ML20074A577
| ML20074A577 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/29/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20074A563 | List: |
| References | |
| CSC-6628, NUDOCS 8305130182 | |
| Download: ML20074A577 (6) | |
Text
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O Consumers power James W Cook Vice President - Projects, Engineering and Construction 1945 West Ferna t Road, Jackson, MI 49201 * (517) 7884453 General offices:
r March 29, 1983 PRINCIPAL STAFF RA lho Hnv
@/31_QCS Aik 3 n&P tdo O
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~Sto Mr J G Keppler, Regional Administrator
@l US Nuclear Regulatory Commission j['
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Region III g
799 Roosevelt Road at qg, g '
Glen Ellyn, IL 601'.7 MIDLAND NUCLEAR COGENERATION PLAh7 INSPECTION REPORT NO 50-329/83-01(OSC) AND 50-330/83-01(OSC)
FILE:
0.4.2, 0485.16 UFI:
70*01, 42*05*22*04 SERIAL:
CSC-6628
Reference:
(1) R F Warnick letter to J W Cook, dated March 4, 1983 Iriapection Report No 50-329/83-01 and 50-330/83-01 This letter, including Attachment 1, provides our response to Reference 1, which transmitted the subject Inspection Report and which requested our written response to the item of noncompliance therein.
Consumers Power Company By James W Cook Sworn and subscribed to before me on this % day of d,)f,, 1983.
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duV Beverft A. S nT1 Notary phblic, Jaclpfon County, Mich Mycommissionexpiresh.,,,y,/4/'///[
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if JWC/ BHP /lr CC: RFWarnick, 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 APR 8 383 OC0383-0037A-MP01 8305130102 830511 PDR ADOCK 05000329 G
PDR j
y
2 Serial CSC-6628 BCC RCBauman, P14-314B WRBird, P14-418A FWBuckman, P14-113A JEBrunner, M-1079 NRC Corres File, P24-517 MLCurland, Midland LEDavis, Bechtel-Midland MADietrich, Bechtel-Midland GFEwert, Midland FDField, Union Electric WJFriedrich, Midland MEGibbs, IL&B WDGreenwell, Bechtel Ann Arbor Dehorn, Midland EMHughes, Bechtel AA KEMarbaugh, Midland QA/NO BWMarguglio/DJones, JSC-220A/206B JKMeisenheimer, Midland DBMiller, Midland (3)
JAMooney, P14-115A JARutgers, Bechtel Ann Arbor PSteptoe, IL&B DATaggart, Midland RAWells, Midland FCWilliams, IL&B Washington REWhitaker, Midland i
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OC0383-0037A-MP01
Serial CSC-6628 CONSUMERS POWER COMPANY'S RESPONSE TO US NUCLEAR REGULATORY COMMISSION, REGION III INSPECTION REPORT NO 50-329/83-01(OSC) & 50-330/83-01(OSC)
Appendix (Notice of Violation) to Inspection Report No 50-329/83-01(OSC) and 50-330/83-01(OSC) provides an item of noncompliance to 10 CFR 50, Appendix B.
The NRC statement and our response are given below.
NRC STATEMENT "10 CFR 50, Appendix B, Criterion V states, in part, ' Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions.'
Consumers Power Quality Assurance Program Manual for nuclear power plants, CPC-1-A, Policy Number 5, Paragraph 3.4-D states, ' Prior to performing work or inspection on a safety-related item (structures, systems and components), suppliers are required to develop written procedures for accomplishing quality-related work activities and performing required inspection and tests. These procedures reference applicable drawings, specifications, codes and standards. The Midland Project Quality Assurance Department reviews field inspection plans or inspection procedures prior to implementation.'
B&W's withdrawal and storage of piping materials FCP 397, states, in part, ' Receive and inspect materials withdrawn in Seg 010 per 9-QPP-108.
Verify material has sufficient identification per 9-MR-100.
Material is to be tagged in accordance with 9-QPP-115. Place material into bin or rack as applicable and identify location of material onto Attachment A.'
Contrary to the above, the licensee issued an untagged valve, Serial Number 77855, to a welding fabrication area on December 1, 1982. As a result, there was no documentation as required by FCP 397.
This is a Severity Level V violation (Supplement II)."
CONSUMERS POWER COMPANY RESPONSE In accordance with this Notice of Violation, an explanation of corrective action is as follows:
- 1) Corrective action taken and the results achieved.
Corrective action was taken via a CPCo letter to Bechtel dated January 14, 1983. This letter, CPCo Serial No CSC-6497, is attached.
This letter was shared with NRC inspector, Mr A Sather, prior to its issuance. Since this letter was issued, the indicated actions have been implemented and no further instances have occurred.
Subsequently, the subject valve, Serial No 77855, was placed back in Bechtel stock.
Bechtel had the quality verification document for this valve which assures the quality of the valve.
OC0383-0037A-MP01 j
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Attachmtnt 1 Page 2 Serial CSC-6628
- 2) Corrective action to be taken to avoid further noncompliance.
In addition to the actions required by the above referenced letter, B&W Construction Company is also revising QC Procedure 9-QPP-108, Receiving and Inspection, for necessary changes.
- 3) The date when full compliance will be achieved.
With the exception of revising QC Procedure 9-QPP-108, which is anticipated to be completed by April 15, 1983, all other actions were completed by March 3, 1983.
Consumers Power would also like to provide a clarification of the wording of this Notice of Violation. Interpreted literally, the Notice states the following:
- 1) That a valve should be tagged prior to receipt inspection.
- 2) Documentation for the valve as needed in the receipt inspection process (FCP 397) was not available because the needed valve was not tagged.
There is no requirement for Bechtel to issue a tagged valve to B&W.
B&W Procedure 9-QPP-108 clearly states that a valve will be tagged (accepted i
or rejected) after the receipt inspection process, which was not completed in this case.
If the valve had been receipt inspected, it would have been rejected because the documentation was in Bechtel's custody at Ann Arbor and thus was not available to be provided to B&W at the time of i
valve transfer to B&W.
JWC/ BHP /WRB/lr i
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OC0383-0037A-MP01
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Consumeni Power Company Midland Project: Po Box 1963, M6dland MI 48640 * (517) 6314 650 January 14, 1983 Mr. L. E. Davis-Bechtel Power Corporation P.O. Box 2167 Midland, MI 48640 MIDLAND PROJECT GWO 7020 CHANGES TO BWCC PROCEDURES File M1.0 UFI:
08*06*04*01 Serial: CSC-6497 Due to recent discussions with the NRC, it is necessary that some procedural changes be instituted within the BWCC receipt / inspection process.
Specific changes to make are as follows:
- 1) BWCC FCP 397 shall be changed to show a sequence between sequences 010 and+020 wherein materials drawn from Bechtel storage are taken to a BWCC QC " Hold Area."
- 2) This BWCC QC " Hold Area" is to be in close proximity to the control-
- j led BWCC storage bin.
Items should remain in the " Hold Area" until receipt inspection is completed and items placed in storage.
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- 3) Concerning the processing MWR's, the following actions shall bo in-l stituted at BWCC.
l All MWR's generated by B&WCC MUST be reviewed by B&WCC Quality l
a.
Control BEFORE submitting to Bechtel Subcontracts for review l
and signature.
b.
B&WCC Q.C. MUST obtain, review, and retain copies of material certifications for the items listed on the MWR's.
Acknowledgement j
of this action SHALL be documented by signing and dating the MWR's.
NOTE: Retaining copies of voluminous data packages may be ex-cluded once they are obtained and reviewed. This exclu-sion shall be determined by the Q.C. Inspection Super-visors. Documenting the review on the MWR is still re-quired.
After B&WCC Q.C. has documented their review on the MWR's, the MWR's c.
I may be released to production personnel.
Subcontracts may then re-view, sign, and date the MWR and material may be withdrawn from Bechtel.
1
CHANGES TO BWCC PROCEDURES Page 2 l
l This required actio hould completed by January 21, 1983.
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