ML19318B505

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Responds to NRC Re Violation Noted in IE Insp Repts 50-329/80-09 & 50-330/80-10.Corrective Actions: Noncomformance Rept Re Failure to Approve Acceptance Criteria Mod for Reactor Vessel Levelness Was Issued
ML19318B505
Person / Time
Site: Midland
Issue date: 05/22/1980
From: Jackie Cook
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19318B502 List:
References
NUDOCS 8006260342
Download: ML19318B505 (3)


Text

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%ce Pressdent, AtsJland hufect Gener al of fices. 1945 West Parnell Road, Jackson, Mechegan 49201 e (517) 788 0640 May 22, 1980 Mr J G Keppler, Regional Director Office of Inspection & Enforcement US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND PROJECT NRC ITEM OF NONCOMPLIANCE - DEFICIENCY INSPECTION REPORT 50-329/80-09 AND 50-330/80-10 FILE:

0.h.2 UFI: 73*60*13 SERIAL: 8992 l

Reference:

Inspection Report No 50-329/80-09 and 50-330/80-10 This letter, with its enclosure, is in response to your letter of April 26, i

1980, as modified by your letter of May 12, 1980, which transmitted the results of your inspection of the Midland Construction Site during the period of February 1-29, 1980 and which requested our written r*

  • ement on the item of noncompliance.

M REW/1r JUN 2 280 B006260 1 0

r 2

requirements but not level with.003", thus requiring the internals to be set parallel to the Reactor Vessel mating face.

Several attempts were made to meet the.003" requirement approximately 1" above the core ledce as required by the procedure, but the.003" van unattainable. The.003" total was attainable when the internals support ledge was above the Ecactor Vessel aligmnent keys; however, a.005" total was experienced with the internals support ledge in the keys.

Because this did not meet the requirement of the procedure, Lynchburg van contacted and the results transmitted. Tuesday, January 15, Lynchburg advised verbally that it would be acceptable to proceed with the trial fit and that viitten response vould be forthcoming t, hat evenir.6 Due to difficulty in transmitting the information, it was not received until 10:00 AM Wednesday, January 16.

By this time and because verbal approval had been received, ILECC decided to proceed with the fit-up even though it violr.ted thcir procedure.

The objective cf the.003" is to allow establishment of core block settings of.0h0" clearance for each pair.

If this is not attained, the procedure requires the leveling operation to be repeated after further core block adjurtments. During the first settinc of the blocks, the correct block clearance dimensions were not obtained.

By the magnitude of the dimensions it was decided that causes other than the levelness of the internals affected the block setting.

It was decided that the IcVeling operation sculd be repeated as provided by the procedure to reset the core blocks. The second setting of the core blocks was acceptable.

However, the levelness and the outlet nozzle clearance were cutside their tolerance requirements. A B&W UCR was issued defining the nonconformances.

This was transmitted to Lynchburg for approval and accepted by an addendw: to Site Procedure Report 13-12.1hh-00.

B&WCC has committed that in the future they vill make every attempt possible to improve response time from Lynchburg. This vill be handled through the BLU Site Cencultant office. The Site Consultant vill expeditt the written approvnic end B&W Constructicn vill not prcceed until written approval is received.

QA Procedure P-QA-05, paragraph 5 and QC Procedure 9-QpF-102, paracraphs 2.2 and 2.3 prohibit proceeding without an approved Field Construction Procedure.

REW/Ir 5/22/80

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Enclosure to Serial: 8992 CONSlNERS POUER COMPANY RESPONSE TO THE ITEM OF NONCOMFLIANCE DESCRIBUD IN NRC INOPECTION REPORT NO 50-3P9/60-09 AND N3 50-330 /80-3 0 NONCONFORMANCE TO B&WCC FIELD CONSTRUCTION PROCEDURE; DEFICIENCY -

50-329/00-09-1 AND 50-330/60-10-1 A.

Descripticn of Deficiency Appendix A of Report No 50-329/80-09 and 50-330/80-10 provides the following:

" Based on-the results of an NRC inspection conducted on February 1-29, 1980, it appears that certain of your activities were not conducted in full compliance with NRC requirements as noted below. This item is a deficiency.

10 CFR 50, Appendix B, Criterion V, states, in part, that,

' Activities affecting quality shall be prescribed by documented instruction, procedures,

. and shall be accomplished in accordance with these instructions, procedures, B&W Quality Control Procedure No 9-QPP-102, Field Construction Procedures states, in part, that, 'Each sequence of a Field Construction Procedure shall be signed and dated by the supervisory personnel responsible for the work activity accomplished at a given sequence.'

Contrary to the above, the Resident Inspector determined that work sequentially proceeded through Field Construction Procedure No 132, Trial Fit-Up of Internals Core Support Assembly (as written) withvut maintaining the 0.003 inch levelness require-ments. referenced in preceding steps during corc support asses.bly lifts when the reactor vessel alignment keys were engaged.

Relief from the 0.003 inch levelness requirements had been

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received in a response to Site Problem Berert No 13-12-14h-00 for this portion of the ossembly that was not reflected in the procedure being used at the assembly location."

B.

Response

CPCo Nonconformance Report M-03 h-0-00h was issued identifying B&W Constructica Company's (B&WCC) failure to obtain written approval to modify the acceptance criteria for levelness of the reactor vessel internals prior to the accomplishment of the leveling activity. The i

following is the B&WCC response to that NCR.

In setting the core internals into 'the Reactor Vessel for_ the purpose of establishing the required clearance dimension on the core blocks, some difficulty in obtaining levelress was experienced. The difficulty in leveling stemmed partly from the ticht.003" total leveJ ncss require-j ment and partly because the Reactor Vessel was' leveled within drawing

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