ML20040F309
| ML20040F309 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/14/1982 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20040F298 | List: |
| References | |
| NUDOCS 8202090065 | |
| Download: ML20040F309 (4) | |
Text
.
eg Consumers Power James W Cook C0mpany vi,, n,,u,,,. n.,,,,a.,i,,a,,
W and Construction General offices: 1945 West PernaH Road, Jackson, MI 49201 * (517) 788 0453 January 14, 1982 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 -
INSPECTION REPORT NOS 50-329/81-12 AND 50-330/81-12 FILE 0.4.2 SERIAL 15?56 Re ference :
- 1) NRC letter, C E Norelius to J W Cook, dated December 3, 1981 This letter, including the attachment, provides Consumers Power Company's response to Reference 1.
Our response was requested to be within 25 days of receipt of Paference 1.
The delay beyond that date, January 1, 1982, was to permit full coordination with the responsible Region III personnel and has been with their understanding and concurrence.
Consumers Power Company By l
James W Cook Sworn and subscribed to before me on th'is 14th day of January, 1982.
l 1
sc M l
Nota [yPhlic,MidlandCounty, Michigan My commission expires Dec.
7, / 90 s GARY A. SIMONEAU Notary Public Midiand County, Mich, t
l My Commission Expires Dec. 7,1933 CC: RJCook, NRC Resident Inspector Midland Nuclear Plant UA}{ 18
\\
B202090065 820203 PDR ADOCK 05000329 C
CONSUMERS POWER COMPANY'S RESPONSE TO US NUCLEAR REGULATORY COMMISSION, REGION III LETTER DATED DECEMBER 3, 1981 DOCKET NUMBERS53-329 AND 50-330 1.
Paragraph 1 of the Region III letter of December 3,1981, requests clarification of two issues, a.
Paragraph la of this letter states:
Field alteration of piping support and restraint installations subsequent to QC inspection and. sign off has not been clearly adcressed.
Identification and correction of problems during final system walk-down prior to preoperational and/or startup tests should be the exception, not the rule.
Your QA pro-gram should include measures to protect systems from damage and alterations after final acceptance by quality control CONSUMERS POWER COMPANY'S RESPONSE We regret that there was an editorial error.which made it appear that we were not being fully responsive to your concern regarding field alteration of piping support and restraint installations subsequent to QC inspection and sign off.
In the third paragraph on page two of the attachment to the October 30, 1981 letter, as a part of our response to violation Item 4, we referenced " Item 6 in your Notice of Violation". We should have refer-enced Item 3.
We apologize for the confusion this editorial error must have caused you.
Our response to Item 3, transmitted on August 7, 1981, stated:
Bechtel Construction has developed Administrative Guidelines addressing rework.
The Administrative Guidelines provide refer-ence to particular field procedures and our1.ine the means of administrative 1y processing rework information such that proper notifications and coordination are attained.
Bechtel Quality control has also developed Administrative Instructions to indi-cate the process followed for processing rework items.
It is noted that the above-referenced Administrative Guidelines and Instructions have been developed for Civil, Instrumentation, Mechanical and Electrical disciplines, and these actions in the Mechanical area.are considered: responsive to Unresolved Item -
329/81-12-15 and 330/81-12-16 concerning procedural provisions to control design revisions on small bore piping and piping suspen-sion systeam.
In the Mechanical area, the guidelines have been issued and revisions to the appropriate Mechanical procedures have been made and are expected to be issued for use by August 12, 1981.
2 The definition of rework as used in these guidelines and procedures includes both the removal of an accepted ins tallation for the purpose of accomplishing a design change on it, and temporary re= oval of an accepted installation simply to accomodate construction congestion.
These guidelines and procedures have.now been released and are being implemented.
This action should preclude unauthorized rework subse-quent to QC inspection and sign off.
b.
Paragraph lb of the Region III letter states:
Your response states, " Project Engineering has been requested to evaluate the conditions represented by Items e, g and h."
What consideration has been given to the possibility that field installation was carried out without a clear understanding of the design require-ments and related interpretations?
CONSUMERS POWER COMPATt'S RESPONSE 3
With respect to Item e, Bechtel Project Engineering was asked to consider whether or not.the pipe hanger and restraint installation tolerances given in Specification 7220-M-326(Q) are in confor=ance with the design requirements.
In response to this question, Bechtel Project Engineering stated that there is only a minimum installation clearance requirement and that there is no.naximum installation clearance requirement, unless specified on the drawing.' TheEE Ts a fabrication interfacing dimensional constraint, which when met, re-sults in an acceptable =aximum installation clearance.
This dimen-sional constraint is verified at the time of fabrication.
When the minimum installation clearance and the fabrication dimensional requirenents are met, design stresses will not be exceeded.
Based on this Project Engineering response, we conclude that the tolerances are in conformance with. the design requirements.
Further-more, se have verified that the 3echtel QC inspections and the MPQAD overinspections are being performed with the full understanding of the tolerances as. set forth above.
Finally, since it appears the circumstances concerning this item should have raised some question as to the proper interpretation of the pertinent design requirements, it has been reemphasized to all QA/QC personnel that, any ti=e such a question or doubt arises, they are to promptly seek written direction from Project Engineering.
With respect to Items g and h, Sechtel Project Engineering was asked to consider whether or not the Technical Specification is an adequate and complete statement of the design requirements.
In response to this question, 3echtel Project Engineering stated that the strength of grouted anchor bolts is controlled by the bond strength between the grout and the
)
concrete interface.
The strength of the concrete cone pull-out, calcu-lated per ACE 349-81, Appendix 3, is approximately three times the design strength of the grout-to-concrete interface.
Therefore, small holes i
drilled within this concrete. cone will not.have a detrimental effect until i
the potential pull-out surface of that concrete cone is reduced by approxi-
{
mately two thirds.
Based on this Project Engineering response, we conclude that the desi t require =ents as currentdyt statad in the Technical Specifica-e tion are adequate.
The occurence of abandoned holes in the proximity 1
7 d
3 of a single grouted-in anchor bolt in such numbers that they would reduce the pull-out area of the concrete cone around the bolt by two-thirds seems highly im'robable. Nevet-the-less, to preclude p
even the remotest possibility of such an occurence, Project Engineer-ing vill revise the Technical Specification to incorporate their response to our question.
2.
Paragraph 2..of the Region III letter states:
Our letter dated September 16, 1981, requested that you provide a date'when full compliance was or will be achieved for each of the eight items of noncompliance. While your additional response for Items'4, 5 and 8 satisfied our re-quest, you failed to provide a date for the other items.
CONSUMERS POWER COMPANY'S RESPONSE The dates for which we were in full compliance'are as follows:
a.
Item 1 - December 31, 1981 b.
Item 2 - December 31, 1981 c.
Item 3 - November 24, 1981 d.
Item 6 - August 5, 1981 e.
Item 7 - May 29, 1981
.