ML20071M389
| ML20071M389 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/13/1982 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20071M382 | List: |
| References | |
| 17573, NUDOCS 8209270108 | |
| Download: ML20071M389 (5) | |
Text
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Coilsumers Power Jasnes W Cook Vice President - Projects, Engsneering and Construction oeneral offices: 1945 West Parnell Road, Jackson, MI 49201 e (517) 7840453 August 13, 1982 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND PROJECT -
INSPECTION REPORT NO 50-329/82-03 (DETP) & 50-330/82-03 (DETP)
FILE:
0.4.2 SERIAL
17573
References:
(1) NRC Letter, C E Norelius to J W Cook, dated July 2, 1982, transmitting Inspection Report 82-03 (2) NRC Letter, C E Norelius to J W Cook, dated July 15, 1982, transmitting corrected copy of the appendix to Inspection Report 82-03 This letter, including Attachment 1, provides our response to References 1 and 2,.which transmitted the subject Inspection Report and which requested our written response on the item of noncompliance therein.
Consu -rs Power Company hL Ofnh' By VJamesAMooneyforJamesWCook Sworn and subscribed to'before me on this 13th day of August, 1982.
$-hnX g_g Notary Public, Jackson County, MjAhigan My commission expires September 8, 1984 JWC/BWM/WRB/jac 8209270108 820922
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2 CC:
RWarnick, NRC Region III (w/att)
WShafer, NRC Region III (w/att)
RCardner, NRC Region III (w/att)
RCook, NRC Resident Inspector, Midland Site (w/att)
RBlandsman, NRC Region III (w/att)
BBurgess, NRC Region III (w/att) : Consumers Power Company's response to US Nuclear Regulatory Commission, Region III Inspection Report 50-329/82-03 (DETP);
50-330/82-03 (DETP) Docket Nos 50-329 and 50-330 i
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1 CONSUMERS POWER COMPANY'S RESPONSE TO US NUCLEAR REGULATORY COMMISSION, REGION III INSPECTION REPORT NO 50-329/82-03 (DETP); 50-330/82-03 (DETP)
DOCKET NOS 50-329 AND 50-330 Appendix A (Notice.of Violation) to Inspection Report No 50-329/82-03 and 50-330/82-03 provides an item of noncompliance to 10CFR50, Appendix B, Criterion V, with three examples, Our response to each example is given in 1
turn, as follows:
1.
NRC Statement Example "a" states:
"CPCo's QA procedure No 6-1 requires that the number of attachment changes to a drawing be limited to four.
Thereafter, any change results in its incorporation into the drawing. Bechtel Drawing C-1315 has nine outstanding FCR's and Drawing C-1316 has five outstanding FCR's."
i This item is labeled 329/82-03-01A and 330/82-03-01A Consumers Power Company Response The CPCo QA procedure in question,does not apply to Bechtel Drawings C-1315 and C-1316. As is stated in the scope of this procedure, it ".
applies to documents prepared during the design, construction, preopera-tional and hot functional phases of the Midland Project and applies only i
I to thos. CPCo documents (or documents prepared for CPCo use) which are or which will become quality records." The parenthetical statement "for CPCo use" was intended to mean "for CPCo issuance or release and tae QA proce-
[
dure will be revised to more accurately convey this intent.
In the absence of such a revision, it is wholly understandable that anyone would come to the same conclusion as did the NRC Inspector.
Bechtel Procedures MED 4.62-01 and EDP-4.62 govern the method of control-ling Field Change Requests (FCRs) and Field Change Notices (FCNs) design documents issued by Bechtel. The Bechtel procedures currently require l
that all outstanding approved changes be incorporated into the field of the drawing:
a.
Within 180 days after an FCR or FCN or DCN has been approved; b.
When 10 approved FCN's requiring document change have been issued;
[
c.
When 5 approved DCNs have been issued; and l
l d.
Any time any change is made in the field of the drawing.
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2 By August 30, 1982, an additional control will be incorporated into the Bechtel procedures to require that incorporation be accomplished when a combined total of 15 FCNs and FCRs have been approved by Project Engineering. These limits exclude FCRs/FCNs not requiring document revision, as defined-in MED 4.62-0/EDP 4.62 (eg, one-time deviations and computer generated data lists).
The above controls do not preclude the possibility'that at any point in time there will be more than 15 attachment changes to a drawing, considet-ing those receiving interim approval in the field but not yet approved by
' Ann Arbor Project Engineering. Nevertheless, the control assures that -
unreasonable and unmanageable numbers of attachment changes cannot exist for any long period.
2.
NRC Statement Example "b" states:
" Specification C-211 does not have the degree of controls necessary for the protection to be used during excavation. This resulted in the BWST
- 3 valve pit being undermined during the removal of an electrical duct bank."
4 This item is labeled 329/82-03-02B and 330/82-03-01B.
I Consumers Power Company Response.
Bechtel Power Corporation Field Instruction FIC-5.100 (Q), Revision 0,
" Excavation Permit System," was-implemented Mcy 24, 1982 to provide the-controls necessary to prevent disturbance of foundation subgrade for structures, to maintain the integrity of compacted backfill and protect i
I existing buried installations. A copy of this instruction was made available to the NRC Inspector.
On April 14, 1982, loose, disturbed material was removed from the undermined area beneath the Southwest corner of the Unit #2 Borated Water Storage Tank Valve Pit.
Forms were placed, as required, and braced around the excavation and concrete was placed in the excavation.
Concrete vibrators were used during placement to prevent voids beneath the foundation.
The work was monitored by the onsite Geotech and the l
Field Engineer, inspected by Bechtel Quality Control, and observed by MPQAD.
3.
NRC Statement Example "c" states:
"CPCo's QA Procedure No 3 requires that verification of-design be performed by individuals other than those who performed the original design. Mergentine's Field Procedures 52 and 55 were marked up in ink to show changes made. There was no evidence as to when or by whom the l
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3 changes were made. This resulted in inadequate assurance that the changes were reviewed and approved prior to implementation of the procedure."
This item is labeled 329/82-03-01C and 330/82-03-01C Consumers Power Company Response The exampic appears to provide two concerns - the first being that the Quality Program requires independent design verification; the second being that for the Mergentine field procedures, the change control method did not provide a clear indication that the changes were reviewed and approved prior to the implementation of the procedures.
CPCo QA Policy 3 and QA Procedure No 3-3, " applies only when a CPCo organization has lead design responsibility," which is not the case for this example.
Independent design verification is covered by the Bechtel Field Engineering Procedure FID-1.100, Mergentine Procedure C195-29 and Spencer, White & Prentice (SW&P) Procedure C194-2.
Since April 30 1982, it has been the practice to issue Mergentine and SW&P procedures at a Level I status. This assures starting with a clean copy. As of July 9, 1982, the practice is to apply the Bechtel Comment Stamp adjacent to any document review comments annotated or any document which is ap-proved at less than a Level status. The use of the Bechtel Comment Stamp became mandatory with Revision 11 to Manager of Engineering Directive (MED) 5.16-0.
Suppliers are prohibited from making revisions by annota-tion on their Bechtel approved submittals. Suptlier originated changes must be submitted to Bechtel for review and approval prior to the release for implementation. There are some existing procedures especially cover-ing instrumentation installation, which were issued prior to the time that these new practices were implemented. However, the programmatic require-l ments in existence at that time governing review and approval were fol-l lowed with one possible exception. The requirements for the mandatory j
use of the Bechtel Comment Stamp was different in FID-1.100 and MED 5.16-0 until Revision 11 of the MED was issued.
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