ML20076C354

Responds to NRC Re Violations Noted in IE Insp Repts 50-329/83-07 & 50-330/83-07.Corrective Actions:Kelly Bldg Upgraded by B&W Const to Storage Facility within B&W Const Guidelines

ML20076C354
Person / Time
Site:	Midland
Issue date:	08/02/1983
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20076C335	List: ML20076C354
References
CSC-6806, NUDOCS 8308220331
Download: ML20076C354 (6)

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Vice President - Projects, Engineering and Constrwetion oeneral offices: 1945 We,t Parnell Road, Jack.on, MI 49201 *(517) 788 0453 August 2, 1983 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER INSPECTION REPORT NO 50-329/83-07(OSC) AND 50-330/83-07(OSC)

File:

0.4.2 UFI:

70*01 Serial: CSC-6806 0485.16 42*05*22*04

REFERENCE:

(1) R F Warnick letter to J W Cook, dated July 1,1983 Inspection Report No 50-329/83-07(OSC) and 50-330/83-07 (OSC)

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.

Based on a telecon with RFWarnick of Region III on July 29, CPCo was given an extension on the response due date.

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JWC/BilP/dmh Attachment cc: RFWarnick, NRC Region III JJHarrison, NRC Region III RNGardnec, NRC Region III RBLandsman, NRC Region III RJCook, NRC Senior Resident Inspector, Midland Site RLBurgess, NRC Resident Inspector, Midland Site 8308220331 830817 f

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CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329/50-330

' Letter Serial CSC-6806 Dated August 2,1983 F

At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commis-I sion's Rules and Regulations thereunder, Consumers Power Company submits the response to R F Warnick letter to.J.W Cook ' dated July 1,1983.

CONSUMERS POWER COMPANY A A By-EsM 4

W Cook, Vice 1% silent Pro ts, Engineering and Construction i

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Sworn and subscribed before me this M day of m,4, 1983.

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9 OL/OM SERVICE LIST Mr Charles Rechhoefer, Esq Mr Frank J Kelley, Esq Administrative Judge Attorney General of the Atomic Safety & Licensing Board Panel State of Michigan US Nuclear Regulatory Commission Mr Stewart H Freeman, Esq Washington, DC 20555 Assistant Attorney General Environmental Protection Div 720 Law Building Lansing, MI 48913 Dr Frederick P Cowan Mr Myron M Cherry, Esq Administrative Judge Cherry & Flynn 6152 N Verde Trail 3 First National Plaza Apt B-125 Suite 3700 Boca Raton, FL 33433 Chicago, IL 60602 Mr Michael Miller, Esq Mr Wendell H Marshall Isham, Lincoln & Beale RFD 10 3 First National Plaza Midland, MI 48640 Suite 5200 Chicago, IL 60602 Mr D F Judd, Sr Project Manager Mr John Demeester The Babcock & Wilcox Company Dow Chemical Building P O Box 1260 Michigan Division Lynchburg, Va 24505 Midland, MI 48640 Atomic Safety & Licensing Board Panel Ms Mary Sinclair U S Nuclear Regulatory Commission 5711 Summerset Street Washington, DC 20555 Midland, MI 48640 Atomic Safety & Licensing Appeal Board Mr Steve Gadler U S Nuclear Regulatory Commission 2120 Carter Avenue Washington, DC 20555 St Paul, MN 55108 Mr William D Paton, Esq Mr Lee L Bishop Counsel for NRC Staff Harmon & Weiss US Nuclear Regulatory Commission 1725 I Street, NW #506 Washington, DC 20555 Washington, DC 20006 Ms Barbara Stamiris Mr C R Stephens 5795 North River Road Docketing and Service Station Route 3 Office of the Secretary Freeland, MI 48623 US Nuclear Regulatory Washington, DC 20555 Dr Jerry Harbour Lynn Bernabei US Nuclear Regulatory Commission Governmental Accountability Atomic Safety & Licensing Board Panel Proj ect (GAP)

Washington, DC 20555 1901 Q Street NW Washington, DC 20009 NOV0783-0001-CN02A

1 Serial: CSC-6806 CONSUMERS POWER. COMPANY'S RESPONSE TO US NUCLEAR REGULATORY COMMISSION, REGION III INSPECTION REPORT NO 50-329/83-07(OSC) & 50-330/83-07(OSC)

Appendix (Notice of Violation) to Inspection Report No. 50-329/83-07(OSC) and 50-330/83-07 (OSC) provides two items of noncompliance to 10 CFR 50, Appendix B.

The NRC statements and our responses are given below:

NRC STATEMENT "10 CFR 50 Appendix B, Criterion XVI states, in part, " Measures shall be established to assure that conditions adverse to qualit/ such as...deficien-cies, deviations...are promptly identified and corrected.

In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition..."

Consumers Power Company Quality Assurance Program Policy (QAPP) No. 16,

" Corrective Action " Paragraph 3.1, states, in part, " Corrective action is initiated to correct conditions adverse to the quality of items and activities... Conditions which require additional action to prevent recur-rence are a matter of judgment, but the following conditions are always evalu-ated:... Unsatisfactory conditions identified by the NRC."

B&WCC Receiving Inspection Procedure 9-QPP-108 states, in part, " Items receipt inspected and found acceptable shall be identified with a " Release for Con-struction" tag as described in B&W Construction Company Quality Control Pro-cedure 9-QPP-115. The number of the " Release for Construction" tag shall be recorded on the Receiving Inspection Report."

Contrary to the above, pipe hangers and hanger components which were deter-mined to be acceptable for construction, were found in the " Kelly Building" without release for construction tags attached. B&WCC records indicate that hangers and hanger components had been stored in this are for periods of up to one year. The licensee had been notified of an analogous situation involv-ing the receiving inspection, tagging and storage of valves without adherence to established procedures (Ref. Report No. 50-329/83-01 (OSC); 50-330/83-01 (OSC). The licensee responded to the Notice of Violation in a letter dated March 29, 1983, stating that corrective action had been taken to correct the situation cited.

This is a Severity Level IV Violation (Supplement II)."

CONSUMERS POWER COMPANY RESPONSE In accordance with this Notice of Violation, an explanation of corrective action is as follows:

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1) Corrective Action Taken and The Results Achieved Since the NRC inspection, the " Kelly Building" has been upgraded by B&W Construction (BWCC) to a storage f acility within the guide-lines of BWCC. This upgrade has consisted of replacing the gravel floor with a concrete floor and making the building weather tight.

The building is considered a storage area and all applicable pro-cedures, including tagging, have been invoked.

2) Corrective Action Taken to Avoid Further Noncompliance A review has been made of all areas within the BWCC organization which are either storage areas or have the potential for being de-fined as a storage area. Appropriate actions have been taken to in-sure that said areas are in compliance with the BWCC program.

3) The Date When Full Compliance will be Achieved Full compliance has been achieved as of 7/15/83.

NRC STATEMENT "10 CFR 50 Appendix B, Criterion XV states, in part, " Measures shall be es-tablished to control materials, parts, er components which do not conform to requirements in order to prevent their inadvertent use or installation. The measures shall include, as appropriate, procedures for... segregation...and notification to affected organizatoins. Nonconforming items shall be review-ed and accepted, rejected or reworked in accordance with documented proced-ures."

Consumers Power Company OAPP No. 15, Nonconforming Items, Paragraph 1.0,-

states, in part, " Procedural controls are established for identifying, docu-menting, segregating, reviewing, reporting and disposing of nonconforming Q-listed materials, parts, components or services..."

B&WCC Quality Control Procedure 9-QPP-111, Paragraph 4.2, states, in part, "The Field Quality Control Supervisor shall be responsible for placing a

' " Reject" tag on the nonconforming item and segregating the nonconforming item when practical by placement in a controlled area."

Contrary to the above, hangers and hanger components for Q-listed Hangers P2A-Sill-2-H4, P24-SB302-Il21 and 2CCA-33-1-Il2 were found in the " material awaiting installation" bins with reject tags numbered 1144, 1110, and 1015, respectively attached. Sufficient area was available within the storage area to provide segregation of this material.

This is a Severity Level V Violation (Supplement II)."

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CONSUMERS POWER COMPANY RESPONSE

1) Corrective Action Taken and the Results Achieved The rejected hanger components have been removed from bins marked

" Material Awaiting Installation." The cognizant people have been instructed on following procedural requirements.

2) Corrective Action Taken To To Avoid Further Compliance Corrective action has been taken by instructing the responsible per-sons about following established procedures. Additionally, areas have been established within'the " Kelly Building" to' allow segrega-tion of hanger components.

3) The Date When Full Compliance Will Be Achieved Full compliance has been achieved as of 7/15/83.

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