ML20032A904
| ML20032A904 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/09/1981 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20032A902 | List: |
| References | |
| 136643, NUDOCS 8111020535 | |
| Download: ML20032A904 (4) | |
Text
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CORSum8IS POW 8f u-w c.*
Company and Construction General offices: 1945 Wer* Parnell Road, Jackson, MI 49201 e (517) 788 0453 September 9, 1981 Mr J G Keppler, Regional Director Office of Inspection & Enforcement US Huclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND PROJECT -
INSPECTION REPORT tIO 50-329 AND 50-330/81-lh FILE:
0.h.2 SERIAL: 13664
Reference:
J G Keppler letter to J W Cook, dated August 7, 1981 This letter, including all attachments, provides Consumers Power Company's response to the referenced letter which transmitted the subject Inspection Report and which requested our written statement regarding one item of noncompliance described in Appendix A of the reference.
Consumers Power Company By A
James W Cook Sworn and subscribed to before me this day of September, 1981.
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Beverly/A. Avery
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Uotary Public, Jackson County, Michigan My commission expires January 16, 1985 WRB/1r CC: RJCook, USNRC Resident Inspector Midland Nuclear Plant 8
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n Attach =;nt 1 Serial 13664 CONSGERS POWER CCMPANY'S PESPC"SE TO NCTICE OF VIOLATION DESCRIBED IN NRC INSPEC" ION REPORT DOCKET NO 50-329/e1-1u iNa so-330,e1-1u Appendix A (Ite= of Ncncc=pliance 329/81-lh and 330/81-1k) states in part, 1.
" Contrary to the above, procedures used by your resident engineers to review and approve field initiated redline drawings for small bore piping and piping supports were not in accordance with your Field Change Request procedures, and as a result, field initiated redline drawings were not receiving design centrol reviews ce==ensurate with those applied to the original design."
Censu=ers Pover Cc=pany's Response It is agreed that the precedures used by resident engineering for review and approval of redlines are not in agreement with the field change request procedure. They are reviewed in accordance with the applicable redline procedure a 3 ve discussed in our July 2h,1981, meeting. This procedure requires incorporation of redlines by revising the original design docu=ent.
All revisions to drawings require reviews cc==ensurate with those applied to the original design.
As noted in our response above, we believe that the ite= of nonec=pliance as stated does not exist. We*therefore request that you recensider the classification of this as an ite= of ncnce=pliance.
2.
Section II of the Inspection Report addrer ses the review conducted in regards to field change redlining procedures. The three ^kservatiens described en page 7 are addressed as follows:
A.
It e: 2a - Inspection Report Page 7 states, "Frc= March 1979, since the formation of the Site S=all Pipe group, to Nove=ber 1980, there was no established precedure for handling the review and approval of FE redline drawings that were issued per FIP 1.112 and FIP 1.110 requirements.
Censumers Pcver Cc=cany's Response We agree with this statement; hevever, it should be noted that this deficiency was noted by 3echtel and corrective measures were taken to docu=ent the practice at the time in a formal precedure implemented on Nove=ber 7,1980.
It should further be noted that in-depth investigations, bcth by Censumers Power Company and 3echcel, have shown no evidence of technical deficiencies relating to redlines.
- 3. Ite: 2b - Inspecticn Report Page 7 states, "The present ECPI L.h6.9 used by RE to review and approve redline drawings does not distinguish between ca.jor or =iner design changes.
If FI requested changes are significant, the RE should not sign off the redline drawings for construction, but chould request FCRs to be approved by the corporate engineering office, as required by EEPI-2.lu.l."
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2 Consumers Power Ccepany's Restonse This procedural enhance =ent was agreed upon in our July 2k,1981 meeting and the procedure has been revised and submitted for your review. This revision includes the criteria to distinguish between major and minor deeign changes and instructions on proper disposition of major and minor design changes. In accordance with our past practice, we agree that significant changes initially identified on redline drawings will be processed in accordance with the options described in EDPI h.h6.9, which include FCRs.
C.
Item 20 - Inspection Report Page 7 states in part, "The Small Pipe Group REs did not recognise that some of the redline hanger drawings without confirmed design loadings supported by the pipe system stress CPDCs were in violation of EDPI-h.h6.9 Paragraph 2, " Definition," which states that,
"A redline is a field mark-up work print which is transmitted frcm project constructten 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-h.37, MED 4.37-0, and MZE 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 calculaticns resulting frcm redline chaages is questionable. For scce of the hangers, the design loads were without documented basis since a system CPDC had not been established prior to structural assembly design."
Consacers Power Ccmpany's Response During the NRC inspection of the site small pipe design activities the week of May 18, it was recognized that there was a lack of procedural controls.
An i==ediate action letter was issued on May 22, 1981, and remedial actions undertaken and tne situation was sutsequently corrected. We agreed that for scme of the hanger s, the design loads were without documented basis since a system CPDC had not been established prior to structural assembly design. Pipe support load sheets had been prepared for the hanger designs by piping stress analysts althcugh a piping stress CPDC may not have existed at the time. The loads were based either upon Specificaticn 7220-M-3h3(Q) standard spans, or were calculated but inadequately documented.
A ccmprehensive and intensive program was established to provide CPDC's for all the piping isometrics. The details of this program and the scheduling of its completion has been fully disclosed to the NRC both by discussion and for=al correspondence. Resident engineering recog-nized the implications of redlines during the early stages of the CPDC review effort. At that time, additional restrictions were placed on the resident engineering redline review process to ensure that the intent of your istediate action letter of May 22, 1981, was met.
The policy of redlining was discussed with the Region III Staff when the subject was subsequently raised. We believed that our interim practice and the documentation of that practice met with your satisfaction based on the July 2h,1981 meeting including the specific understandings of additional speciff eity to be added to the redlining procedures as documented in our letter to you dated July 27, 1981.
V V
f The completion of the calculational r* views and the establishment of the CFDC's has provided evidence of the design adequacy of the small pipe support s. As the stress CPDC's were being completed, new support loads were also being evaluated. In most cases, leads decreased indicating the conservatism in the original designs. In no case was a physical change to a hanger required due to the original absence of CFDC's.
It is our belief that this demonstrates the adequacy of controls and the viability of the redlining procedures to support the site design effort.
W3B/JWC/lr