IR 05000329/1981012
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b.b Docket No. 50-329 Docket No. 50-330 Consumers Power Company ATTN: Mr. James W. Cook Vice' President Midland Project 1945 West Parnall Road Jackson, MI 49201 Gentlemen:
Thank you for your letter dated January 14, 1982, informing us of the steps you have taken to correct violations 4 and 5 and the dates of corrective action for several other items identified in our Inspection Reports No. 50-329/81-12 and 50-330/81-12, forwarded by our letter dated July 10, 1981. We have no further questions regarding the res'ponses pro-vided in this most recent letter and your earlier letters dated August 7, 1981 and October 30, 1981.
Your cooperation with us is appreciated.
Sincerely,
"Ot.
n:I LIG:d Ly C,E,1,.;,;;e-n
l C. E. Norelius, Director Division of Engineering and l
Technical Inspection cc w/Itr dtd 1/14/82:
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris Mary Sinclair Vendell Marshall RIII RIII RII
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CONSUMERS POWER COMPANY'S RESPONSE TO
US' NUCLEAR REGULATORY COMMISSION, REGION III
- LETTER DATED DECEMBER 3,1981
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DOCKET NUMBERS 50-329 AND 50-330
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Paragraph 1 of the Region III letter of December 3,1981, requests clarification of two issues.
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Paragraph la of this letter states:
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' Field alteration of piping support and restraint installations subsequent to QC inspection and. sign off has not been clearly addressed.
Identification and correction of problems during final system walk-down prior to preoperational and/or startup tests should be the exception, not the rule.
Your QA pro-gram should include measures to protect systems from
. damage and alterations after final acceptance by quality control.
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CONSUMERS POWER COMPANY'S RESPONSE We regret that there was an editorial error.which made it appear that we
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were not being fully responsive to your concern regarding field. alteration of piping support and restraint installations subsequent to QC inspection and sign off.
In the third paragraph on page two of the attachment to the October 30, 1981 letter, as a part of our response to violation Item 4, we referenced " Item 6 in your Notice of Violation".
We should have refer-enced Item 3.
We apologize for the confusion this editorial error must have caused you.
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Our response to Item 3, transmitted on August 7, 1981, stated:
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f Bechtel Construction has developed Administrative Guidelines
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addressing rework.
The Administrative Guidelines provide refer-ence to particular field procedures and outline the means of administrative 1y processing rework information such that proper notifications and coordination are attained.
Bechtel Quality Control has also developed Administrative Instructions to indi-cate 'the process followed for processing rework items.
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It is noted that the above-referenced Administrative Guidelines
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and Instructions have been developed for Civil, Instrumentation,
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Mechanical and Electrical disciplines, and these actions in the
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Mechanical area,are considered; responsive to Unresolved Item -
329/81-12-15 and 330/81-12-16 concerning procedural provisions to control design revisions on small bore piping and piping suspen-sion systema.
In the Mechanical area, the guidelines have been issued and revisions to the appropriate Mechanical procedures have been made and are expected to be issued for use by August 12, 1981.
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The definition of rework as used in these guidelines and procedures includes both the re= oval of an accepted installation for the purpose
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of ceco =plishing a design change on it, and te=porary re= oval of an cecepted installation si= ply to acco=odate cons truction congestion.
Those guidelines and procedures have. now been released and are being i=ple=ented.
This action should preclude unauthorized rework subse-qu:nc to QC inspection and sign off.
b.
Paragraph Ib of the Region III letter states:
Your response states, " Project Engineering has been requested to evaluate the conditions represented by Ice =s e, g and h."
k' hat consideration has been given to the possibility that field installation was carried out without a clear understanding of the design require-
=ents and related interpretations?
CONS'M.RS Pok'ER CCMPATI' S RESPONSE With respect to Item e, 3echtel Project Engineering was asked to consider whether or not.the pipe hanger and restraint installation tolerances given in Specification 7220-M-326(Q) are in confor=ance with the design require =ents.
In response to this question, 3echtel Project Engineering stated that there is only a =ini=um installation clocrance require =ent and that there is no.=axi=u= installation ciecrance require =ent, unless specified on the drawing.' Thei U s a febrication interfacing di=ensional constraint, which when =et, re-sults in an acceptable =axi=u= installation clearance.
This di=en-sional constraint is verified at the time of fabrication.
Vhen the =inimum installation clearance a.nd the fabrication di=ensienal rsquire=ents are =et, design stresses vill not be exceeded.
30 sod on this Project Engineertng response, we conclude that the eclerances are in confor=ance with. the design require =ents.
Further-ore, we have verified that the 3echtel QC inspections and the MPQAD overinspections are being perfor=ed with the full understanding of cho tolerances as set forth above.
Finally, since it appears the circu= stances concerning this ite= should have raised sc=e question as to the proper interpretation of the pertinent design require =ents, it hcs been ree=phasi:ed to all QA/QC personnel that, any ti=e such a qu stion or doubt arises, they are to pro =pely seek vritten direction from Project Engineering.
With respect to !te=s g and h, 3echtel Project Engineering was asked to ecnsider whether or not the Technical Specification is an adequate and co:plete state =ent of the design require =ents.
In response to this
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qu2stion, Bechtel Project Engineering stated that the strength of grouted
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anchor bolts is controlled by the bond strength betseen the grout and the cencrece interface.
The strength'of the concrete cone pull-out, calcu-laced per ACE 349-81, Appendix 3, is approximately three ti=es the design strength of the grout-to concrete interface.
Therefore, small holes drilled within this concrete. cone vill not.have a detri= ental effect until tha potential pull-out surface of that concrete cone is reduced by approxi-cately two thirds.
Based on this Project Engineering response, we conclude
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'that the design require =ents as current 41 statad in the Technical Specifica-
tica are adequate.
The occurence of abandoned holes in the proxi=ity
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of a single grouted-in anchor bolt in such numbers that they would
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reduce the pull-out area of the concrete cone around the bolt by two-thirds seems highly im' probable. Never-the-less, to preclude even the remotest possibility of such an occurence, Project Engineer-ing will revise the Technical Specification to incorporate their response to our question.
2.
Paragraph 2 of the Region III letter states:
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Our letter dated September 16, 1981, requested that you provide a date when full compliance was or will be achieved for each of the eight items of noncompliance. khile your -
additional response for Items 4, 5 and 8 satisfied our re-quest, you failed to provide a date for the other items.
CONSUMERS P0b'ER COMPANY'S RESPONSE 1he dates for which we were in full compliance are as follows:
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Item 1 - December 31, 1981 b.
Item 2 - December 31, 1981 c.
Item 3 - November 24, 1981 d.
Item 6 - August 5, 1981 e.
Item 7 - May.29, 1981
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o UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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799 ROOSEVELT ROAD
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h Docket No. 50-329 Docket No. 50-330
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Consumers Power Company ATTN: Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 Gentlemen:
Thank you for your letter dated October 30, 1981, responding to our letter dated September 16, 1981, which addressed the need for you to provide additional information so we could complete our evaluation of the steps you have taken to correct the items of noncompliance which
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we brought to your attention in Inspection Report No. 50-329/81-12; 50-330/81-12 forwarded by our letter dated July 10, 1981.
We have reviewed your response and have the following comments:
1.
Response to Items 4 and 5
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Your response is generally acceptable; however, two issues warrant further clarification:
a.
Field alteration of piping support and restraint installations subsequent to QC inspection and signoff has not been clearly addressed.
Identification and correction of problems during '
final system walkdown p-ior to preoperational and/or startup tests should be the exception, not the rule. Your QA program should include measures to protect systems from damage and alterations after final acceptance by quality control.
b.
Your response states, " Project Engineering has been requested to evaluate the conditions represented by items e.,
g., and h."
What consideration has been given to the possibility that field installation was carried out without a clear understanding of the design requirements and related interpretations?
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CONStHERS FO'a*ER CCMPARY'S RESPONSE TO NOTICE OF VIOLATIONS DESCRIBED IN NRC INSPECTION REPCRT DOCKET NO 50-329/81-12 AND 50-330/81-12
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Item k from Appendix A (Item of Noncompliance 50-329/81-12 and 330/81-12-12 provides the folleving:
"10CFR50, Appendix B.- Criterien V states, in part, ' Activities affecting quality shall be prescribed by docu=ented instructions, precedures, or drawings..
cedures, or drawings.'and shall be accomplished in with these instructions, pro-
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The Consumers Power Cc=pany Quality Assurance Progra:
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Policy No. 5, Re-vision 9 states. in part, ' Instructions for controlling and perferning activities affecting quality of equipment or operations during the design, construction... phases of nuclear power plants, such as.... construe-tion, installation... are documented in instructicns.
. and other forms of dccu=ents, and the responsible CP departments shall 'also verify
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through audits that the required instructions.
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Centrary to the above, seven large bore pipe restraints, supports, and anchers were not installed in accordance with design drawing and 'specifi-catien requirements.
(229/81-12-11; 330/81-12-12)
This is a Severity level V violation (Supple =ent II)."
CCNS*JMIP.S pC'aTR COMPANY'S FESPONSE I
Violation Iten k The pipe supports identified in the NRC report of the May 18-22, 1981
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inspection which vere used as supporting details for Item k in the Notice of Violation vere all turned over to QC for inspection in 1980 (inspec-tions completed between 5/80 and 12/80).
An evaluation was conducted by MPQAD of the quality indicators related to hangers for the time period of June 1980 to May 1981.
half of the indicators vere issued between 9/17/80 and 11/19/80This study found that Ufhis study cencluded that construction did not assure that hang which coin-related items were cceplete and in accordance with the =est recent drawing and
,revisicapriortoturnovertoQC}.}
As a result of actions taken primarily in the Quality Centrol area, the number of quality indicators dropped from a peak of 13L in August /Septe=ber 1980 to an average of 19.25 per month frem March 1981 thru June 1981, and that general level has been maintained.
Overinspections conducted by MPQAD have
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- providing increased assurance that pipe hangers which have been QC inspected and accepted do meet drawing and specification require =ents.
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s Actions taken as a preventive measure include the folleving.
In June 1961, field engineers vere issued a hanger checklist which was prepared for their use to assist in the checking of hangers prior to turnover to QC. This checklist includes a review to confir= use of the most recent drsving re-
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vision, and by checking all items noted on the checklist, the field engineer can help assure that the hangers are cc plete and in accordance with the drawing and specification require =ents prior to turnover to QC for their inspection.
In addition, the reading list for Mechanical Field Engineers has been expanded to enhance their skills.
Based on this evaluation and the resulting recc :endations and action taken by Bechtel Field Engineering, and the infor=ation in our response to Ite
of the Notice of Violation, we are scheduling an overinspection by IGQAD of
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a sa:ple of those pipe hangers and supports installed prict to January 1981
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to assess the acceptability of the installations and adequacy of the original inspection performed by Bechtel QC. This overinspection progra vill be
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E cc pleted by December 31, 1981. Subsequent evaluation of the overinspection results vill be used to deter =ine if there is any need for additional corrective action.
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In addition to the abcVe, in respcase to your cen:ern abcut reverk subsequent to QC inspectien (Ite: f), this concern is similar to Ite: 6 in your Notice cf Violatica resulting frc: the May 18-22, 1981 inspectien. We request that you review our respense to Ite: 6, as our response to the cencern ststed in ycur letter dated September 16, 1951.
In that letter, you stated that ycu vill examine this =atter during a subsequent inspection, therefore apparently accepting the acticns we have taken. Therefere, ve feel that no additienal action is necessary on this ite:. An audit is plannei to be conducted in November 1981 to address the effectiveness of the rev rk centrols which includes the additional procedures generated since the May inspectien.
All of the specific hanger deficiencies are being addr ssed.
It e: a through 4 and f have been resolved. Project Engineering has bet. requested to evaluate
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_the ecnditi_cns._ represented by ite=s e, g andj._ Dispc.ticn and. CorreitM e ~
actica results frc= the disposition is anticipated to.: Ocepleted by January 5, 1961. Pending the result of the overinspe: sn to be a::ceplished by MP.AD of the ha.gers installed prior to January 1951. the plant vill be in ec pliance in regards to this matter at that time.
Ite 5 frc: Appendix A (Ite: of Noneo:pliance 329/61-12-12 and 330/61-12-13)
provides the folicving:
"10CFR$0, Appendix B, Criterion X states in part:
'A progra: for inspecticn of activities affecting quality shall be established and executed by or for the organizatien perfor=ing the activity to verify conformance with the docu-mented instructions, procedures, and drawings for accceplishing the activity. '
The Consumers Fever Cc pany Quality Assurance Prcgra: Felicy No 10. Revisien 8 states, in part, 'Inspecticns and surveillance are perforced to assure that activities affecting quality ec ply vith... design documents.'
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Contrary to the above, l'1censee' construction quality control inspectors
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inspected and accepted six of,seven largobore pipe re straints, supports, and anchors that, in fact, had' act been inst'alled in accordance with design drawings and spacifiesticrs' as determined by the :GC inspector.
(329/81-12-12; s
330/81-12-13).
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s This is a Severity Level V Wolation (Supplement ITs. "
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CONSC'ERS POVEF COMPANY'S RESPONS?
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Violatien Ite: 5
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The pipe supports identified by the NRC in thef report of their site inspecticn of May.16-22,1981, which vere used es supporting details for Ite: 5 in the all inspected in the 'tice period of May 1980 to l
Notice of Violationg.e:
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S December 1960.
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fl An evaluation conducted by MPQAD of quality indicatera related to hangers ter i
the ti=e period June 1980 to May 1981 found that \\)alf of the indicatcrs were issued between 9/17/80 and 11/19/80, which coincidas with the 40 inspection dates,for the hangers identified by !.'.r Yin.
he evaluation also fcund that during that time perier., the n=ber of crafts personnel significantly increased. Cogaet,ien had not assured that hanger:
vere ec=plete and met the requirements of the cost recent draving revisien prior to turnover to (C. The result was that QC received a large number of hangers to inspect and these hangers had a ralatively large number of (deficiencies."
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In October and Nove=ter of 1980, planned per:cnnel changes included a new Lead Mechanical QCE, and pipe suppert group supervisor. These changes brought additional experience to t'.e QC crganization. Additionally, increased effort was directed to the inspection of pipe supports.
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h$scNent ho, these actions, the number af quality indicators dropped frc: a peak of 13L in August / September 1980 to e average of 19.25 per centh frc=
March -1981 through June 1981, and that general hvel has been maintained.
Overin'spections c%iueted by MMAD hav4. enfirmed that the Se:htel QC inspection of hanger)'has i= proved and is provdJing increased assurance that pipe hangers whith havAbeen QC inspected tnd accepted do =eet drawing and specification rigthre ents.
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A quea*.icn regarding the intent of Specification M-326 vith regards tc the locaticn for the measure =ent for clearance det'er=inatien (is a clearance s that varies from 1/16" to 3/8" acceptable if the desving requires a 1/16" clearance) has been referred to Bechtel Project Engijeering.
' hil of the specific hanger deficiencies are being addressed. Ite: a thrcugh d
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any f, gave been resolved, Project PIEineering has been requested to evaluate
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thei ca.cditions represented by items a, g and h.
Disposition and corrective a:tidresults fro: the dispcsition le anticipated to be ec:pleted by Jutuary 5,4981. An41n's the result or the overinspection to be aceemplished by MPQAD of the,hef ters installed ;rior'to January 1981, the plant will be in
'coc:pliance in rdErros to this matter t.t that time.
It is felt that our present
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inspection progrsm is bin cottp'iance'vith npplicable requirements in regards to hanger inspections. p,,
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Docket No. 50-329 j
Docket No. 50-330 Consumers Power Company ATTN:
Mr. James W. Cook b
Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 Gentlemen:
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Thank you for your letter dated August 7, 1981, informing us of the steps you have taken to correct the items of noncompliance which we brought to your attention in Inspection Report No. 50-329/81-12; 50-330/81-12 for-warded by our letter dated July 10, 1981.
Your letter has been reviewed, and particular attention was given to the information presented. We do not consider the actions delineated in your letter to be fully responsive as described below.
1.
Response to Items 1, 2, and 3 We will examine these matters during a subsequent inspection.
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Response to Items 4 and 5 l
iesetwononcomplianceitemsinvolveinstallerswhofailedtofollow work procedures and design instructions and also QC inspectors who l
failed to provide adequate installation verification. We contend that
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installation and inspection are two distinctly different functional
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areas.
In addition, in our review of this matter we cannot support your statement that approximately half of the specific findings could be substantiated after further analysis.
Ites e (Rigid Trame Restraint 18-1HCB-2-H13). We do not concur
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with your statement that this item is not in fact nonconforming to its design requirements nor was there an inspection error.
Our basis ist (1) the procedure did not call for the use of a level and angle finder for this specific application, (2) due
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to the small surfaces involved, use of the angle finder may not
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be considered applicable, (3) calculations proved that the
- e, reading from the angle finder was not conservative, and (4) as
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Consumers Power Company I
i it stands, portions mf the gap clearance are in noncompliance Furthermore, your response did not with the restraint design.
address our inspector's question as to whether or not the 2 criteria is permissible since the design drawings called for a full load bearing surface between the pipe lugs and box f rame
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restraint shims.
Your statement, Item f (Sliding Stanchion Assembly 2HBC-124-H7).
"It is believed that the hanger movement occurred after the QC
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inspection that accepted the installation'.
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you are not aware that alteration of installation, subsequent to
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QC inspection without proper control could indicate a breakdown in your site QC inspection program.
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Item g (Rigid Frame Assembly 12-2HBC-124-HSR) and Item h (Anchor
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During our inspection discussions with your
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2 1/2" ICCB-2-H7).
staff, we did not understand that thefanchor bolts installed were
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grouted-in type; however, we feel the issues identified are still This is based on the engineering consideration that the load capacity for both types'of anchor bolts is principally valid.
dependent on the condition of the affected shear cone' are not only weaken the concrete, but they will also initiate crackingIf concrete.
along the disturbed regicns.
type anchor bolts installed in this manner is available, we will
review it during a subsequent inspection.
We could not concur with-m Item i (Sway FSK-M-2HBC-137-3-H3(Q)).
your statement that since this item had not as yet been released for QC inspection, it is considered "under construction" and as
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As we stated in our inspection such, no inconsistency is noted.
L report, we recognized that the hanger installation had not been We consider the problem warrants attention, even QC inspected.
if your QC inspection could identify and correct the problem at We believe that the installer should implement a later date.
design requirements independently of QC inspection.
x In addition to the comments presented above your response did not address (1) the program inspection performed to insure that similar.
deficiencies do not exist in other systems, (2) when the specific
~ roblems and extended inspection program will be initiated and completed, and (3) the corrective action taken to prevent future p
recurrence.
3.
Response to Item 6 Vetperformed a followup inspection in this area prior to receipt ofW your response to this item.
during future inspections.
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Attechment to
Serial 13525
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Additionally, the field procedures were revised to more clearly address rework in some areas. Specifically, within the electrical area, Field Procedures FPE-3.000, " Installation of Electrical Tray and Conduit;" FIE-3.100, " Class IE Tray Support Installation;" and FIE-3.300, " Class IE Conduit Support," have been revised to address the rework of electrical raceway. These documents are in the approval cycle and are expected to be issued by August 12, 1981.
In addition to these procedure revisions, an Administrative Guide E-1.00,
" Processing Rework of Scheduled Raceway," was issued for use by Bechtel Construction.
Bechtel Quality Control has developed and issued QC Administrative Instruction No 617, " Instructions for Processing Rework Electrical Items." This instruction details how rework is processed by Quality Control.
The lack of prompt corrective action described in the Item of Noncompliance relative to the Bechtel and Consumers Power Company audit findings was due to considerable discussion between parties on.the need, extent and detail necessary to adequately cover the rework activity procedurally. There was a lack of any identified nonconformances relative to items being reworked and as such, there were not and are not now, indications that the rework processes were out of control.
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It is noted that the above-referenced administrative guidelines and instructions have been developed for Civil, Instrumentation, Mechanical and Electrical disciplines, and these actions in the Mechanical area are I
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i considered responsive to Unresolved Item 329/81-12-15 and 330/81-12-16
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concerning procedural provisions to control design revisions on small bore
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P P ng and piping suspension systems. In the Mechanical area, the guidelines l
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have been issued and revisions to the appropriate Mechanical precedures have
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been made and are expected to be issued for use by August _12m 19_8h _ _ _ _
Full compliance will be achieved upon issuance of the procedures.
Item 4 from Appendix A (Item of Noncompliance 50-329/81-12-11 and 330/81-12-12) provides the following:
"10CFR50, Appendix B, Criterion V states, in part, ' Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings.
. and shall be accomplished in with these instructions,
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procedures, or drawings. '
The Consumers Power Compaay Quality Assurance Program Policy No. 5, Revision 9 states, in part, ' Instructions for controlling and performing activities affecting quality of equipment or operations during the design, construction.
. phases of nuclear power plants, such as
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construction, install tion.
. are documented in instructions.
. and
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other forms of documents,' and the responsible CP departments shall 'also verify through audits that the required instructions
. are
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implemented.' Contrary to the above, seven large bore pipe restraints, miO881-0001a-12
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Attachment to Serial 13525 Page 6
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supports, and anchors were not installed in accordance with design drawing and specification requirements.
(329/81-12-11; 330/81-12-12)
This is a Severity Level V violation (Supplement II)."
Item 5 from Appendix A (Item of Noncompliance 329/81-12-12 and 330/81-12-13)
provides the following:
"10CFR50, Appendix B, Criterion X states, in part:
'A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for i
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accomplishing the activity.'
The Consumers Power Company Quality Assurance Program Policy No. 10, Rm ision 8 states, in part:
' Inspections and surveillance are performed to assure that activities affecting quality comply with.
. design docu-ments.'
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Contrary to the above, licensee construction quality control inspectors inspected and accepted six of seven large bore pipe restraints, supports, and anchors that, in fact, had not been installed in accordance with design drawings and specifications as determined by the NRC inspector.
(329/81-12-12; 330/81-12-13)
This is a Severity Level V violation (Supplement II)."
Response to Item 4 and 5 These two items of noncompliance are appropriately addressed together.
The item identification used in this response is identical to the identification of the seven specific examples of noncompliance found in Section V 2 of the body of the inspection report. Further analysis of the seven items substantiated approximately only half of the findings.
Specifically the following was determined.
1.
Items e and d were found upon reinspection to be in nonconformance with their requirements and erroneously accepted by Bechtel Quality Control.
Nonconformance reports have been issued for these discrepancies.
Compliance will be achieved upon closure of the nonconformance reports.
2.
Item e (rigid frame restraint 18-1HCB-2-H13) is not in fact nonconforming to its design requirements nor was there an inspection error.
QC reinspection of this restraint utilizing standard inspection methods (level and angle finder) indicated that this item is within tolerance.
The NRC calculations had indicated a 2.23* out of parallel condition between the upper shim plate and stanchion plate versus 2* allowable.
miO881-0001a-12
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Attachment to
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Serial 13525 Page 7 L-.
F 3.
Itee f (sliding stanchion assembly 2HBC-124-H7) at the time of the NRC inspection was nonconforming.
paint line between the base plate.and the wall was broken.Further QC inspection revea thisi it is believed that the hanger movement occurred after the QC Because of l
inspection that accepted the installation.
An SCN (No. 26) to M-326 dated June 16, 1981 has been issued rendering the previously inconsistent condition acceptable.
No further action on this item is required.
4.
Ites 3 (Risid Frame Assembly 12-2HBC-124-H5R) is in compliance.
Consumers notes that the NRC Inspector referenced the wrong specification.
Specification 7220 C-305(Q) relates to drilled-in anchor bolts.
applicable specification for this condition is Specification 7220-C-306(Q)
The for grouted-in anchor bolts. This Specification (C-306) references no requirements for proximity of abandoned holes (due to the different anchoring mechanism none is required). 'Therefore, no inconsistency I-existed nor was there an inspection error.
No further action is required.
5.
Item h (Anchor 21/2" - ICCB-2-H7) in a similar manner to (g) above is in compliance.
proximity of abandoned bolts._The applicable Spec. (M-306) contains no requirements fo (Note:
the 1/4" diameter bolts were, in fact, abandoned).further QC inspection revealed that inconsistency existed nor was there an inspection error.Therefore, no ac' tion is required.
No further 6.
Item i (Sway, Strut FSK-M-2HBC-137-3-H3(Q)) had not, as yet, been released for QC inspection, it is considered "under construction" and as such, no inconsistency is noted.
than' assuring at the time of inspection the item is in conformanceNo further ac
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Item 6 of Appendix A (Item of Noncompliance No.
14) provides the following:
50-329/81-12-13 and 330/81-12-
"10CFR50, Appendix B, Criterion III states, in part:
'The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews.
shall be applied to items such as.
.. Design control measures
. stress analysis...'
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j The Consumers Power Company Quality Assurance Program Policy No. 3, Revision 9 states, in part, 'The design organization identifies the applicable regulatory requirements, design bases, codes and standards; develop the design and specify the design interfaces; perform design verification and prepare design documents.'
Contrary to the above, several of the small bore pipe and piping suspension system designs performed at the site had not been prepared, reviewed and approved in accordance with established design control procedures.
(329/81-12-13; 330/81-12-14)
This is a Severity Level IV violation (Supplement II)."
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Functional or Program Areas Inspected f
1.
Observation of Underpinning Instrumentation Installation Activit_ies r
a.
The faspector observed the partial installation of several undarpinning instrumentation thermocouple cables. The inspector observed that the raceway internals were free of hazardous debris and sharp edges. The cables and raceway were undamaged and cable pull tensions were properly monitored.
b.
On July 1, 1982, the inspector observed the supports and the anchor bolt installations pertaining to cxtensometers 3 and 5.
The inspector observed that unapproved installa-tion / coordination forms were being used by construction personnel to document these installations.
The use of installation / coordination forms was discussed with the licensee during the May 28 and June 17 exit meetings.
This subject was also discussed during a conference call between the inspector and licensee representatives on June 18, 1982. During these discussions the licensee committed to the use of approved installation / coordination forms during the installation of affected underpinning instrumentation. Therefore, it has been determined that the licensee is in deviation from an NRC commitment as described in Appendix B of the report transmittal letter (50-329/82-11-01; 50-330/82-11-01).
During the observation of extensometer EX5, one anchor was found to not have the required embedmont depth as specified in Specification C305. Construction and engineering had signed-off on the coordination form for that instrument indicating completion of this activity. This failure to properly install the anchor bolt is in noncompliance to 10 CFR Part 50, Appendix B, Criterion V, as described in Appendix A of the report transmittal letter (50-329/82-11-02; 50-330/82-11-02). Subsequently, the licensee initiated an NCR on this item.
2.
Other Areas Inspected - Units 1 and 2 During a tour of the Auxiliary Building and the Cable Storage Yard the inspector observed the following:
The inspector observed a 20 inch vertical separation between a.
redundant Class IE cables located in the Unit 1 cable chase at slovation 659. The 20 inch vertical separation was measured at the point at which Class IE cables exit racew f sleeves 1DH058 (separation Group D) and IBFF001 (separation Group B).
The required vertical separation is 36 inches.
If this separation cannot be attained then barriers must be installed. This matter is unresolved pending review
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of previous licensee inspections of this area and the identified barrier requirements for raceways 1DH058 and IBFF001.
(50-329/82-11-03)
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b.
The inspector observed the condition of Class 1E cables stored in the Cable Storage Yard. TWo instances were observed in which the ends of Class 1E cables were not properly capped. The licensee stated that immediate corrective action would be taken.
3.
Freeze-wall Monitoring Pits The inspector reviewed the procedures and drawings for the four monitoring pits and determined that they were acceptable.
The inspector also inspected the four pits for conformance with the design drawings and also determined they were acceptable.
The inspector gave the licensee verbal concurrence that they could activate the freeze-wall on May 21, 1982. The only open hold point is that they cannot dig below the deep duct bank until they get NRR concurrence on the proposed method.
4.
Pond Fill Line Repair The inspector gave the licensee verbal concurrence that they could repair the 72 inch pond fill line if the following twa conditions were met:
a.
An approved site excavation permit for that activity.
b.
Fines monitoring on the dewatering wells to be the same as previously approved by NRR for plant area dewatering wells.
5.
Slope Layback at Auxiliary Building Access Shafts The inspector gave the licensee verbal concurrence that the slope layback scheme proposed for the auxiliary building access shafts was acceptable. This scheme was shown on Drawings C1420 and C1421, Revision 3.
FIVP Temporary Supports The inspector while reviewing drawing C-2020, which defines the FIVP support system, requested evidence that the as-built configuration of the supports is as shown on the drawing. The licensee could not produce any documented evidence that the support structures were built as illustrated on the drawing since it was installed non "Q" several years ago.
The licensee (
agreed to do an inspection of the supports to determine their g
adequacy. Subsequently, the licensee determined that Unit 1 g
support steel has nine deficiencies from the drawing; while
's Unit 2 has ten deficiencies from the drawing. That is, tne specific details of the installation drawing have not been
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July 19, 1982
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Docket Hos.: 50-329/330 OM, OL
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APPLICANT: Consumers Power Company FACILITY:
Midland Plant, Units 1 and 2 SUBJECT:
SUM 1ARY OF JutlE 25, 1982 MEETING ON SOILS RELATED l
REQUESTS FOR INFORMATION l
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On June 25, 1982, a neeting was held in Bethesda, Maryland between Consumers l
Power. Cocoany (the applicant), the NRC, Bechtel and various consultants to
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discuss the applicant's responses to enclosure 8 of the NRC letter of May 25, 1982 which requests additional infomation on soils related remedial activities for the liidland Plant. At the outset'of the meeting the staff
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oresented memoranda containing specific structural and geotechnical cuestions which are attached as enclosures 1 and 2.
During the meeting the response to the cuestions in enclosures 1 and 2 were prepared by the applicant and are attached as enclosure 3.
Enclosure 3 also includes the applicant's responses to verbal cuestions on piping raised during the meeting (see Section III); a sumary of an NRC caucus (see Section IV); and a review of the FIVP design ( see Section V).
fleeting attendees are listed by enclosure 4.
arl Hood, Project flanager Licensing Branch #4
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Division of Licensing Enclosures:
As stated cc:
See next page M=
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JUL 2 3 1982
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.ae re=u m. c.co.acu cae OFFICIAL RECORD COPY m: m-2.
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MIDLAND Mr. J. W. Cook Vice President
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Consumers Power Cogany 1945 West Parnall Road Jackson, Michigan 49201 I
{
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cc: Michael I. Miller, Esq.
Mr. Don van Farrowe, Chief f
Ronald G. Zamarin, Esq.
Division of Radiological Health
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Alan S. Farnell, Esq.
Department of Public Health
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Isham, Lincoln & Beale P.O. Box 33035 Suite 4200
' Lansing, Michigan 48909
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1 First National Plaza f
Chicago, Illinois 60603 William J. Scanlon, Esq.
l 2034 Pauline Boulevard
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James E. Brunner, Esq.
Ann Arbor, Michigan 48103 I
Consumers Power Cogany 212 West Michigan Avenue U.S. Nuclear Regulatory Comission j
Jackson, Michigan 49201 Resident Inspectors Office
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Route'7 I
I Ms. Mary Sinclair Midland, Michigan 48640 5711 Summerset Drive Midland, Michigan 48640 Ms. Barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Division Consumers Power Company 720 Law Building 212 W. Michigan Avenue Lansing, Michigan 48913 Jackson, Michigan 49201 i
Mr. Wendell Marshall Mr. Walt Apley Route 10 c/o Mr. Max Clausen Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL)
Battelle Blvd.
Mr. Roger W. Huston SIGMA IV Building Suite 220 Richland, Washington 99352 7910 Woodmont Avenue l
Bethesda, Maryland 20814 Mr. I. Charak, Manager l
NRC Assistance Project Mr. R. B. Borsum Argonne National Laboratory Nuclear Power Generation Division 9700 South Cass Avenue Babcock & Wilcox Argonne,11.linoi s 60439 7910 Woodmont 1. venue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Comission, Cherry & Flynn Region III Suite 3700 799 Roosevelt Road Three First National Plaza Glen Ellyn, Illinois 60137
,
Chicago, Illinois 60602 dr. Steve Gadler l
2120 Carter Avenue l
St. Paul, Minnesota 55108
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Mr. J. W. Cook-2-I
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cc: Commander, Naval Surface Weapons Center ATTN:
P. C. Huang White Oak Silver Spring, Maryland 20910 Mr. L. J. Auge, Manager Facility Design Engineering Energy Technology Engineering Center P.O. Box 1449 Canoga Park, California 91304 Mr. Neil Gehring U.S. Corps of Engineers NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commissica Washington, D. C.
20555 Mr. Ralph S. Decker Atomic Safety & Licensing Board U.S.. Nuclear Regulatory Commission Washington, D. C.
20555
Dr. Frederick P. Cowan Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 Jerry Harbour, Esq.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Geotechnical Engineers, Inc.
ATTN: Dr. Steve J. Poulos 1017 Main Street f
Winchester, Massachusetts 01890
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