature were con-trolled without-benefit of documented instructions or procedures and thisis considered an item of noncompliance (341/83-05-02-b).

! The above are additional examples of a lack of procedural discipline inthe performance of preoperational testing. Procedural discrepancies were

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! also identified during the performance of preoperational testing of the

f Standby Liquid Control System (PRET C4100.001) and the Reactor Recircula-tion System (PRET B3100). These discrepancies were documented in NRCinspection Report 50-341/82-20.

A procedural requirement of SI 4.5.1.01, Administrative Control of StartupOriginated Procedures and Test Change Notices, is that the changes andthe reason for the change must be listed in the TCN. TCN 455, Step 2,

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added two procedural steps which were deleted by Step 1 of the procedure; but no reason was given for the reinsertion. TCN 456 added 34 procedural

steps plus sub-steps with no reason given for the change.

The inspectors are concerned about the adequacy of the review of the pro--cedure changes. The above examples contain both procedural and technical,

inconsistencies. These changes were reviewed and signed off by the'

responsible parties from Engineering QA and Startup. The inspector couldfind no evidence that any of the reviewing parties questioned the changes.,

It does not appear that these TCNs were reviewed in accordance with Section8.3.3 of the SUM.

7. Independent Inspection

a. Allegations and Concerns,

(1) Quality Control of Penetration Fire Seals

On February 3, 1983, a craftsman employed by the penetration>

fireseal contractor, SACO/ICMS (S/I), made allegations relatingto penetration fire seals deficient quality controls and practices.The following allegations were made:

(a) Penetration seals P-1037 and P-1039 had been QC accepted'

but did not meet acceptance criteria.

(b) .A lack of quality controls for the mixing compounds and themixing equipment used in making penetration seals.

The inspectors investigated the allegations and found thatAllegation (a) was unsubstantiated. A review of QA recordsrevealed that the subject penetrations had not been QC inspected

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thus could not have been QC accepted. The investigation revealedthat Allegation (b) was substantiated. The inspectors foundthat mixing equipment and material was left unattended and un-secured in several areas of the Auxiliary Building. They also

l' observed that the five gallon containers of mixing compound werenot sealed, there were some with unsealed, partially open, or,

removed lids, (dirt contamination was visible in some uncoveredcans) and lacked adequate quality control labels. The inspectorsalso observed that the crafts provided QC with compound samplesat the beginning of each shift and after maintenance was per-formed on the equipment. QC did not take random and independent<

i samples of sealant materials.

-The control measures in place for this activity failed to assureidentification of and prevent the use of incorrect or defectivematerials, and is in noncompliance with Criterion VIII of 10CFR 50, Appendix B (341/83-05-03).

On February 5,1983 the inspectors met with S/I and licenseeQA representatives. During this meeting, inspection findings

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were discussed and an in-plant tour was made. Both licenseeand site contractor acknowledeged the need for additionalcontrol measures. The following corrective actions were im-plemented:

storage of all mixing materials in a secured area.

covers for unattended mixing equipment.

attachment of material identification labels to all.

containers

random material sampling by-QC.

On February 14, 1983 S/I revised and implemented the followingprocedures:

PWI-052 Installation of Silicone Rubber Foam

QC-101 Quality Control Inspection

QC-131 Material Storage and Handling

The inspectors verified that the above corrective measures wereincoporated in the revised procedures. Compliance with therevised procedures should preclude the recurrence of deficientquality practices in this area.

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The inspectors have completed their review of this matter. Noresponse to this item is required since appropriate actions havebeen taken to correct the noncompliance.

(2) Startup Organization Quality-Related Activities

-On February 3, 1983, NRC Region III management and the Senior_

Resident Inspector performed a tour of Fermi-2 facility. Duringthe tour a Project Quality Assurance Inspector (PQA) expressedhis concern of certain quality-related activities at Fermi.

On February 4, 1983, the SRI met with the PQA Inspector in anattempt to obtain any specific allegations or concerns. ThePQA Inspector stated he did not know of any wrongdoings or non-conforming conditions which had not been documented or reported,but he did have the following concerns:

(a) Inadequate corrective action (core spray bellows)

(b) Startup lacked adequate configuration control (he referredto NRC Open Item 79-17-01).

(c) System Test Engineers (STE) had trouble knowing actualsystem configuration at the time of testing.

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Items (a) and (b) both relate to NRC identified problems: Item(a)--was. initially reported by the licensee and was reported asa 50.55(e) (82-04). NRC followup inspection found that thelicensee's corrective action was not adequate. This matterresulted in an item of noncompliance (82-01-06). Item (b)--re-lates to NRC Open Item (79-17-01) Design Change Controls (DECO)Startup. This matter relates to the lack of control measuresfor design changes to systems which were to be turned over tostartup for testing. In November 1981, (prior to-the start ofpreoperational testing of safety related systems) Deco estab-lished the System Completion Organization, with it the respons-ibility and the administrative procedures for configurationcontrol. This item was inspected and closed in NRC InspectionReport No. (82-20). Item (c) concern was valid for the periodprior to 1982. Since then DECO has required drawing revisionswhen design changes exceed five, also the System Test Engineerand Lead Systems Test Engineer must initial changes to systemsfor which they are responsible. Drawing and change controlprocedures together with required system walkdowns shouldprovide STEs adequate knowledge of system configuration at timeof testing.

The inspector considers this matter closed.

B. Quality Assurance Implementing Procedures

This review was performed to ascertain implementation of QA/QCprograms and procedures, including appropriate processing anddispositioning of Deviation Disposition Requests (DDRs) and Sur-veillance Reports (SRs). As part of this review the inspector,

interviewed Wismer and Becker (WB) QA/QC Inspectors and Supervisors.The inspector reviewed the following documents:

Procedures: WB-QA Manual| WB-E-138 Deviation Disposition Request| WB-Q-113 Quality Surveillance Reporting

DDRs: 9484 CRDHS IW Piping4128 - Weld End Attachments for Snubbers4209 - Snubber Stroking Problems4172 - Hanger Lug Retainers

SRs: Fourteen Surveillance Reports--various surveillance matters

The inspector found that WB DDRs had been processed and disposi-tioned in accordance with WB procedure. Surveillance Reports, whichhad been entered in WB tracking system, had been appropriatelyprocessed. The inspector found that WB QC frequently used SRs toinquiries as opposed to documenting practices and adverse qualityconditions. The disposition or response to SR of inquiry was oftenbrief, not fully addressing QC inspector's questions.

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During interviews with WB QC inspectors, the inspector was told thatsome SRs would not be processed (would be discarded by QC supervision),

i and other SRs were being dispositioned by the lead QC Inspector with-out processing the SR in accordance with WB Q-113 Quality SurveillanceReporting. The inspector reviewed one SR which had not been assigneda SR number nor entered in the WB Surveillance Log. In response tothe inspector's question regarding the discarding of SRs, the WB QA

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| Field Supervisor stated that he had discarded some SRs which he con--sidered to be "not adverse to quality" and for which verbal answers,

were appropriate.j

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The practice of " field dispositioning" voiding or discarding of SRsis not in accordance with WB-Q-113 which states in part, "...The<

! Project Quality Manager shall maintain a suspense log (SurveillanceReport Computer Log) and' assign a serial number. The PQM willassign the responsibility for dispositioning the Surveillance Reportand forward the form for dispositioning."

1 . Failure to accomplish activities in accordance with procedures iscontrary to DECO Operational Quality Assurance Manual, Section 5,Paragraph 4.3. This is another example of an item of noncompliance

i .with Criterion V of 10 CFR 50, Appendix B (341/83-05-02-c)..

8. Plant Toursi

' The inspectors conducted tours of the RHR complex, the Reactor, Auxiliaryand Turbine Buildings and the Rad Waste area. These areas were inspectedfor general housekeeping / fire prevention practices, work controls, and

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maintenance of safety-related system integrity. The inspectors have noted' continued attention'and effort is being given to housekeeping. The in-

spectors also observed the. starting and running of Diesel GeneratorsNos. 11 and 12.

No items of noncompliance or deviation were identified.

9. Exit Interview

The inspector met with licensee representatives (denoted in Paragraph,

1) at the conclusion of the inspection and summarized the scope and*

findings of the inspection, including the items of noncompliance. The>

licensee acknowledged these findings and was responsive to the need forj ' additional control measures in these areas.

1

d

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