IR 05000329/1982003

IE Insp Repts 50-329/82-03 & 50-330/82-03 on 820412-14, 21-23 & 29.Noncompliance Noted:Failure to Follow Procedures Re Attachment Changes to Drawings & Verification of Design Changes & Inadequate Controls During Excavation

ML20055B039
Person / Time
Site:	Midland
Issue date:	07/01/1982
From:	Gardner R, Landsman R, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20055B035	List: IR 05000329/1982003 ML20055B034 ML20055B036
References
50-329-82-03, 50-329-82-3, 50-330-82-03, 50-330-82-3, NUDOCS 8207200289
Download: ML20055B039 (7)

Text

{{#Wiki_filter:. U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-329/82-03(DETP); 50-330/82-03(DETP) Docket No. 50-329; 50-330 License No. CPPR-81; CPPR-82 Licensee: Consumers Powers Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Plants, Units 1 and 2 Inspection At: Midland Site, Midland, MI Inspection Conducted: April 12-14, 21-23 and 29, 1982.

(.h. W jbn Inspectors: R. N. G dner LBA C g -/q - 7.?_ - R. B. Landsman Accompanying Personnel: C. E. Norelius (April 12-13) C. C. Williams (April 29) J. F. Norton (April 21-23) J. L., Lych (April 21-23) . Approved By: C. C. %1ha s, Chief [ [[ 7 M lant Systems Section // . . Inspection Summary ' Inspection on April 12-14, 21-23, and 29, 1982 (Report No. 50-329/82-03(DETP); 50-330/82-03(DETP)) A_reas Inspected: Followup on previously identified inspection findings; verification of QA Program for deep-seated benchmarks, BWST remedial work, and freezewall monitoring pits.

The inspectors also attended two meetings in Midland with intervenors, NRR and the licensee. The inspectors also attended a ACRS Subcommittee meeting in Washington, D.C.

The inspection involved a total of 75 inspector-hours by two NRC inspectors.

Results: Of the areas inspected, one item of noncompliance was identified - Severity Level IV, Failure to follow procedures.

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__ __ - - . , DETAILS I Persons Contacted Consumers Power Company J. A. Mooney, Executive Manager, Midland Project Office J. Shaub, Assistant Executive Manager, Midland Project Office l W. R. Bird, MPQAD Manager M. Curlan, QA Superintendent M. J. Shaeffer, MPQAD, Electrical Section Head D. E. Horn, MPQAD, Civil Section Head H. P. Leonard, MPQAD, HVAC Section Head G. Murray, Site Management Office - Construction D. Sibbald, Site Management Office - Construction R. M. Wheeler, Site Management Office - Construction B. Palmer, MPQAD, GED Tech J. L. Donnell, MPQAD, Civil ,,, , Bechtel Power Corporation d M. A. Dietrich, PQAE

i J. Fisher, Manager, Bechtel Remedial Soils S. Kerter, Civil CQE D. S. Preslar, Lead Electrical CQE G. D. Warner, Resident, Lead Electrical Engineer NRC D. G. Eischut, Director, NRR, Division of Licensing R. H. Vollmer, Director, NRR, Division of Engineering E. G. Adensam, Chief, NRR, Licensing Branch No. 4 D. S. Hood, NRR, Project Manager, Midland R. Cook, SRI Other licensee and contractor personnel were routinely contacted during the course of these inspections.

, Licensee Actions on Previously Identified Items (Closed) Unresolved Item (50-329/80-01-06; 50-330/80-01-07): The NRC had requested additional information concerning fire retardance requirements for electrical internal cables located in the Nuclear Instrumentation ' (NI) and Reactor Protection System (RPS) cabinets.

Babcock and Wilcox letter to Consumers Power Company, dated December 4, 1981, identifies the use of teflon wiring in the manufacture of the NI/RPS cabinets.

Further, Consumers Power Company Internal Correspondence, dated February 15, 1982 states, in part, "... Bailey Controls Company stated teflon wire that had passed the FR-1 Vertical Flame Test had been used in the NI/RPS... cabinets".

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. . . , (Closed) Unresolved Item (50-329/81-11-01; 50-330/81-11-01): The inspector questioned the lack of procedural requirements for the sealing of cable ends on pulled electrical cables. The licensee, in response to Quality Action Request (QAR) F-049, has determined that the installation of cable end scals af ter pulling is not necessary if the cable is in a controlled environment and its ends are positioned so as not to be susceptible to direct contact with liquid contaminants. The licensee requires cable end seals for underground cable runs which are outdoors or in uncontrolled environments.

(Closed) Noncompliance (50-329/81-11-06; 50-330/81-11-05): Installed cable 1BB6404A located in Motor Control Center 1B64 violated the minimum bend radius critoria.

Bechtel procedure FPE7.000 has been revised to incorporate minimum bend radius criteria for cables inside equipment. Nonconformance report (NCR) 3405 was closed on March 10, 1982. The inspector verified that the subject cabic is now terminated such that the minimum bend radius is not violated.

(Closed) Noncompliance (50-330/81-12-07): It was observed that cable 2AB2322B had been installed in Motor Control Center 2B23 with a minimum . bond radius violation. This condition was documented on licensee NCR M-01-9-1-061, dated May 21, 1981. The subject NCR was closed on December 18, 1981. The inspector verified that the cable is now installed such that the minimum bend radius is not violated.

(0 pen) Noncompliance (50-329/82-06-02; 50-330/82-06-02): The licensee was performing underpinning instrumentation installation activities without a quality assurance program established to control these activities. The licensee, as stated in the March 31, 1982, letter to the NRC, suspended all underpinning instrumentation installation activities pending the development of approved, controlled drawings and procedures / instructions to prescribe these activities. During this inspection, the inspector reviewed underpinning instrumentation cabic pulling drawings, procedures, and the plans established to inspect and audit cablo pulling activities.

The inspector reviewed the following drawings, procedures, and instructions: Drawings Reviewed C-198-11, Revision 2, " Instrument Cable Installation" Procedure Reviewed FPE 4.000, Rcvision 5, " Installation and Rework of Electrical Cables" Quality Control Instructions Reviewed EU-4.0, Revision 0, " Installation of Electrical Cable for Underpinning Data Acquisition System" EU-1.0, Revision 0, " Installation of Conduit and Boxes for Underpinning Data Acquisition System"

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. , Quality Assurance Overinspection Instructions Reviewed EU-4a, Revision 0, " Installation of Conduit and Boxes for Underpinning Data Acquisition System" EU-5A, Revision 0, " Installation of Electrical Cables for Underpinning Data Acquisition System" The inspector determined that the above drawings, procedures, and instructions were acceptable. The licensee was informed that underpinning instrumentation cable pulling activities could be resumed.

This item will remain open pending the establishment and implementation of a quality assurance program for all underpinning instrumentation installation activities.

l (Closed) Open Item (50-329/82-06-03; 50-330/82-06-03): The inspector ques-tioned the lack of procedural requirements for requiring the revision to drawings due to FCR's.

Subsequently, the inspector determined that CPCo's Document Control Procedure No. 6-1 requires that the number of attachment changes to a drawing be limited to four.

Thereafter, any change results in its incorportion into the drawing. During a review of drawings con-trolling the freezewall monitoring pits, the inspector determined that Bechtel Drawing C-1315 has nine outstanding FCR's and Drawing C-1316 has five outstanding FCR's.

Because the licensee has not been revising drawings due to FCR's and the subsequent discovery that there is a pro-cedural requirement to do just that, this open item is to be escalated-to an item of noncompliance with 10 CFR 50, Appendix B, Criterion V as described in the Appendix of the report transmittal letter (329/82-03-01A; 330/82-03-1A).

It was the licensee's position that the' procedural require-ment only governs CPCo's drawings and not Bechtel's. Bechtel only has to follow its procedural requirements of revising the drawing once every 180 days for changes. The inspector informed the licensee that Criterion II of Appendix B states in part, "that the QA program shall provide control over activities affecting quality...to an extent consistent with their importance".

If CPCo ascertained that it was important to safety to revise a drawing after 5 FCR's have been written against it, then this design control criteria is equally applicable to their subs.

Functional or Program Areas Inspected 1.

Deep Seated Benchmarks The inspection was conducted to verify the implementation of the QA Program for the benchmarks. The benchmarks are being installed to monitor the movement of the auxiliary building during underpinning operations.

The inspector reviewd the following documents controlling the bench-marks installation:

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Subcontractor Procedure GP-16, " Benchmark Installation," , Revision 1, dated January 28, 1982.

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Records of the nine completed benchmarks which included QA over-inspection plans C-19C and subcontractor QC logs.

From this review the inspector concluded that the nine benchmarks are satisfactory to monitor the movement of the auxiliary building.

2.

BWST Remedial Work During an inspection of the remedial work on the BWST, the inspector observed that while removing an electrical duct bank by BWST #2 valve pit, the workmen were also undermining the southwest corner of the valve pit.

From discussions with site personnel, it was determined that excavations on site in "Q" areas are not considered under their quality plan. That is, excavating activities on site are not controlled by either QC or QA. Only the replacement of material in "Q" areas is censidered quality related. The site specification governing excavations, C-211, does not provide the degree of controls necessary for the protection to be used during excavation. Controls are necessary to prevent disturbance of found-ation subgrade for structures, maintain the integrity of compacted backfill and protect existing buried installations. This failure to have an adriquate procedure is another example of noncompliance j with 10 CFR 50, Appendix B, Criterion V as described in the Appendix of the report transmittal letter (329/82-03-1B; 330/82-03-1B).

Subsequent to the inspectors findings, QA issued nonconformance report ' No. M01-9-2-051, regarding the need for specific criteria and direction for excavating on site.

3.

Freeze Wall Monitoring Pits The inspection was conducted to verify the implementation of the QA Program for the monitoring pits. These pits are to keep ground heave from having any effect on safety-related buried utilities.

The inspector reviewed the following documents controlling the monitor-ing pit installations: , a.

Subcontractor Procedure C-195-52-1, " Integrated Construction Pro-cedure for the Installation of Monitoring Pits for 26" Service Water Lines," Revision 1, dated April 9, 1982.

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Subcontractor Procedure C-195-55-1, " Integrated Construction Pro-cedure for the Installation of Monitoring Pits for Installation of Sheet Piles for Deep Q Duct-Bank," Revision 1, dated April 9, 1982.

PIPR C-26-E, " Installation Inspection of Monitoring Pits for 26" c.

, Service Water Lines," Revision 0, dated April 14, 1982.

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PIPR C-26-F, " Installation Inspection of Sheet Piles for Deep Q Duck-Bank," Revision 0, dated April 14, 1982.

FIR MCP-34, " Installation of Sheet Piles for Deep Q Duct-Bank e.

Access Pit," dated April 14, 1982, f.

FIR MCP-33, " Installation of Monitoring Pits for 26" Service Water Lines," dated April 14, 1982.

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Mergentine Drawings; C-195-54(1)-1, Revision 0, dated April 9, 1982 C-195-54(2)-1, Revision 0, dated April 9, 1982 C-195-58-1, Revision 0, dated April 9, 1982.

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Bechtel Drawings; C-1315, Revision 0, dated February 1, 1982 C-1316, Revision 0, dated February 1, 1982 From this review, the following concern was discussed with the licensee.

Mergentine's two procedures, numbers 52 and 55, were found to be all + marked-up in ink to show changes made. There was no evidence as to when or by whom the changes were made. CPCo's Design Control Pro-cedure No. 3 requires that verification of design be performed by individuals other than those who performed the original design. This failure to have evidence of design verification is another example of the licensee's noncompliance with 10 CFR 50, Appendix B, Criterion V as described in the Appendix of the report transmittal letter (329/82-03-1C; 330/82-03-1C).

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Meetings ! a.

The inspectors attended a meeting on April 12, 1982, in Midland between NRR officials and intervenors. The purpose of the meeting was for intervenors to voice their concerns about Midland to top , I NRR officials.

b.

The inspectors also attended a meeting in Midland followed by a site tour on April 13, 1982 between CPCo, NRR officials, Bechtel , and intervenors. The purpose of these was for top NRR officials and intervenors to obtain first-hand knowledge of the remedial soil work activities.

c The inspectors also attended a ACRS Subcommittee meeting held > in Washington D.C. on April 29, 1982. The purpose of this meeting was to inform the ACRS of the remedial actions being taken by CPCo regarding the soils settlement issues.

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Exit Interview The inspectors met with licensee representatives at the conclusion of the inspections on April 14 and 23, 1982. The inspectors sum-marized the scope and findings of the inspection. The licensee acknowledged the information.

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