IR 05000329/1978007
| ML20058A122 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/11/1978 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 7810200211 | |
| Download: ML20058A122 (2) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION E 1 ) 'e E
REGION 881
Md ROOSEVELT ROAD GLEN Et LYN, ILL:NoIS 60137 001 111973'
Docket No. 50-329 Docket No. 50-330 Consumers Power Company ATTN:
Mr. Stephen H. Howell Vice President 1945 West Parnall Road Jackson, MI 49201
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Gentlemen:
This will acknowledge receipt of your letter dated September 18, 1978, (
which was submitted in response to the item of noncompliance identified in our letter dated August 17, 1978, and IE Inspection Report No.
50-329/78-07 and No. 50-330/78-07.
Your letter has been reviewed, and particular attention was given to the information presented, as well as your belief that no item of noncompli-ance occurred. Our position remains that this item is considered an item of noncompliance (2 examples) and, as such, we do not consider the actions delineated in your letter to be fully responsive as described below. There-fore, we request that you submit a second letter to adequately respond to this item within 10 days following receipt of this letter.
With respect to item 1, we are concerned that Seismic I HVAC systems were being installed by contractor personnel utilizing uncontrolled / superseded drawings and that their personnel were unf amiliar with established draw-ing control measures, as described in Section II, Paragraph 3 of thE refer-enced inspection report. Moreover, this concern is further amplified by (
your response which indicates that several weeks had elapsed before thi's~
contractor received the latest approved drawing revisions for use,_i.e.,
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drawings C-884, Revision 2 and C-241, Revision 9 were espproved by. Bechtel on June 2, 1978 and May 18, 1978, respectively, were received / processed by the sita document control center on June 13, 1978 and May 24, 1978, respec-tively, and were received by the contractor for use on July 31, 1978.
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With respect to item 2, Bechtel Procedures FPD-1.000 and FPD-3.000 (current revisions) have not provided the controls necessary to preclude contractor personnel from using outdated documents, as described in Section II, Paragraph 3 of the referenced inspection report and, as identified during Bechtel QA audits of site contractors (described in your response and in a previous IE inspection report as Unresolved Item 329/78-04-04; 330/78-04-03).
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Specifically, we are concerned about the lack of controls / requirements,
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governing all superseded drawings that are not destroyed. Further, your practice of allowing superseded drawings and controlled drawings to be-stored on the same working stick, and thus readily available for use by contractor personnel has not been effective. In this regard we require that measures be established for superseded documents not destroyed such
that access to these documents is controlled / specified, and that their
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use is limited to nonquality related activities.
With respect to your offer to provide a presentation on Bechtel's method l
of design document control to RIII personnel, the resident inspector will arrange for this briefing at his convenience. We also encourage that Bechtel provide this training to contractor personnel so that they will be faciliar with this complex subject, and perhaps similar items of noncompliance may l
be avoided.
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The contents of this letter were discussed with Mr. B. W. Marguglio of your staf f, by Mr. R. F. Heishman, of my staff on September 28, 1978.
Sincerely,
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James G. Keppler l
Director cc: Central Files
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Reproduction Unit NRC 20b PDR Local PDR NSIC TIC (
Ronald Callen, Michigan Public Service Commission j
Dr. Wayne E. North l
Myron M. Cherry, Chicago l
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