ML20069K397
| ML20069K397 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/30/1982 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20069K389 | List: |
| References | |
| 19052, NUDOCS 8210260195 | |
| Download: ML20069K397 (4) | |
Text
Consumers Power Campany 0"1",Lj,,,,, r.,,,,s.,
and Construction General offices: 1945 West Pernell Road, Jackson, MI 49201 + (517) 788 0453 September 30, 1982 Ifr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Pegion III 199 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND PROJECT -
- INSPECTION REPORT NOS 50-329/82-05 (DETP) & 50-330/82-05 (DETP) AND 50-329/82-06 & 50-330/82-06 FILE
0.4.2 SERIAL
19052
References:
(1) NRC Letter, C E Norelius to J W Cook, dated April 26, 1982, transmitting Inspection Report 82-05 (2) NRC Letter, C E Norelius to J W Cook, dated April 26, 1982, transmitting Inspection Report 82-06 (3) Letter, J W Cook to J G Keppler, dated May 28, 1982, providing CP Co's response to Inspection Reports 82-05 and 82-06 (4) NRC Letter, R F Warnick to J W Cook, dated September 2, 1982, requesting an additional response to Inspection Reports 82-05 and 82-06 (5) Letter, J W Cook to J G Keppler, dated August 13, 1982, providing CP Co's response to Inspection Report 82-03 (6) NRC Letter, R F Warnick to J W Cook, dated September 22, 1982, requesting a further response for noncompliance item 82-03-01A Reference 4 asked for an additional response by September 27, 1982, to non-compliance items 82-05-02, part a and b, and item 82-06-01.
Mr R Gardner extended our response due date to September 30, 1982, at the oral request of our M J Schaeffer.
1:cgarding item 82-05-02, part a, the positions relative to the "Q" listing of the soldier pile installation are well documented in References 1, 3 and 4.
This situation could not be repeated now because of the additional controls initiated since the soldier piles were installed. These controls include:
- 1) Mergentine Proce: lure MCP 1.000 Q requires a specific cover sheet format appropriate to the Mergentine procedures, as well as providing overall procedural controls.
8210260195 821020
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DR ADOCK 05000329 l
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Scrial 19052
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An excavation permit system is in place to control excavations.in "Q" soil.
- 3) The ALAB Order dated April 30, 1982 and the Quality Assurance Plan, MPQP-2, now clearly make this type of work rubject to the Quality Assurance Program.
- 4) The NRC and CP Co Work Authorization Procedure, dated August 12, 1982, provides for the specific authorization by the NRC as a' prerequisite for any construction work covered by the ALAB Order of April 30, 1982.
The implementation of the above controls provided the corrective action to assure
- that the Project is in compliance on this matter.
Regarding Item 82-05-02, Part B, we believe that it is impractical to proceduralize a time limit for the distribution of Specification Change Notices (SCNs) from the time they are released by Project Engineering to the time they are distributed at the site. As described in Reference 4, Project Engineering must provide the effectivity of the SCN, including its effect on any backfit and on work underway.
Distribution of the SCN, once received by Construction Document Control, is normally within two working days. A review will be made of the SCNs written in September to determine how long it takes for an SCN to be distributed once released by Project Engineering. This should provide a basis for determining if improvements are necessary in.the schedular controls'for SCN distribution.
Regarding 82-06-02 dealing with the overinspection of Class IE Cable, we are contin-uing the review of this task to determine the most effective approach and.the schedule to accomplish the objective of assuring that cable routing satisfies FSAR requirements. We anticipate providing a further response on this item by October 15, 1982.
Regarding Itra 82-03-01, Reference 5 stated that by August' 30, 1982, the Bechtel procedures would be revised to require the incorporation of FCRs/FCNs into the drawing when a combined total of 15 FCNs and FCRs are' approved by Project Engineering.
During the week of September 13, 1982, Dr R Landsman was informed that this procedur-l al change was not yet issued.
It should be noted that the new requirement was issued l
by Project Engineering directive on June 17, 1982. Since the initial response was made, the Project has been discussing additional measures to further control this process. The Bechtel procedural revision was not initiated while awaiting the final decision on these measures. As of September 23, 1982, Project Engineering issued a further directive that requires that Bechtel will initiate incorporation when 15 i
drawing change documents are received (rather than when they are approved) and that the drawing revision will be processed within 30 days (including the final approval).
The same type of exclusions remain as to the types of design change documents which do not have to be incorporated. The formal change of the Engineering Procedures will be made by October 30, 1982.
We are revising the Consumers Power Company Quality Assurance Program Procedure No 6-1 concerning the number of attachment changes to drawings, to require that Lead Design Organizations, during the design and construction phase, have controls in place appropriate to their scope of work. This provides the additional correc-tive action required by Referenca 6.
The procedure will be changed by October 30, 1982.
3 Serial 19052 Consumers Power Company e;
By I
/
e __
Sworn and subscribed
.*.o before me on this 30th ay of September, 1982.
' 17h t/
so Notary Public, Bay CountffMich My Commission Expires 3/Y!85 CC RWarnick, NRC Region III WDShafer, NRC Region III RNGardner, NRC Region III RJCook, NRC Resident Inspector, Midland Site RBLandsman, NRC Region III BLBurgess, NRC Region III
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4 Serial 19052 BCC RCBauman, P-14-314B WRBird, P-14-418A JEBrunner, M-1079 MLCurland, Midland LHCurtis, Bechtel-AA LEDavis, Bechtel-Midland MADietrich, Bechtel-Midland FDField, Union Electric JFFirlit, JSC-236A JAFisher, Bechtel-Hidland MEGibbs, IL&B-Chicago WDGreenwell, Bechtel-AA RCHollar, Bechtel-AA Dehorn, Midland KEMarbaugh, Midland QA/NO BWMarguglio, Midland JKMeisenheimer, Midland DBMiller, Midland (3) 4 JAMooney, P-14-115A NRC Corres File, P-24-517 SJPoulos, Geotech JARutgers, Bechtel-AA JRSchaub, P-14-309 PSteptoe, IL&B-Chicago DMTurnbull, Midland RAWells P-14-113A i
FCWilliams, IL&B-Washington f
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