ML19324A101

Responds to NRC 800418 Ltr Re Violations Noted in IE Insp Repts 50-329/80-01 & 50-330/80-01.Corrective Actions:Freeze Will Be Placed on Implementing Design Changes 90 Days Prior to Scheduled Turnover

ML19324A101
Person / Time
Site:	Midland
Issue date:	05/15/1980
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19324A090	List: ML19324A101
References
8968, NUDOCS 8006200537
Download: ML19324A101 (3)

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Consurims power James W Cook ComDgY MEE Vsce PressJent. \tsJLund Prerject Generat omces. 1945 West Parmall Road, Jackson, Michigan 49201

• t517) 788-0640 May 15, 1980 Mr J 0 Keppler, Regional Director Office of Inspection and Enforce.ent US !uclesr Regulatory Cc=missicn Regicn III 799 Roosevelt Read Glen Ellyn, IL 60137

'4IDLA:!D PROJECT

!RC ITI:: OF OZVIATIC:!

I::SFECTION REPORT No 50-329/80-01 AND 50-330/80-01 FILE: 0.L.2 UFI: 73*60*13 SERIAL: 8968

References:

1) S H Howell letter to J G Keppler; Midland Nuclear Plant - NRC Item of Ncncompliance; Inspection Report No 50-329/80-01 and No 50-330/80-01; Serial Howe-60-80; dated March 21, 1980

2) G Fiore111 letter to S H Howell; dated April 18, 1980 Reference 1 transmitted our response to the Inspecticn Report No 50-329/80-01 and No 50-330/80-01. Subsequent discussions with your staff identified the need for more information on the deviation concerned with handling of design changes on ecmpleted work. Reference 2 documents the understanding that Consumers Power Company would supply a supplemental response on the deviation.

The attachment to this letter fulfills that ec=mitment.

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'a3/lr Attachment MAY 211980 8006200 g g

Attachment to Serial: 8968 SUPPLEE;TAL PESPONSE TO NPC DEVIATION 329/80-01-02; 330/80-01-03

'A. Description of Deviation Appendix B of Report 50-329/80-01 and 50-330/80-01 provides the following:

" Eased'on the inspection conducted on Ceteber 10-12, 1FT9 and January 8-11, 1980, it appears that certain of your activities were not in .accordance with co==ittents, codes , standards, guides, or acceptable practices, as noted below.

Consumers Power Company letter dated June 18, 1976 to Mr J G Keppler, Item 11.B, states, 'Eechtel vill change its program so that in the future, nonconformance reports need not be written when design is changed after the activity is ecmplete. In lieu of this (using the NCR), Bechtel Field Engineering vill cither implement the design change or prepare a Field Change Request. In addition, the plan of action described for Topic 1 vill be useful .*n preventing further

-7 instances of changes to design after completion of constructicn.

Consumers Power vill review the procedural change resulting frem this plan of action prior to the implementation.'

Contrary to the above, on October 11, 1979, the inspector established that a design change was made to Unit 2 Make-Up and Purification System, line No h"-2CCB-1 from the Make-Up Pump, 2P-583 to Valve No h0h-2-007 on April 19, 1978. This design change was neither tsplemented nor was a Field Change Request prepared. Furthermore, it was established that procedure for handling design change of completed work does not exist."

B. Response The original response to 'this item stated that Bechtel was revising Bechtel Field Procedure FFD-1.000(Q), " Design Document and Correspondence Control," in order to resolve concerns on implementation of design changes to completed work. This change was to be effected by completing a New Drawing Sign-off Sheet for the required drawing per procedure FPD-1.000(Q) with an estimate? date of completion being May 1,1980. Subsequent to that response, there vere a number of questions from Region III relative to that response. After analyzing those questions and our original response, it is no longer our intent to change FPD-1.000(Q). The following is submitted as the method by which such changes will be controlled:

As a part of the normal activities, Quality Control reviews quality control inspection records (QCIRs) and reconciles any differences in design document revision numbers. Specifically, a freeze vill be placed on Enplementing design changes 90 days prior to scheduled turnover.

Bechtel Engineering Department Project Instruction (EDPI) h.h7.1 vill be issued by May-31, 1980 with an Snplementation date' of June 30,1980 to cover this. As a part of the quality verification, preparatory to turnover, Quality Control vill identify the differences between the design docusent revision that was.used for acceptance inspection on the applicable QC7Rs and the revision that is in effect when the design

. .e . - . s freese:is initiated. The differences between the revisions will be evaluated and;the' appropriate action taken to' reconcile the differences.

This vill consist of either verifying.that the revisions to the design document have not :affected the work inspected on the applicable QCIRs or by conducting a reinspection to the revised design ~ requirements.

Quality Control vill issue a procedure by the week of May 19, 1980 giving the. mechanics of the design. revision reconciliation process.

This system vill track changes to insure that .they are made and not lost and will-be ' applied to .all' disciplines except where an . equivalent closed' loop system is in effect (eg, electrical cable pull and raceway c ards ) .

This progra= resolves the questien of design changes which have been made over the. life of the project since by definition they exist at time of turnover. In ~ addition to the Eechtel _Frogram, Censumers Power Company's overinspection program has provided a check in the past and vill continue to provide a check that ec=pleted work meets the latest design drawings and specifications.

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