ML20028E368
| ML20028E368 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/05/1982 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20028E366 | List: |
| References | |
| 19087, NUDOCS 8301210267 | |
| Download: ML20028E368 (6) | |
Text
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Vice President ~ Projects, Engineering and Construceson General offices: 1945 West Parnell Road, Jackson, MI 49201 * (517) 78& O453 U
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Mr J G Keppler, Regional Administrator l
l-I US Nuc1 car Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEArs C0 GENERATION PLANT -
INSPECTION REPORT NO 50-329/82-18, AND 50-330/82-18 FILE:
0.4.2 SERIAL
19087
Reference:
(1) R F Warnick letter to J W Cook, dated September 22, 1982, Inspection Report No 50-329/82 '38 and 50-330/82-18 (2) J W Cook letter to J G Keppler, Serial 19079, dated October 22, 1982 This letter, including Attachment 1, provides our response to Reference 1, which transmitted the subject Inspection Report and which requested our Reference 2 written responsa on the items of noncompliance therein.
documents that the response is to be submitted by November 8, 1982.
Items 1 and 3 require a further response to provide the dates of when full compliance will be achieved. We anticipate providing this information by December 15, 1982.
Consumers Power Company 8301210267 830118 M /N PDR ADOCK 050003 By P
James W Cook O
Sworn and subscribed to before me on this 5 day of November, 1982.
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' Notary Public, Jackson County, Mich September 8, 1984 My commission expires JWC/WRB/JKM/lr NOV 10 E OCll82-9003A-MP01
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.RJCook.-NRC Resident': Inspector,: Midland' Site:
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RBLandsman,NRC' Region:III; s BLEurgess.-NRC' Region'III' i
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1 CONSUMERS POWER COMPANY'S RESPONSE TO US NUCLEAR REGULATORY COMMISSION, REGION III INSPECTION REPORT NO 50-329/82-18, 50-330/82-18 50-329/82-18 and Appendix (Notice of Violation) to Inspection Report Noprovides four items o 50-330/82-18 Our response to each item is given in turn, as follows:
NRC STATEMENT that.
10 CFR 50, Appendix B, Criterion III, states, in part,
' Measures shall be established to assure that applicabic regulatory 1.
requirements and the design basis, as defined in 50.2 and as specified in i
the licensee application... are correctly translated into... draw ngs Consumers Power Quality Assurance Program Policy No 3, Revision 12,
'Each group or organization performing in part, Paragraph 3.3 states, detailed design translates the applicable regulatory requirements, de bases, codes, standards and design criteria into design documents, such as... drawings...'
Contrary to the above, the licensee failed to translate into applicable 8.3.1.4.1.1 of the raceway drawings, the requirements of Paragraph'The minimum separation distance Midland FSAR which states, in part, separated between redundant class lE cable... is... three feetseparation is unattainable, In cases where three foot dd enclosed raceways that qualify as barriers or other barriers are provi e vertically...
This is exemplified by the 2' 5" centerline between redundant circuits.'
for redundant raceway 1DH058 to centerline vertical dimension requirement Further, there and 1BFF001 as identified on raceway drawing E-628(Q).
were no barrier requiremeats identified on the applicable racewayAs drawings.
in raceways 1DH058 and 1BFF001 with a vertical separation of approximately 20 inches.
This is a Severity Level V violation (Supplement II)."
CONSUMERS POWER COMPANY RESPONSE The technical criteria as provided for with the additional detail given in (DCN) No 6 to E-47 and DCN No 157 to E-42, provides the Design Change Notice the necessary information to assure the plant design is in conformance to final safety analysis (FSAR) requirements.
the CPCo will establish additional programmatic elements to assure that process corrective action for identifying separation violations are in place by December 31, 1982.
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NRC STATEMENT
- that, 10 CFR 50, Appendix B, Criterion III, states in part,' Me i
"2.
quality standards are specified and includedPolicy No 3, Consumers Power Company Quality Assurance Program'The organization
- that, Revision 12, Paragraph 3.4 states in part, itable.'
assures that the designs and materials are su ify the Contrary to the above, Specification C-197 did not specFurthermore, the sampli location for the well sampling points.
points being used were in the wrong location.
d closed 329/62-18-02 and 330/82-18-01 an This item is labeled 50-329/82-11-04; 50-330/82-11-03."
unresolved item CONSUMERS POWER COMPANY RESPONSE ified in Locations of the sampling points were not originally specProject Engine ice tcocks to be Specification C-197.(SCN) 12004 to Specification C-197 requiring the sampl In July 1982, the line.
located on a horizontal run of pipe below the center ith the SCN.
petcocks were changed, as required, to conform w th to determine Subsequently, a study was performed for a period of one montration of fines samp Four the effect of sampling locations on the concenTwo sampling petcocks were located on the h East and West sampling points were monitored. horizontal and two on the original verti l
returns of the ME dewatering system, respective y.
2, 1982 until i d from August h
monitored a total of 10 times during the per oThe testing for fines were performed d d for both the 50 September 2, 1982.US Testing Procedure QCP-8 and the results were recor eTh d between rust, algae Micron and 5 Micron filters. fines retained on the filters and no d and soil particles.
f fines the measured difference in concentration ortical pipes varied This study indicates thatbetween the petcocks located on the horizontal an h
sampling locations by approximately + 1.0 ppm. difference in concentrations of fines observed in h
rather than the l
is indicative of the sampling and testing methodo ogy l
The average concentration of fines measured in samp es sampling J ocation.
t The taken from petcocks located on the horizon ad on the vertical pipes.
the samples taken from the petcocks locate l sampling locations ranged from readings for both the vertical and horizontaless than 0.0 ppa to limit of 10 ppm.
is considered consistent On the basis of these results, previous monitoringlidating previous monitoring lls have been with present monitoring methods therefore vaFines monitoring for de operating within allowable limits and the resu data.
conformance to project requirements.
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Attachmint 1 3
NRC STATEMENT "3.
10 CFR 50, Appendix B, Criterion V, states in part, that,
' Activities affecting auality shall be prescribed by documented instructions, procedures, or drawings... and shall be accomplished in accordance with these instructions, procedures, or drawings.'
Consumers Power Quality Assurance Program Policy No 5, Revision 12, Paragraph 1.0 states, in part that, ' Instructions for controlling and performing activities affecting quality... are documented on instructions... these documents provide qualitative and quantitative acceptance criteria for determining that important activities have been satisfactorily accomplished.'
Contrary to the above, the licensee failed to assure that the slope layback at the Auxiliary Building access shaft was constructed in accordance with design drawing C-1421. The completed slope was 1:1 instead of 1 :1 as required by the drawing.
Furthermore, Bechtel issued au FCN after the fact instead of an NCR as required by their procedures. Additionally, the Onsite Geotechnical Engineer did not perform his monitoring duties as required by the site Excavation Permit System Procedure.
This item is labeled 329/82-18-02 and 330/82-18-02."
CONSUMERS POWER COMPANY RESPONSE Project Engineering is reviewing the as built condition of the slope layback to determine if the slope layback can be used ac is or will require rework.
The current condition poses no problem. The engineering disposition, which is anticipated by November 9, 1982, is required to assure that the configuration has been analyzed in terms of all future construction work anticipated in that area.
The Field Soils Organization (FS0) conducted training in the proper use of FCRs/FCNs and the need to write NCRs. This training was given to all FSO Field Engineers on November 2, 1982. The training augmented training for all Bechtel Field Engineers on the proper use of FCRs, held on September 3, 1982.
The Resident Geotechnical Engineer conducted training in the responsibilities of the Onsite Geotechnical Engineer as they relate to the Site Excavation Permit Procedure. This training was given to all Onsite Geotechnical Soil Engineer / Resident Geotechnical Engineers on November 2, 1982. This augmented training on the Excavation Permit System held on October 11, 1982 and attended by all GSO/RGE personnel.
NRC STATEMENT "4.
10 CFR 50, Appendix B Criterion IX, states in part, that, ' Measures shall be established to assure that special processes... are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable... criteria, and other special requirements.'
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Attachmsnt 1 4
Concumers Power Quality Assurance Program Policy No 9 Revision 12, Pargraph 1.0, states in part, that, 'Where the required level of quality cannot be measured by inspection only of the item...
accomplish these processes under controlled conditions in accordance with applicable codes, standards and specifications using qualified procedures, equipment and personnel.'
Contrary to the above, the inspector determined that the calibration of the crack grouting equipment used for the BWST was not controlled using qualified procedures. This resulted in inadequate assurance that both the required grouting pressure and component mix were being adhered to.
This item is labeled 329/82-18-04 and 330/82-18-03."
CONSUMERS POWER COMPANY RESPONSE An approved procedure, " Guidelines for Specific Structure Concrete Bonding Process," by Adhesive Engineering Company, was used to calibrate the mixing ratio of the adhesive components for the grout. Pressure gages and measuring containers were calibrated prior to mixed ratio determination. Mixing ratios for component flow were tested at a line pressure of 0 psi and 200 psi.
During calibration testing, the pressure gages for adhesive component supply 1
lines were adjusted in accordance with the procedure to maintain a required line pressure of 200 psi.
These minor pressure adjustments were required due to the inherent viscosity properties of the adhesive components, Both adhesive components were simultaneously discharged into separate calibration containers. The amounts discharged during the same time period were compared to determine whether the mixed ratio met specification requirements.
In operation, the adhesive component lines enter an open chamber within the mixing gun. The two components then flow into a mixing channel to the gun i
nozzle. A single pressure gage is mounted on one of the component lines adjacent to the grout gun.
The supply lines and the channels within the gun are comparatively large and the fluid velocity in these areas is small such I
that there is essentially no pressure drop in this part of the system.
Essentially all of the pressure drop is taken across the gun discharge, thus the pressure gage located in one line is representative of the pressure in both supply lines and within the gun.
The calibration test is an actual simulation of the grouting process. Therefore, mixing ratios meeting such pressure requirements by the calibration test indicate adequate assurance of proper mixing ratios during grouting.
It is our position that the vendor's procedure which stipulates the calibration steps does not require further user qualification and that both the calibration and the actual grouting was done in conformance to requirements.
WRb/JKM/MJS/lr 1
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