ML20079E795
| ML20079E795 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/06/1984 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 26648, 83-09-2, 83-9-2, NUDOCS 8401170430 | |
| Download: ML20079E795 (9) | |
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PRINCIPAL STAFF dY A pp 7/RA x
T/HA WAS COnSum8fS vc w
Power 2y tc3v
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i General offices: 1945 West Parnall Road, Jackson, MI 49201 * (517) 788-0550 Jnnuary 6, 1984 83-09 J?
Mr J G Keppler, Regional Administrator US Nuclear Regulatory Comroission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER DOCKET NOS 50-329 AND 50-330 REVIEW AND CONTROL OF Q LISTED DRAWINGS AND SPECIFICATIONS FILE:
0.4.9.81 SERIAL:
26648 Reference 1) J W Cook letter to J G Kepplet, Serial 22608, Same Subject, dated November 21, 1983 This letter is another interin 10CFR50.55(e) report on a deficiency in the system for processing field changes involving project design documents.
The attachments to this letter provide a description of the deficiency and the corrective actions being taken to resolve this problem.
Another report, either interim or final, will be sent on or before February 10, 1984.
% d. M JWC/AHB/rlm Attachments:
(1) MCAR-73 Inte Report 2, dated December 2, 1983.
CC: Document Conttol Desk, NRC Washington, PC RJCook, NRC Resident Inspector Midland Nuclear Plant DSHood, US NRC 8401170430 840106 Office of NRR PDR ADOCK 05000329 S
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OC0184-0001A-MP01 QAN 12 g.
83-09 #2 2
OM/0L SERVICE LIST Mr Frank J Kelley Atomic Safety & Licensing Attorney General of the Appeal Board Stai of Michigan U S Nuclear Regulatory Commission Ms Carole Steinberg, Esq Washington, DC 20555 Assistant Attorney General Environmental Protection Division Mr C R Stephens (3) 720 Law Building Chief, Docketing & Services Lansing, MI 48913 U S Nuclear Regulatory Commission Office of the Secretary Washington, DC 20555 Mr Myron M Cherry, Esq Suite 3700 Ms Mary Sinclair Three First National Plaza 5711 Summerset Street Chicago, IL 60602 Midland, MI 48640 Mr Wendell H Marshall Mr William D Paton, Esq RFD 10 Counsel for the NRC Staff Midland, MI 48640 U S Nuclear Regulatory Commission Washington, DC 20555 Mr Charles Bechhoefer, Esq Atomic Safety & Licensing Atomic Safety & Licensing Board Panel Board Panel U S Nuclear Regulatory Commission U S Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr Frederick P Cowan Ms Barbara Stamiris 6152 N Verde Trail 5795 North River Road Apt B-125 Rt 3 Boca Raton, FL 33433 Freeland, MI 48623 Mr Fred C Williams Mr Jerry Harbour Isham, Lincoln & Beale Atomic Safety & Licensing 1120 Connecticut Ave, NW, Suite 325 Board Panel Washington, DC 20036 U S Nuclear Regulatory Commission Washington, DC 20555 Mr James E Brunner, Esq Mr M I Miller, Esq Consumers Power Company Isham, Lincoln & Beale 212 West Michigan Avenue Three First National Plaza Jackson, MI 49201 52nd Floor Chicago, IL 60602 Mr D F Judd Mr John Demeester, Esq Babcock & Wilcox Dow Chemical Building PO Box 1260 Michigan Division Lynchburg, VA 24505 Midland, MI 48640 Mr Steve Gadler, Esq Ms Lynne Bernebei 2120 Carter Avenue Government Accountability Project St Paul, MN 55108 1901 Q Street, NW Washington, DC 20009 OC0184-0001A-MP01
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.s Serial 266h8 83-09 #2 I36660
SUBJECT:
MCAR 73 INTERIM REPORT 2
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DATE:
December 2, 1983 FROJECT: Midland Plant Units 1 and 2 Consumers Power Company Bechtel Job 7220 Introduction This report addresses probless with inconsistent processing and review of Field Change Requests (FCRs)/ Field Change Notices (FCNs) against project design documents.
1 Description of Deficiency _
It was found that in some cases project design change documents (FCRs/FCNs) were not attached to the proper base design documents or i
CPCo Audit reviewed by the appropriate quality organization. (Ref:
MSA-83-3/)
Bechtel Field Procedures FPD-1.000, PPD-2.000, and FID-2.100, Project Engineering Procedure 4.62.1 and Administrativ6 Department Procedure and Instruction ADP-2,12 and ADI 2.12.10 describe the process of initiating, Although the reviewing, approving and processing FCRs and FCNs.
individual organizations complied with their respective procedures, the operations involved in these procedures were not fully integrated to achieve proper continuity between site and design office activities, thereby resulting in a situation where:
FCRs and FCNs may not have been attached to the proper base design a) documents. (Ref: CPCo Audit MSA-83-32)
Quality organization review of FCRs/FCNs affecting Q-related design (Ref: CPCo b) documents may not have been performed where required.
Audit MSA-83-32)
Historical Background and Summary of Investigation It has been identified that design engineering has not consistently reviewed and indicated either approval or disapproval of the entries made by field engineering in the "other drawings or specifications affected" (The FCR and FCN forms are included as l
block on the FCR and FCN forms.
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I MCAR 73 Interim Report 2 136660 Page 2 136632 Attachments 1 and 2.) Furthermore, field engineering assumed that if design engineering did not comment on the entries in the "other drawings or specifications affected" block, design engineering concurred with the entries; however, this was not always the case.
Design engineering sometimes referenced related documents in the
" remarks" block (which is reserved for design engineering use) on the FCR and FCN forms. The design office Document Control Canter (DCC) keyed only on the " remarks" block for entering other related design documents in the FCR/FCN registers. On the other hand, Field Document Control Center (FDCC) personnel keyed on documents listed in the "other drawings and specifications affected" block, rather than the " remarks" block, whether or not the " remarks" block mentioned other documents.
PEP 4.62.1 identified the requirement for quality organization review of FCRs/FCNs to Q-listed specifications. In some cases FCRs/FCNs were written against Q or non-Q documents and then other Q-listed specifications were added to the "other drawings or specifications affected" block or the " remarks" block without obtaining the appropriate quality organization review and approval for the added Q-listed documents.
Analysis of Safety Implication c.ll FCRs As described in the corrective action section of this report, with at lasst resident (design) engineering interim approval and all FCNs with at least project field engineering approval will be reviewed to determine the base design documents that they should be posted against.
These FCRs and FCNs will also be reviewed to identify those cases where the quality organization review and approval was required but not performed. This review and approval will then be obtained. The above g
j reviews will include an evaluation as to the possibility of incorrect I
t hardware installation.
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While there was a lack of integratiod between the procedures described previously, no safety concern has been identified at this time, Consumers Power Company (CPCo) has reported this item to the NRC under the rules of 10CFR50.55(e) on October 22, 1983. Completion of the review of PCRs and FCNs will allow conclusions to be drawn as to whether there
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are any safety implications.
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I36660 interim Response 2 Page 3 i
i36632 i
Probable Cause_
d
/
The probable cause was the lack of integration between field proce ur i
instructions FFD-1.000, FFD-2.000, and FID-2.100, Project Engineer ng d
Procedure (PEP) 4.62.1 and Administrative Departm iw approval, and pt cessing of FCRs and FCNs.
Corrective Action d
A program has been established and documented in FCR/FCN Rev a) identify the proper base 1.
Resolution Program (FID-2.400) to: design documents which t
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l were ensure required quality organization review and app h
b ve resulted in hardware deficiencies. overview and verificatio Assurance Department of these actions.
From this j
FCRs and FCNs have been reviewed neder this program.
review, a total of 8 NCRs have been initiated.
In addition to this program, the Field Procedures, Project i nd Engineering Procedures and Administrative Dep i d Bechtel personnel will be as necessary to ensure intescation. instructed in the use of th ith their departments' respective training procedures.
i Review Bechtel department procedures (e.g., Administrative Serv ces f
Project Engineering, Construction) for consisten 2.
d R/FCN identify and correct any potential problems similar to th interface problem.
be developed.
A plan describing steps to accomplish t'.iis review together with 6, 1984.
schedule for accomplishing the plan will be issued by January i
l
MCAR 73
,i.3.66.60 R**e'*" Report 2 136632 Reportability The conditions described in this report were reported to the NRC Ly telecon under the rules of 10CFR50.55(e) on October 22, 1983.
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Submitted by:
A.
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stant Project Maneger Approved by:
_ m 4 ^ %4 E.B. Poser Project Enginee ng Manager R
Concurrence by-
_i l.H. Siai th Engineering Manager
[Mh Concurrence by:
(seM.A.~Dietrich/
Project Quality Assurance Engineer TJS/h1 120103 0
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Att:ctament 1
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