IR 05000329/1981014
| ML20091H048 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/05/1982 |
| From: | NRC |
| To: | Saunders D AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-09, CON-BOX-9, FOIA-84-96 NUDOCS 8406050040 | |
| Download: ML20091H048 (1) | |
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UNITED STATES g
NUCLEAR REGULATORY COMMISS!ON a
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REGION 111
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7te ROOsEVsLT ROAD OLEN ELLYN,lLLINois S0137
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j Docke't No. 50-329
'A Docket No. 50-330
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Consumers Power Company
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ATTN:
Mr. James W. Cook Vice President
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Midland Project
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1945 West Parnall Road Jackson, MI 49201
Gentlemen:
Thank you for your letter dated September 9 to your attention in Inspection Reportsteps you have taken to
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, 1981 omp i
forwarded by our letter dated August 7 s No. 50-329/81-14; 50-330/81-14ance which we bro
,.1981.
We disagree with the statement in your lett item of noncompliance as stated does not exist"er that, "we believe that the on the findings stated in Paragraphs 2 a
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Our conclusion was based inspection reports as paraphrased below
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.., b.,
and c. of the above RIII I
From March 1979 to November 1980, there was n a.
engineering review of redline drawings. o procedure for g
b.
At the time of inspection, the engineering review of red line drawings were considered to b procedures for the e inadequate, c.
At the time of inspection, the site design hangers and restraints without confirmed preli iengineers were design Since our review of your response did not m nary design loads.
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is a Severity Level V violation, we do not fully responsive in that you failed to documchange our position that
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consider your letter to be be taken to avoid further noncomplianceent (1) corrective action to pliance was or will be achieved.
, and (2) the date when full com-e
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Consumers Pow
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tions,rther disagree technical deficiboth by Consumwith you DCI et, u,
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significant defici ers Pow statement design relating toer Company and Be hthat, "...
encies
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reviewsanalysis encies redlines".tel, havin-depth inv %
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issuance'of redline drawinand calculation p
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result of your in-d You show estiga-e inspectionof your findingsof our Immediate A n no ackages epth reviewreported sevevidence g
gs fo ction I.etter datedsmall bor,e pipingincluding th r
en reports listed abare documented in P of the e
system,ngineering As discussed ov.
May 22 pleas during the aragraph 1, Item,6 1981 since the s
1981 e
effor,ts to identify of Details e
in advise thismanagement meeting h the RIII other office site whet
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i cf2 request activities.her of W
or the eld at thereresults the not site of your inv this letter to ththat you provid similar problems estigationon July 24, are e
Yar coope officewritten existing is respons with us is addressing the within 25 days ration e
appreciated.
matters discussed of the d
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above. ate
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Sincerely
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A. Bert DavisOrfginal signed b y
DivisionC. E. Norelius
' Document Control </1tr dtd 8/7/81:
Technicalof Eng,ineeringDirector and
'dnt Inspector, RIIIDesk (RIDS)
Inspection id
'lic Service CommiCallen, Michigan M. Cher.7 ssion trbera Stamiri s
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Vect Pressdent = Projetss, Engreernes
and Constrettien Generet Offwen: 1945 VWest Pernen Road, Jackson. MI 49201 * ($1M 7860453
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i September 9, 1981
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Mr J G Keppler, Regional Director Office of Inspection & Enforcement
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US Nuclear Regulatory Co= mission Regica III T99 Roosevelt Road
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MIDLAND PROJECT -
INSPECTION REPORT NO 50-329 AND 50-330/81-14
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I FILE:
0.h.2 SERIAL: 1366h
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Reference: J G Keppler letter to J W Cook. dated August 7, 1981 This letter, including all attach =ents, provides Consumers Power Company's respense to the referenced letter which transmitted the subject Inspection Report and which requested our written state =ent regarding one ite: of ncncompliance described in Appendix A of the reference.
Consu=ers Power Company i
decea 4'-
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, James W Cook i
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j S-orn and subscribed to before me this. h day of September, 1931.
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Bever17/A. Avery
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l Notary Public, Jackson County, flichigan My commission expires January 16, 1985
WE3/1r CC: RJCook, US3RC Resident Inspector Midland Nuclear Plant
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CONSUMERS
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DESCRISCCOMPANf'S *!$P 1366k
DOCKY!
i Appendix A (It 50-329/61-14D :qtC C'fSE NO i
s I;iSPEC*IONTO N0f!CE
" Contrary to th
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abov,ncompliance 50-33C/81-lkRI.* PPT
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e procedurpiping supportse field e
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initiated redliprocedures 329/81-1k w
originaleceiving designes, and as r
ere used by and
' i not in 330/81-1k) state result accordancne drawings for your a
r small bore pipinesident eng
Consumers Powdesign." control rev,iewfield g
e initiated redlinwith your Field s
s to commensurate g
g andreview Change Request er Coarra y's Reste
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It is n
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and appr eed w
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nst applied not
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procedureov l of redlinesthe procedures to the a
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procedur. They ar
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are e
All revisions tes incorporatioe discuss dreview dnot in
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to the e
in e
our July 2kaccordanceement with ta engineering for n
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original o drawingsof r dlines by r,1981 the field chan review with e
the noted design.
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ap stated our eviewevising,themeeting.plicable ge response commensurateoriginalThis proredliner q\\
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e j clas ificati not exist.
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design documen
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- de'therefore believ those
'to fieldSection II of
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i e that applied an ites
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e r guest the item f 4ago 7 a changethe Inspecticaof noncompliance o
that you o
redlining Report reconsider thenoncompliance re k
addressed as follprocedures. addresses the
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, fcrsationItem 2a - Inspe i
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ows:
The three review
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procedurthe Site Smallction Repcrt Fas obsertatieco ducted'in
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drawings that e for handling th, to Noe 7 states, "From nz described onregards-Pipe group i
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ere issued per FIP Consumers Pow
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p agree er Coenany's Resn 1 112 andreview ember 1980, 79,'
March e
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with FIPand appr theresince the
}actico noted by Bechtelstatement; how 1110 requiremenov l of FE redlin a
was
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ac i
e at should further bethe time inand correctiv er, is ts."
e ev y
sting toer Campsay and a formal procedur measur should
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Re noted be es w noted that in-depth
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"j 2b redlines.chtel, hav e implemented on Nere taken to doc that 'his defi t
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e inv shown
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- Inspection Report P estigations, bothesher i, *e i
l to ument cienc/'
no evidence ov th
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review cr
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of and'approv minor design age 7 states, "Th technical defiby Consum980.
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, should not sign
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e r ers changes.edline drawings do t FCRs to
riencies e prese t EP!-k off
- f t-2 1k.1. " be redline drawings fFE roguested ch the
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Censu ers Pov This pr er Ceetany's R o
and c dur l enha esten e
the pr a
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designevision include e
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oc dur nce
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as design changes s the agr en r evis d and submieed upon in in
~ changes. and criteria to dist significa t cha e
instru tions our July 24,198 n
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c 7e accordanc inguishtted acecrdan nges initially id with ouron proper dispo betwfor your C.
e ce with REs did not rite: 2e - Ins
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eco5nispe tion Repo t Poptions describen the een r
i actic, of majorand minorThis
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c ecnfir in CPI k.L6 9r dline drawin e
e in med ed ve
"A r dlinviolatiodesign Icadine that s age 7 states i gs ee thatand minor r
agr e
n gs ome of vill a field mEPI-h.k6 9 Pars pported the c
of onstructioe is n pa t
, which include FCRsbe prcces u
by the piperedline ha,ger d"~he Sm ll engine r
awingering drn to pr ject sd e
dr a k-up wo k pri agraph r
n a
o 2 "Definitiosystem avings Pipe Group
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ther avings."
r The prand MD,k 37-6 (should engineering to r
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e nt which In is transmittedn," which statess str order to is requ es Se be do r
esulting frent pra tice d: sign lo ds r dline Region III cumented sue est a vere c
chang CPOCs pea project-ap;e in projectfrc es that, o
of Inspection Rep the RE r cstablished a
e project were n
r Bechtel e
Ce prior towithoutcha ges is que EP-k.37 rov d engineeriapprov d eviewing ha
e orts No doc n
e sumers Pev structursi asumented basisstionable.
nger 50-329/8, MD k. 37-0, ng structur l calc l1-12; 50-330/81 e
iuring the NBC r Cc ;sny'hs sembly design "a For a
since sc=e u
f Ma of attens syst e CPDCthe hangers-12).
1 i=:y 16, it winspectio e,
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Ert ediate had not
, the as n
reco of the actica le.gniz d
- cc aken andthe ter that site been e
w ther small e
c3 of syste: CPDCthe hangerssituatte as issued o pipe design
'gn.o e was n was a lack of
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n May 22,1981 Pipe had not be, the design 1c dsubs qu activities the iting s e
support load sh pro ently cor
, and rem dial acc dur l centr l to tim.tr e
ess en a s a
w analysts e ts hade tablished eek rected.
were e
s ard spans,The lo ds e
e o
without
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althcugh a pipinbeen pr par dprior to a
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do agr tic or wer cumentedeed * hat ns were e bas d either e
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- hensiv for the hangstructural asbasis
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calculated e
e g str e
drs of, the piping isintensivbut upo e
and ss CPDC :sy act sently n Specificatien 7 inadequately d er designs e
unsics its completiocretrics. progr :
hav a
e
- or:t.o 1 ;11eationsformal corrn has beThe detailsestablished ocu=ented.22C-M exis vas and f
kengineerine en f of espo denc.ully diselesthis progra:rovide C77C to p At of r dlines duri n
that e
e ti=e dicte actica letterr dline, review padditicnal rng theResident engin ed and
's e
the
,vas dis estrictionsearly stagesering reccg h
e cussed with May 22 7 rais d.
of roc pat me ting in luding th ess to e
of n cf thst prh*e believ dthe Regica,III, wensure thate pla the CFDC wer 1961 the intent ofced on the e
as e
to be actice met with yourthat our inteStaff when th set.
The policy of c
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July 27,1981r dliningspecific understa dingssatisfactice basubject w actic e
e and as the proc dur
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s d on the n
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es as doewtentedof addittenal in cur N
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The completion of
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CPDC's has providedthe calculational r
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supports.
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evidence ere also being evaluat dAs the stress CPDC's the design and the
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w of eviews
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conservatisa in the In mostwere being completedadequacy of theestab
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i a hanger
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the due to the original aboriginal designs. cases, loa small pige required that. this demonstrat i
new In no redlining procedur e
indicating the case was
es to support thees the adequacy of contr l sence of a
CPDC's. physical change to
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WRB/JVC/1r site design and the viability ofour belief
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effort.
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JAN 613'.
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Docket No. 50-329
l Docket No. 50-330
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Consumers Power Company
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i ATTN: Mr. James W. Cook
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Vice President
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Midland Project
)
1945 West Parnall Road
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l Jackson, MI 49201
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Gentlemen:
Thank you for your letter dated November 20, 1981, providing us additional t
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t details regarding the steps you have taken to correct the noncompliance
which we brought to your attention in Inspection Reports No. 50-329/81-14;
r 50-330/81-14 forwarded by our letter dated August 7, 1941. We will examine these matters during a subsequent inspection. At that time we will thoroughly examine the contents of your indepth review of design and cal-
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I-culation packages and respond to the request in Paragraph 2 of your letter requesting us to reconsider our position on the technical deficiencies identified during your indepth review.
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j Your cooperation with us is appreciated.
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sincerely, k
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'D'. Int! ED:,4 Ll/ C.E. l' ors.r. '
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j C. E. Morelius, Director j
Division of Engineering and Technical Inspection
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cc w/1tr dtd 11/20/81:
DNB/ Document Control Desk (RIDS)
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Resident Inspector, RIII Ronald Callen, Michigan
Public Service Coenission i
Myron N. Cherry i
Barbara Stamiris
'l Mary Sinclair Wendell Norshall
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RIII RI RIII R I RIII
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b lI dYin/so J s
Danielsen Williams
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ConSumBf3
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L power
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CompHRy via mou--~#au ca<~n i
and Caessmeties
General offices; 1948 West Parnest Reed, Jacksoa. MI 49201 * (517) 7 2 04&3 I
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Nevember 20, 1981
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Pr J G Keppler, Regicnal Director i
Office of Inspection & Enforcement US Nuclear Regulatory Co==ission Region III 799 Roosevelt Road Glen E11)m, IL 60137
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l MIDLA'iD PROJECT -
INSPECTION REPORT NO 50-329/81-1L AND 50-330/81-1k
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FILE:
0.k.2 SERIAL: 1k618
References:
1.
ERC letter, C E Norelius to J W Cook, dated October 28, 1981 2.
Consumers Power letter Seria11 13664, J W Cook to l
J G Keppler, dated September 9, 1981 3.
KRC letter, J G Keppler to J W Cook, dated August 7, 1981 This' letter, including all attachments, provides Consur.ers Fever Co=pany's response to Reference 1, which rejected portions of our l
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response (Reference 2) to one ites of noncompliance described in Appendix A of Reference 3.
Consu=ers Power Company By MM
" James W Cook Svern and subscribed to before me on t a 20th day of November,1991.
S m/gd. de-EMilf A. AQ Notary %blic, JacF/on County, Michigan My commission expires b 4 /f/l*
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WRB/1r CC: RJCook, USNRC Resident Inspector Midland Nuclear Plant (1)
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CONSUMERS POWER COMPANY'S RESPONSE TO
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l US NUCLEAR REGULATORY C0!NISSION, REGION III LETTER DATED OCTOBER 28, 1981 DOCKET NUMBERS 50-329 AND 50-330 i
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The second paragraph of the Region III letter of October 28,3581,
. states:
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"We disagree with the statement in your letter that, 've believe that the ites of noncompliance as stated does not exist. ' Our l
conclusion was based on the findings stated in Paragraphs 2a, 2b j
and 2c of the above RIII inspection reports as paraphrased below:
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From March 1979 to Nove=ter 1980, there was no procedure for a.
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engineering review of redline drawings.
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b.
At the time of inspection, the engineering procedces for
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the review of redline drawings were considered to be inadequate.
c.
At the time of inspection, the site design engineers vere designing hangers and restraints without confirmed preliminary design loads.
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i Since our review of your response did not change our position that
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this is a Severity Level V violation, we do not consider your letter
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to be fully responsive in that you failed to document: 1) corrective
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l action to be taken to avoid further nonco=pliance, and 2) the date when full cc=pliance was or vill be achieved."
CONSUMERS PC'4ER COMPANY'S PESPONSE Upon further review and consideration of the detailed findings set
forth in Paragraphs 2a, 2b and 2c of Inspection Reports 50-329/81-1k l
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and 50-330/81-1k, it is acknowledged that the described conditions do
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constitute an item of nonco=pliance as stated in these Inspection Reports. Accordingly, as requested, the follo'ving information concern-ing the actions taken to correct those described conditions and the item of nonce:pliance is provided:
A.
Item 2a, page 7 of Inspection Report 50-329/81-lL and 50-330/
{
81-1k states:
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"From March 1979, since the formation of the Site Small Pipe group, to November 1980, there was no established procedure for handling the review and approval of FE redline drawings that were issued per FIP 1.112 and FIP 1.110 requirements."
Corrective Action Taken Bechtel Management audit AAMA-2, conducted in August of 1980, initially identified this deficiency. As a result of that audit, EDPI k.k6.9 was initiated to decument the redline prac-tices in effect at the time. This deficiency was corrected
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with the issue and implementation of Revision 0 of EDPI k.h6.9 on November 7, 1980.
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Serial ik618
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Item 2b, page 7 of Inspection Report 50-329/81-Ik and 50-330/81-lk states:
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"The present EDPI-k.k6.9 used by RE to review and approve, redline g
drawings does not distinguish between major or minor desigh
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changes. If FE requested changes are significant, the RE should
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l not sign off the redline drawings for construction but should
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request FCRs to be approved by the corporate engineering office,
as required by EDPI-2.1k.1."
Corrective Action Taken l
As was agreed in our July 2k,1981, meeting EDPI k.L6.9 has been revised to include definitive criteria for distinguishing between
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majcr and minor design changes and to provide instructions to
l Resident Engineering for dispositioning each such category of change. These instructions do not permit Resident Engineering Small Pipe and Hanger Group approval of proposed redline changes which are categorized as major; rather, three alternate methods of proceeding, including the processing of an FCR, are provided.
Revision 2 of EDPI k.k6.9, incorporating the above described changes, was issued and implemented on August 2k,1981.
f C.
Item 2c, page 7 of Inspection Report 50-329/81-ik and 50-330/81-1L states:
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"The Small Pipe Group did not recognize that some of the redline i
hanger drawings without confirmed design loadings supported by l
l the pipe system stress CPDCs were in violation of EDPI-4.k6.9, i
Paragraph 2, ' Definition,' which states that:
'A redline is a field mark-up verk print which is trans-mitted from project construction to project engineering to request a change in project-approved engineering drawings.'
In order to issue a project-approved engineering drawing, there should be documented CPDCs per Bechtel EDP-k.37, M2) k.37-0, and MED k.37-6 (see Region III Inspection Reports No 50-329/
81-12; 50-330/81-12). The present practice of the RE reviewing hanger structural calculations resulting from redline changes is questionable. For some of the hangers, the design loads vere without documented basis since a system CPDC had not been
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established prior to structural assembly design."
Corrective Action Taken We understand the basis of the above described concern with redline drawings to be the fact that several of the small bore pipe e.nd piping suspension system designs performed at the site had not been prepared, reviewed and approved in accordance with established
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design control procedures. Specifically, it was found that some
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drawings had been issued for construction without the required Committed Preliminary Design Calculations (CPDCs). This procedural
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violation was identified during the NRC inspection of May 18-22
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1981, and was the subject of the NRC Immediate Action Letter I
dated May 22, 1981.
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Based on the Im=ediate Action Letter of May 22, 1981, reme' dial
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action was undertaken. A comprehensive and intensive program
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vas established to provide CPDCs for all the piping isometries.
The details of this program and the scheduling of its completion has been fully disclosed to the NRC, both by discussion and for a1 correspondence. Resident Engineering recognized the implications of redJines during the early stages of the CPDC review effort.
At that time, additional restrictions were placed on the resident
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engineering redline review process to ensure that the intent of
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your Immediate Action Letter of May 22, 1981, was met.
In i
addition, on July 27, 1981, a hold was placed on installation i
of small bore piping whose isometric drawing ves not supported by a CPDC. The policy of redlining was discussed with the Region
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III staff when tha subject was subsequently raised. We believed that our interim practice and the documentation of that practice met with your satisfaction based on the July 24, 1981, meeting, including the specific understandings of additional specificity
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to be added to the redlining procedures as documented in our letter to you dated July 27, 1981.
The remedial program of calculational reviews and the establish-ment of CPDCs for all piping isometries was completed on August 5.
1981. Consequently, the review of hanger structural calculations
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resulting from redline changes are based on design loads docu-
mented by the system CPDC in all cases.
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Based on the actions taken in 1A, B and C on the previous pages, we censider the plant has been in compliance on this matter since August 2k, 1931.
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2.
The seecnd paragraph of the Region III letter 'of October 28, 1981, states:
"We further disagree with your statement that:
"...indepth inves.
tigation, both by Consumers Power Company and Bechtel, have shown l
no evidence of technical deficiencies as the result of your indepth review of the design analysis and calculation packages, including the engineering reviews of redline drawings for small bore piping systems, since the issuance of our Immediate Action Letter dated May 22, 1981. Details of your findings are documented in Paragraph 1. Item 6 of the Region III inspection reports listed above."
CONSUMERS ItVER COMPANY'S PESPONSE We believe there may be a minor misunderstanding on this matter. As indicated, seven significant discrepar.cies were identified as the J
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result of our indepth review of the design analysis and calculatien packages and were reported to you in accordance with the Immediate i
Action Letter dated May 22, 1981. However, it is important to note that none of these discrepancies were related to the redlining of drawingst all were related to other issues. This fact was brought to
.'your attention during our July 2k,1981, meeting. Accordinglyive
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- consider our statement to be a true and accurate representation of the situation and request you to reconsider your position on this
matter.
The fourth paragraph of the Region III letter of October 28, 1981,
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states:
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"As discussed during the management meeting held at the site on July 2h, l
1981, please advise this office of the results of your investigation efforts to identify whether or not there are similar problems existing i
in other site activities."
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l CONSUMERS PO'a'D COMPANY'S RESPONSE l
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Three audits were conducted at the site between June and November 1981 I
of all Site design activities. Two other areas on site were identified as having similar problems. The first was the Instrument Tubing Support Group, which was identified by Consumers Power as not having adequate procedures to govern the Field Engineering preparation and l
Resident Engineering's review of calculations and drawings. Work was stopped in this area until approved procedures to prepare and review calculations and drawings for instrument tubing and supports were generated. It should be noted that the audit was timed to review these activities just as they were being initiated. The second area was the site Resident Engineering Civil Group. It was identified by Bechtel Quality Engineering that calculations had been performed as
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j back-up informat.on, but they had not been formally approved All of
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the calculations involved were subsequently reviewed and necessary
approvals were given. It should be noted that, no procedural changes were initiated as a result of this deficiency since the audit finding was for a procedural violation. Our investigation revealed no other similar problems.
Design activities being conducted in the other Resident Engineering groups were found to be done in accordence with the EDPs, and the procedures were also found to te adequate.
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