IR 05000329/1981004

IE Insp Repts 50-329/81-04 & 50-330/81-04 on 810101-0214. Noncompliance Noted:Failure to Follow Access Control Procedure & to Have Appropriate Vent Valve Installation Procedure

ML19350D119
Person / Time
Site:	Midland
Issue date:	03/05/1981
From:	Boyd D, Cook R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19350D116	List: IR 05000329/1981004 ML19350D115
References
50-329-81-04, 50-329-81-4, 50-330-81-04, 50-330-81-4, NUDOCS 8104130363
Download: ML19350D119 (8)

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

REGION III

Report No. 50-329/81-04: 50-330/81-04 Docket No. 50-329; 50-330 License No. CPPR-81; CPPR-82 Licensee:

Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name:

Hidland Nuclear Power Plant, Units 1 and 2 Inspection At:

Midland Site, Midland, MI Inspection Conducted:

January 1-31 and ebruary 1-14, 1981 33 !O f Inspector:

R. J. Cook

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Approved By-bC ho/d,"Ch'

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4' Reactor Proj., Section IA Inspection Summary Inspection on January 1-31 and February 1-14, 1981 (Report Nos. 50-329/81-04:

50-330/81-04)

Areas Inspected: Activity pertaining to resolution of item of noncompliance pertaining to violations of QC Hold Tags; examination of site conditions; licensee evaluations pertaining to lif ting of Stop Work activities for test-ing of HVAC duct segments; presence of fluid in 350 MCM-3C B-11 power cable and subsequent stop work; 50.55(e) item pertaining to underrated terminal strips being used in Limitorque valve operators; installation of Unit 2 core support assembly vent valves and resolution of the items of noncom-pliance pertaining to these activities. This inspection effort involved a total of 61 inspector-hours by one NRC inspector Results: Two items of noncompliance (Severity Level V, failure to follow the access control procedure and Severity Level V, failure to have an appropriate procedure for the installation of the vent valves) were iden-tified in one area of the six areas reviewed.

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e DETAILS Persons Contacted Consumers Power Company Personnel J. Cook, Vice President, Midland Project W. Bird, Manager, QA, Midland Project D. Miller, Site Manager

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Cooke, Project Superintendant

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Turnbull, Site Project QA Superintendant B. Peck, Construction Supervisor R. Volkal, QA Engineer, IE&TV D. Keating, IE&TV Section Head

• H.

Leonard, QAE Section Head L. Howell, IE&TV Supervisor R Whittaker, QAE Supervisor M Schaeffer, QAE Electrical Supervisor

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Evans, Senior Engineer E Jones, QA Electrical H. Allen, QA Mechanical Bechtel Power Corporation Personnel L. Dreisbach, Project QA Engineer

• M.

Dietrich, Project QA Engineer B & W Personnel W. Lee, Site Project Manager

• R Shope, QC Supervisor Numerous other principal staff and personnel were contacted during the reporting period.

• Denotes those present during the exit interview conducted during the reporting period.

Licensee Action on Previously Identified Items (Clor,ed) Noncompliance (50-329/79-27-01; 50-330/79-27-01).

During the reporting period, the Resident Inspector reviewed Quality Action Request (QAR) No. SD-233 dated July 6,1979, and which was subsequently closed on October 31, 1979 after taking corrective action to preclude violation of QC Hold Tags as defined in the licensee's letter to the NRC dated January 11, 1980. The Resident Inspector reviewed the attendance list for the October 24, 1979 training session (referred to in the.lanuary 11, 1980 letter) honoring QC Hold Tags and viewed the slides and presentation

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a pertaining to the significance of QC Hold Tags which is offered to all

"new hires" as part of the Safety Indoctrination.

The Resident inspector also examined a letter dated.Tuly 16, 1979 and written by the Bechtel Site Manager which strengthens the use of Hold Tag Procedure and the adverse implications of performing unauthorized work.

Field Instruction Procedure FIG 1.500, Rev. 1, Quality Control Hold Tags, was reviewed and found to include both Bechtel and Consumers Power Co.

hold tags as referenced in the licensee's response of January 11, 1980.

Based on the above reviews and efforts of the licensee, the item of noncompliance referenced in Appendix A of NRC Inspection Report No.

50-329/79-27: 50-330/79-27 is considered closed and no further action is considered at this time.

Functional or Program Areas Inspected 1.

Site Tours At periodic intervals during the report period, tours of selected site areas were performed. These tours were intended to assess the cleanliness of the site; storage conditions of equipment and piping being used in site construction; the potential for fire or other hazards which might have a deleterious effect on personnel and equipment; and to witness construction activities in progress.

2.

Consumer Power Audits of the Zack Co.

As discussed in NRC Inspection Report No. 50-329/80-37: 50-330/80-38, the licensee had issued a Midland Project QA Stop Work Order against Zack Co. duct segment leak testing activities.

During the reporting period, Specification M-151A HVAC Seismic Class I, Equipment and Duct-work Installation was revised to delete the requirements for duct segment testing and requires field testing of all standard duct runs af ter installation and testing of a selected portion of duct-work on unit coolers. The licensee's basis for the changes to the specifications are (1) the specified field testing for the installed duct-work provides assurance that the duct-work would perform the intended safety related function and (2) the shop tests originally specified were intended to detect conditions which might have a potential for failure of field testing.

Deletion of the shop test requirements may help in meeting construction schedules.

3.

Presence of Fluid in 350 MCM -3/C B-11 Power Cable On February 10, 1981, Consumers Power Co. issued a formal Stop Work Order to the Bechtel Corporation for installation of Essex 350 MCM-

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r 3C B-11 600 volt power cable. The stop work was issued because quantities of moisture were found in conductor strand interstices in

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numerous reels of the above referenced Essex cable upon terminating.

As a corrective action to the propensity of moisture in the cables, the field was instructed to purge the cables using the vendor purg-ing procedure. The vendor had been instructed to purge all this type cable prior to inspection by the Supplier Quality Representacive (SQR).

However, moisture was detected in cables which had been in-spected and/or purged. The presence of fluid in 350 MCM 600 volt power cable has been discussed in NRC Inspection Report Nos.

50-329/79-13, 79-15, 79-27, 80-08; 50-330/79-13, 79-15, 79-27, 8r-08.

4.

50.55(e) Item - Underrated Terminal Strips on Limitorque Valve Operators During the reporting period, the licensee informed the Resident Inspector and the Regional Office of a reportable item. pertaining to terminal blocks being found in Limitorque valve operators which lower voltage than the 460 volt power being appear to be rated at a supplied.

The terminal blocks used which are in question are Marathon Series 100 and Marathon Series 300 and the operators are used on nuclear service butterfly valves. Of the eighteen valve operators examined, seven had underrated terminal blocks and ten had terminal blocks of questionable rating. These ten valves used the Marathon Series 300 terminal blocks which at one ti=e were rated at 600 volts based on voltage tests. H owever, these Marathon Series 300 terminal blocks have since been derated to 300 volts.

It has not been fully deter-mined whether the Marathon Series 300 terminal blocks can be used for 460 volt applications and this is undergoing further evaluation.

The licensee is continuing to examine all of the seventy-one ques-tionable operators purchased under a common purchase order.

5.

Installation of Core Support Assembly Vent Valves During the reporting period on January 15, 1981, the Resident Inspec-tor witnessed portions of the installation of two vent valves into the core support assembly for Unit 2.

The Resident Inspector was accompanied by a member of the licensee's QA staf f.

While witnessing of these installation activities, the Resident Inspector examined the procedure, Field Construction Procedure No. 298, Installation of Vent Valves, and inquired of the QC personnel in the area the meaning of step 030 which stated:

"A.

Collapse the retaining rings of each valve toward the center of valve prior to installing. Jackscrews must be turned simultaneously to avoid " binding" retaining ring.

"B.

Install each vent valve and orientate as shown per Drawing 136254E.

"c.

Maintain the "X" and "Y" dimensions as called cut per Note No. 2 of Drawing 136254E."

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During the discussions with the QC personnel, there appeared to be some confusion as to the meaning of maintaining the "X" and "Y" dimensions and the orientation as per Drawing 136254E. The Resident Inspector asked to see the drawing and was informed that the drawing was not at the work location. The Resident Inspector inquired how the valves were uniquely numbered and was informed that a part number from one of the exposed valve assembly pieces was being used.

However, this number was not exposed on two of the valves being installed.

Therefore, it appeared that unique identification was not being used.

While in the clean room area for installation of the vent valves, the Resident Inspector noted a 3/32" diameter wire approximately one foot long and a file on the temporary flooring. The Resident Inspector inquired as to the source, control and use of these items.

It was learned that these items were being used to aid cleaning of tight crevice areas of the valve assembly. Af ter leaving the clean area, the Resident Inspector informed the licensee of the above findings.

Subsequent to the inspection of assembly of the vent valves, the Resident Inspector was informed that the wire and file had not been logged into the clean area during the work covered on the current

" Equipment Log".

However, it was claimed that the wire and file had been used during installation of the core support assembly guide blocks but had been checked out of the area at the completion of this work.

B&W Quality Control Procedure No. 9-CP-101, Access Control states that:

"4.1 All tools, equipment, materials, and supplies that are used in Zones I,11, and III shall be accounted for on the form shown in Attachment 2."

(A t tachment 2 is the Equipment Log).

Failure to comply with the provisions of the above referenced proce-dure as it applied to the wire and file found in the clean room is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion V as described in Appendix A of this report.

(50-330/81-04-01)

As a result of the violation of the Access Control Procedure, B&W issued Nonconformance Report No. 1767 on January 16, 1981. To resolve this nonconformance report, all loose parts, tools, and equipment (excluding scaf folding and welding machines) were removed from Unit 1 and 2 internals assembly clean rooms; all existing personnel and equip-ment logs for the clean rooms were upgraded and new logs in accord-ance with the procedure were instigated. QC verified compliance with the above which was completed on January 19, 1981. Also, a meeting was held with all QC, supervisory, and craf t personnel on January 20, 1981 to discuss the requirements of Access Control Procedure No. 9-CP-101.

The Resident Inspector reviewed the licensee's action pertaining to vio-lation of the Access Control Procedure and determined that no further action is required at this time. Therefore, no response to this item of noncompliance is required.

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4 It was determined that some of the confusion involved with discus-sions of the procedure was attributed to step 030, as described above, not being particularly applicable to the evolution of inserting the vent valves into the access holes of the core support assembly. Also, there did not appear to be enough guidance in the procedure being used to adequately describe the functions being performed or to reflect some of the precautions described in Manufacturer's Instruction Manual.

Failure to have an appropriate procedure describing the installation of the vent valves is considered an item of noncompliance with 10 CFR 50 Appendix B, Criterion V as described in Appendix A of this report.

(50-330/81-04-02T As a result of the above findings,-Consumers Power Co. issued a formal Stop Work Order to B&W on January 16, 1981 for further work on installing the vent valves. Also, Consumers Power Co. issued a letter to the NRC Region III offices dated fanuary 22, 1981 stating that the Stop Work action would remain in effect until the following corrective actions had been accomplished and reviewed by the NRC:

"1.

The installation procedure for this activity is being revised as appropriate to clarify the method of installation and to specify the required dimensional checks as needed. The pro-cedure as revised will either contain all the necessary infor-mation from the Naign drawing or will clearly reference which information on the design drawing is applicable to the instal-lation process.

"2.

The indoctrination and training of the personnel performing the installation of the vent valves and the QC personnel inspecting the work will be reviewed and strengthened as appropriate to insure that these personnel are suitably pro-ficient to carry out their assigned tasks.

"3.

The overview inspection plan for this activity will be re-vised to assure that problems similar to those encountered

by your inspector will be eliminated when work is resumed."

On February 9 and 10, 1981, the Resident Inspector reviewed the revised Field Construction Procedure No. 298 Rev. 3, Installation of Vent Valves, and determined that the procedure removed ambiguities and it offered additional guidance and description for the installation of the vent valves. Each pertinent step of the revised procedure re-quires identifying each valve by serialized number for which the pro-cedural step was performed. The procedure also identifies the location of the " unique" valve number.

The Resident Inspector verified from training record attendance sheets that personnel performing tne installation of the vent valves had re-ceived training and indoctrination. The Resident Inspector was also informed that comments made during the training session were incorpor-ated as improvements into the procedure. The Resident Inspector ascer-tained that the procedure had been approved by all parties involved.

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The Resident Inspector examined the revised Consumers Power Co.

Project Inspection Plan No. 03-M-41 for the overview inspection of the vent valve installation. This overview plan was approved on February 10, 1981.

Based on the above listed reviews by the Resident Inspector of the licensee's action pertaining to the violation of not having appro-priate procedures, the Resident Inspector determined that no further action is required at this time. Therefore, no response to this item of noncompliance is required. The Resident Inspector informed the licensee of this on February 10, 1981 and the Stop Work action was lifted by the licensee.

Exit Interview and Management Meetings The Resident Inspector met with management personnel from Consumers Power Co., Bechtel Power Corp. and B&W on January 15 and 16 and February 9 and 10, 1981 to discuss the installation of the Unit 2 core support assembly vent valves. On January 19 and 20, 1981, additional conversa-tions transpired via telephone between the Resident Inspector, Region III management and Consumers Power Co. management to discuss the Resident Inspector's findings relative to the vent valve installations.

The Resident Inspector met with licensee representatives (denoted under Persons Contacted) on February 12, 1981. The inspector summarized the scope and findings of the inspection effort to date.

The licensee

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acknowledged the findings reported herein.

Attachment:

Preliminary Inspection Findings

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LICENSEE 2.

RECIONAL GFFICE

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Co.. users ?ower Co::.psny U.S. Nuclear Regulatory Consissica 1%5 '.*!est dern 11 hoad Office of Inspection & Enforcerent, RIII Jackson, XI 49201 7% Roosevelt Road

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G;er. 21;yn, IL 60137

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Midland Unit 2 (Xidisad, XI)

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LOCKE7 ^CS3ERS 4.

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LA Dec. T~ 0 1,IN'9@? '7 Tan. 1-31, 19E S

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50-319 50-330

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Feb. 1-12, 1981 b*

^Ithin thd nCope of the inspectioLe no ite:S oi nonComplienCC or deviation

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The fo;;owin; matters are preliminary inspection findings:

Noncompliance item (50-329/79-27-01; 50-330/79-27-01) pertaining to violations of QC Hold Tags referenced in Appendix A of NRC Inspection Report No. 50-329/79-27 50-330/79-27 is considered closed and no further action is planned at this time.

Failure to comply with the B8N Access Control Procedure No. 9-CP-101 Step 14.1 by having a 3/32 inch oiemeter wire and a file in the Unit 2 core support assembly clean room during installation of the vent valves without these items being listed on the Equipment LoS is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion V.

Failure to have an appropriate and specific procedure to describe the installa-tion of the Unit 2 core support assembly vent valves is considered an item of noncompliance with 10 CFR,50, Appendix B, Criterion V.

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7c...,e pralininary inspection findings will be reviewed by NRC Supervision /

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..en;;atant at the Region !!I Office end they will correspond with you concerning any enforce =ent action.

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