IR 05000329/1981003

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IE Insp Repts 50-329/81-03 & 50-330/81-03 on 810127-29 & 0414-16.No Noncompliance Noted.Major Areas Inspected:Open Items,Status of Vent Valve Installations & Site Procedures for Processing Bulletins
ML20004G047
Person / Time
Site: Midland
Issue date: 05/13/1981
From: Danielson D, Sutphin R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20004G046 List:
References
50-329-81-03, 50-329-81-3, 50-330-81-03, 50-330-81-3, NUDOCS 8106290050
Download: ML20004G047 (9)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Reports No. 50-329/81-03; 50-330/81-03 Docket Nos. 50-329; 50-330 Licenses No. CPPR-81; CPPR-82 Licensee: Con :.mers Pouer Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant, Units 1 and 2 Inspection At: Midland Site, Midland, MI Inspection Conducted:

anuary 7-29 and April 14-16, 1981 Inspector:

. N. Sutphin J'/ / 3 / 8'/

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Approved By:

D. H. Danielson, Chief

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Materials & Processes Section i

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Inspection Summary Inspection on January 27-29 and April 14-16, 1981 (Report No. 50-329/81-03; 50-330/81-03)

Areas Inspected: Review of open items; checking status of vent valve installations; site procedures for processing of bulletins, circulars and information notices. The inspection involved a total of thirty-four (34)

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inspector-hours on site by one NPC inspector.

Results: No items of noncompliance or deviations were identified.

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DETAILS Persons Contacted Consumers Power Company Personnel (CPCo)

  • D.

M. Miller, Jr., Site Manager

    • *D. M. Turnbull, MPQA Site Superintendent

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  • D. R. Keating, IE&TV Section Head H. P. Leonard, QA Eng. Section Head R. E. Whitaker, Supervisor QA Eng., Fluids & Mech.

D. E. Horn, Supervisor QA Eng., Civil L. R. Howell, Supervisor IE&TV, Fluids & Mech.

Bechtel

  • M. A. Dietrich, PQAE NRC RIII
  • R. J. Cook, Senior Resident Inspector The inspector also contacted and interviewed other licensee and contractor employees at the site.
  • Denotes those present during the exit interview conducted on April 16, 1981.
    • Denotes those present during the exit interview conducted on January 29, 1981.

Licensee Action on Previous Inspection Findings (Open) Unresolved Item (329/78-20-02 and 330/78-20-02) Effect of ground water on DGB settlement, as covered by 78-12 report, pages 7 and 10, Items 3.d. and 8 respectively, and 78-20, page 9.

As of January 22, 1981, the licensee proposed that this item be considered completed and closed.

"As discussed in the K-T analysis, the effect of ground water on the diesel generator building settlement would be insignificant had the compaction of the (soils) materials been to the proper density. This position is addressed in Howe 218-79 letter to J. G. Keppler, dated August 10, 1979." This item remains open.

(Closed) Noncompliance (329/80-21-01; 330/80-22-01) Zack Co.

Failure to audit supplier, Photon Testing, Inc., for services to qualify Zack Company welders and failure to issue an appropriate purchase order for the work.

The inspector reviewed with CPC0 the; files and records on the five items cf response and action on this noncompliance per J. W. Cook's letter of October 22, 1980.

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1.

The Zack Company assigned a purchase order number (C15496) August 8, 1980, for the purchase to Photon Testing Inc. of services to qualify welders to AWS D1.1-79 and/or AWS D1.3-78.

2.

The Zack Company performed an audit on August 11, 1980 of Photon Testing Inc. using the form from "Q.C. Surveys of Vendors" PQCP-17, Rev. O, Exhibit E, pages 15, 16, 17, 18.

3.

Midland Project Quality Assurance and Bechtel Quality Assurance accompanied Zack Co. on the survey / audit and participated in delinea-tion of the applicable 10 CFR 50 Appendix B criteria and purchase order preparation. The survey / audit was conducted by the Zack Co.,

Corp. Q. A. Mgr. CPC0 has documented their participation via CPC0 memo file 2.10, August 12, 1980, serial 242FQA80, including the AWS attribute checklist dated August 11, 1980.

4.

Consumers Power Co. visited the Zack Co.-Chicago Plant during August 24-27, 1980, and made a similar audit on August 26, 1980 of (PTL) Pittsburgh Testing Laboratory, the supplier of welder qualification services to that Zack plant. The same criteria was used as at the Photon Testing Inc.

survey / audit.

PTL had a QA manual and well documented procedures.

Pre-vious findings from earlier audits were closed and it was concluded that the PTL program met the requirements.

5.

An audit of Zack Co. in Chicago by Bechtel, accompanied by CPCO, September 23-25, 1980, verified that both PTL and Photon Testing Inc.

are on Zack's approved vendor list.

The inspector visited the Zack Co. office on site and reviewed the Photon Testing Inc. audit report of August 11, 1980. The inspector observed that the audit report failed to note that Photon Testing Inc. had in their possession the required referenced standards: AWE DI.1-79 and/or AWS D1.3-78.

Prior to the conclusion of this inspection at the site, the inspector inter-viewed the CPC0 auditor who participated in the au2(r pio verbally confirmed that he had checked the AWS standard in Photon Te s.

q Lic.'s possession at the time of the audit.

This noncompliance is considered closed.

(0 pen)

loncompliance 329/78-17-01; 330/78-17-01.

Persoasol air lock weld cracks and the wrap-around weld issue..The inspector reviewed the status of the action items on the personnel air locks that resulted from the October 15, 1980 meeting between Consumers Power Company, Bechtel, W. J. Woolley Company, and the NRC. The drawings had been revised and the stress report up ated and both submitted by the W. J. Woolley Co. to Bechtel and CPC0 for review. On March 26, 1981, CPCP returned the following comments to Bechtel:

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Comments on Woolley Submittal 1.

The Woolley Drawings No. 30437 and No. 30438 should be revised to reflect the wrap around weld requirements for all stiffener to barrel and stiffener to door frame connections. This should be done for the inside and outside faces of each bulkhead.

2.

The note stating wrap around welds are acceptable that appears at the bottom-center of the Woolley Drawings No. 30437 and No. 30438 should be removed. This note leads to confusion and is not needed when comment No. 1 is incorporated.

3.

It appears that the revisions to the stress reports have not been reviewed by a Registered Professional Engineer. Please confirm a PE approval and preferably by the same PE that reviewe' the original stress reports.

General Comments 1.

Bechtel should revise the disposition of NRC 1185 and incorporate the changes to wrap around welding requirements and any stress re.t.ieving considerations.

2.

It is CPCO's understanding that all work associated with this issue has and will continue to be performed in a fashion to support the maintenance of the N-Stamp on the personcel air locks.

CPC0 concurs with this approach.

Consumers Power Company is now waiting for Bechtel's response or the resubmittal of drawings and data. Consumers NRC No. M01-9-8-096 remains open as well as the NRC noncompliance.

(0 pen) Deviation (329/30-01-02; 330/80-01-03)

"No procedure for handling design changes made after completion of work." CPCO, in their first response to this deviation (HOWE-60-80 dated March 21, 1980), indicated that "Bechtel is revising Bechtel field procedure FDP-1.000(Q), design document and corre-spondence control, in crder to resolve concerns on implementation of design changes to completed work. The specific design change on the make-up and purification systeo, which initiated this deviation, will be effected by completing a new drawing sign-off sheet far the required drawing when the revision to FPD-1.000(Q) is completed. The estimated date for completion of all required actions with regard to this deviation is May 1, 1980."

After discussions with RIII personnel, CPCO indicated that they would supplement their first response.

In the supplemental response (J. W. Cook Serial:

8968, dated May 15, 1980) they advised that it is no longer their intent to change FPD-1.000(Q). The following was submitted as the methods by which such changes will be controlled:

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(a) As part of their. normal activity, Quality Control reviews quality contre.1 inspection records (QCIRS) and reconciles any differences in design document revision numbers.

(b) A freeze will be placed on implementing design changes 90 days prior to scheduled turnover. Bechtel Engineering Department Project Iustruc-tion (EDPI) 4.47.1 will be issued by May 31, 1980 with an implementation date of June 30, 1980 to cover this.

(c) As a part of the quality verification, preparatory to turnover, Quality Control will identify the differences between the design document revision that was used for acceptance inspection on the applicable QCIR's and the revision that is in effect when the design freeze is initiated --- Quality Control will issue a procedure by the week of May 19, 1980 giving the mechanics of the design revision reconciliation process.

(d) In addition to the Bechtel program, CPCO's over inspection program has provided a check in the past and will continue to provide a check that completed work meets the latest design drawings and specifications.

During this inspection the inspector reviewed parts 3.4.2 and 3.5 of Procedure

"AAPD/ PSP G-11.1 Rev. 1, January 30, 1981 - Functional Turnover of Syntr2s, Subsystems and Items - which specifies that the turnover group is required to verify that as installed piping complies with design documents, and this veri-fication shall be noted on the Quality Control Turnover Checklist. This pro-cedure satisfies Part (c) of the above items. This deviation will remain open pending NRC verification of the other (a, b, d) items. (methods) as proposed in the J. W. Cook Serial-8968 supplemental response letter of May 15, 1980.

Licensee Action on IE Bulletins (Closed)79-05A Nuclear Incident at Three Mile Island. All B&W power reactor facilities with an 0.L. submitted for information. No response required (NRR). CPC0 log indicates the bulletin was received April 9, 1979 at Company HP Jackson, MI, and at Site Manager's office on April 10, 1979.

It was assigned to the Project Engineer for review and circulated to the Technical Supervisor and Test Superintendent.

(Closed) 79-08 Events relevant to BWR reactors identified during Three Mile Island incident.

Submitted for information.

(NRR) CPC0 log indicates the bulletin was received April 18, 1979 at Company HQ Jackson, MI, and at Site Manager' office April 26, 1979. A copy was circulated to the Bulletin Coordinator, Test Superintendent and Midland Project Management for information.

The subject matter was not applicable (N/A) to. Midland.

(Closed) 79-13 Cracking in feedwater system piping. Submitted for informa-tion.

(NRR) CPC0 log indicates the bulletin was received June 29, 1979, that nine (9) copies were made and distributed to appropriate project management.

On August 20, 1979 the Project Engineer, CPCO, wrote project Serial 7471 letter-S-

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to the B&W owners group technical _ sub-committee with a concurrence that an

- appropriate technical committee be formed and requesting that CPCO:have an

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opportunity-to, participate in the. subcommittee activities resulting from this bulletin.

(Closed) -79-13 Rev. 2.

Cracking in feedwater system piping. Submitted

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.for information (NRR). CPC0 log indicates this revised bulletin was received October 23, 1979, and that nine (9) copies were made and distributed to t.he same project management who received the original 79-13 bulletin.

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(Open) 79-14 LSeismic analysis for as built safety-related piping systems.

o Submitted for action. The CPC0 log shows that this bulletin was received and assigned to Bechtel for action with followup by HQ personnel in Jackson, MI.

(Closed) 79-21 Temperature effects on level measurements. Submitted for information.

(NRR) CPC0 log indicates that this was assigned to the pro-ject engineer at Jackson and that copies were distributed.for information.

Action on the subject of this bulletin was subsequently requested by R. L. Tedesco, Assistant Director, Division of Licensing, in his memo of September _4, 1980, as request number 031.54, including four (4) questions that CPCO is requested to respond to and to revise their FSAR consistent-with the~ responses. This bulletin is considered closed as the response's will be addressed in the FSAR question.

(Closed).'79-26 Boron loss from BWR control blades.

Submitted for informa-tion.

(NRR) CPC0 log shows the bulletin was received November 28, 1979 and

eight-(8) copies were made a'nd distributed to the project organization for information. The. subject matter was not applicable (N/A) to Midland.

(Closed) 80-05 Vacuum condition resulting in damage to chemical volume control system (CVCS) holdup tanks. Submitted for action.

CPC0 log shows that the bulletin was received March 13, 1980 and that letters to the A.E.

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and NSSS were sent on March 17, 1980, for review of applicatica to Midland.

CPC0 received a response from.the A.E. on May 30, 1980 which listed the tanks that may be susceptible to the problem of vacuum in the tank system. On June 19, 1980 a letter was forwarded from Project to Operations Group (S-9044)

requesting that OPS develop a preventative maintenance plan. At the same time

.CPC0 made their initial response to the NRC (S-9047) which included a list of the: tanks. An interim response (BLC 9525) was received from the A.E. on

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July 29, 1980 and a final response with reports of design review (BLC 9785) on September 26, 1980'

CPC0 completed their review of the bulletin and forwarded i

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their' completed action response to the NRC (S-9858) on October 10, 1980. An

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' internal CPCO memo on-December 18, 1980 recorded the fact that plant maintenance procedures MAME 9625.3 and MAME 9625.5 had been assigned for two relief valves,

j the valves have been entered in the (PACS)-Periodic Activity Control System,

and PACS control sheets have been established.

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Functional or Program Areas Inspected

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1.

Reactor Internals Vent Valves - Status of Installation, Unit 2 a.

The inspector reviewed the status of the discrepancies noted by the Resident Inspector during his inspection of the internals vent valve installations activity on January 15, 1981. CPC0 had stopped work on January 16, 1981, after the discrepancies were noted by the NRC Resident In pector, and agreed not to lift the Stop wwrk Order and resume the installation work until the dis-crepancies were resolved to the satisfaction of the NRC.

CPC0 had initiated or had resolved to take action on the following:

(1) Installation procedures would be revised as appropriate, (2) Indoctrination and training of personnel performing the installation and the inspections would be reviewed, strengthened and reconducted as nece sary.

(3) The overview inspection plan would be revised to eliminate further problems.

b.

The inspector received and reviewed the following documents:

(1) B&W Construction Company Field Construction Procedure No. 298 (FCP-298), Revision No. 1 of September 11, 1980, titled, " Installation of Vent Valves".

(2) CPC0 Project Inspection Plan 03-M-41 of January 16, 1981, titled, " Installation of Vent Valves Reactor Internals".

(3) B&W Construction Company NCR No. 1767 Report of Nonconformity dated January 16, 1981, titled, "R.V.

Internals 14" Vent Valves", Job No. CL-238; re:

requirements of Access Control Procedure 9-CP-101.

(4) List of attendees for meeting held January 20, 1981 to discuss requirements of Access Control Procedure 9-CP-101 as the corrective action for B&WCC Nonconformance Report 1767.

c.

CPC0 advised that they were waiting for B&W to revise FCP-298, which was held up pending receipt of requested information on the crimping tool used in Operation Sequence No. 060. Training in the revised FCP-298 would be conducted prior to a review with the NRC and a decision to lift the CPC0 Stop Work Order.

d.

No action was taken on January 29, 1981 by the NRC to give 'inal approval of any action taken to date by CPC0 on this item or to prepare detailed acceptance of items prior to the review for

. lifting the Stop Work Order.

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Subsequent to the inspection of January 29, 1981, the NRC review for lifting the stop work order was completed and 'he stop work order was lifted on February 10, 1981, as reporte-t inspection report 50-329/81-04; 50-330/81-04.

2.

Midland Plant Procedure (s) - For the Processing of NRC Bu?letins, Circulars and Information Notices, at the Midland Site a.

The inspector reviewed the Midland Plant Procedure " Station 1040.10, Rev. 1, April 6, 1981", Subject - Processing of'NRC Bulletins, Circulars and Information Notices. The subject proce-dure was initially prepared and submitted by the Site Technical Engineering office December 17, 1980, reviewed by QA March 9, 1981 and approved by the Plant Manager April 6, 1981. This procedure references MPP-18 from the Midland Project Procedures Manual and covers the handling at the site by the assigned technical engineer those bulletins, circulars and information notices forwarded by the Project Management office. The procedure referenced three standard forms as enclosures to assist in the documentation of the activity.

Form 1040.10F2 provides for the identity of file numbers, the assign-ment to individuals and the record of evaluation for applicability to the Midland Power Plant. Form 1040.10F3 is the status sheet / log

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form which provides for a log record of the activities associated with the bulletin, circular, or information notice from the date of -

receipt to the close out of action at the site. The third form is the standard form used for the close out record of site action on each bulletin, circular or information notice, and provides for (UFI) uniform filing index and (DDC) document control center informa-tion for each completed document package.

b.

The inspector reviewed the technical engineers file on the activity associated with Bulletin 80-09, as a sample, and found the file to be in accord with the procedures.

It was noted by the inspector that the procedure did not specifi-c.

cally address the question of a timely review and initiation of site activity after receipt of a bulletin, circular, or information notice at the site. This was brought to the attention of the Technical Engineer and the Site Manager, and although there were no indications in the record of excessive delays or unacceptable levels of activity, they will review this aspect of the procedure for adequacy. This is considered an unresolved item.

(329/81-03-01; 330/81-03-01).

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. An unresolved item disclosed during this inspection is discussed in Paragraph 2.c.

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Exit Interview

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. The inspector met' with site representatives (denoted -in Persons Contacted paragraph) on April 16, 1981.and January 29, 1981, and at'the conclusion-of the insocction. _The inspector summarized the scope and findings of the inspection, which were: acknowledged by the licensee.

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