ML20082C785
| ML20082C785 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/04/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20082C768 | List: |
| References | |
| CSC-6962, NUDOCS 8311220202 | |
| Download: ML20082C785 (5) | |
Text
. -. _ _.
=.
Consumers Power James W. Cook CDmpany nn ~sisn uints. tninnri, and Construction General o f fices: 1945 West Parnall Road, Jack son, MI 49201 = (517) 788 0453 November 4, 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 50-329/83-12(OSC) AND 50-330/83-13(OSC)
File:
0.4.2 UFI:
70*01 Serial:
CSC-6962 0485.16 42*05*22*04
REFERENCE:
(1) R F Warnick letter to J W Cook, dated September 29,1983 Inspection Report No 50-329/83-12(OSC) and 50-330/83-13 (OSC)
This letter, including Attachment 1, provides our response to Reference 1, which transmitted the subject Inspection Report and requested our written response to the item of noncompliance therein.
b JWC/ BHP /JTW/dmh Attachment cc: RFWarnick, NRC Region III JJHarrison, NRC Region III RNGardner, NRC Region III RBLandsman, NRC Region III RJCook, NRC Senior Resident Inspector, Midland Site RLBurgess, NRC Resident Inspector, Midland Site l
g[
8311220202 831117 PDR ADOCK 05000329 G
PDR NOV0783-0001A-CN02
O i
OL/0M SERVICE LIST Mr Charles Bechhoefer, Esq Hr Frank J Kelley, Esq l
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 i
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 i
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 1
Atomic Safety & Licensing Board Panel Ms Mary Sinclair U S Nuclear Regulatory Commission 5711 Summerset Street Washington, DC 20555 Midland, MI 48640 1
3 Atomic Safety & Licensing Appeal Board Mr Steve Gadler U S Nuclear Regulatory Commission 2120 Carter Avenue i
Washington, DC 20555 St Paul, MN 55108 Mr William D Paton, Esq Mr Lee L Bishop 4
Counsel for NRC Staff Harmon & Weiss i
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 i
Freeland, MI 48623 US Nuclear Regulatory Washington, DC 20555 Dr Jerry Harbour Lynn Bernabei US Nuclear Regulatory Commission.
Governmental Acrountability Atomic Safety & Licensing Board Panel Project (GAP) l Washington, DC 20555 1901 Q Street NW Washington, DC 20009 NOV0783-0001A-CN02 I
I
o 1,
4 CONSUMERS POWER COMPANY Midland Units I and 2 Docket No 50-329/50-330 Letter Serial CSC-6962 Dated November 4 1983 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 Commission's Rules and Regulations thereunder, Consumers Power Company submits the response to R F Warnick letter to J W Cook dated September 29, 1983.
)
CONSUMERS POWER COMPANY By
[WCook,VicePresident Projects, Engineering and Construction Swornandsubscribedbeforemethisf day of b 2
, 1983.
i
/ /M K/ L 2
W
~ Notary Public c/g PATRICIA A. PUItLH Notary Public, Bay County, A ysooa.
, /f My Commission Expirco
,M/d 4
.NOV0783-0001A-CN02
. -.. ~. =-
Attachment I to Serial CSC-6962 CONSUMERS POWER COMPANY'S RESPONSE TO US NUCLEAR REGULATORY COMMISSION, REGION III l
INSPECTION REPORT NO. 50-329/83-05 (OSC) & 50-330/83-05 (OSC)
Appendix (Notice of Violation) to Inspection Reports No. 50-329/83-12 (OSC) l and 50-330/83-13 (OSC) provides an item of noncompliance to 10 CFR 50, Appendix B.
The NRC statement and our response are given below:
{
NRC STATEMENT l
10 CFR 50, Appendix B, Criterion V states, in part, " Activities af fecting quality shall be prescribed by documented instructions, procedures, or i
drawings of a type appropriate to the circumstances and shall be accomplished
'n accordance with these instructions."
Consumers Power Company Quality Assurance Program Policy No. 5, states in 1
i part, " Instructions for controlling and performing activities affective j
quality of equipment or activities such as... construction installation...are documented in... procedures, specifications...and other forms of documents."
Q t
Contrary to the above, the licensee failed to follow procedures as indicated in the following four instances:
4 1.
B&WCC removed approximately l\\ lineal inches of material from two struc-tural elements of Hanger 1-601-2-16 without initiating a deviation to the Field Construction Procedure in effect for the hanger installation. The result of this action was to exceed the allowable tolerance for these members as prescribed in Specification 7220-M-366(Q), Paragraph 5.4.1.b.
2.
B&WCC relocated Hanger 2-611-1-35 to a new position in accordance with an authorized change order. NDE inspection was not performed as required by deviation 01341 to Field Construction Procedure 74B.
3.
Field weld #2, Hanger 2CCA-1-2-H2, was undersize for the entire length of the weld and ground to an unacceptable contour.
4.
Field welds #1 and #2, Hanger 2CCA-1-2-H3, were welded in the wrong location.
This is a Severity Level IV violation (Supplement II).
CONSUMERS POWER COMPANY RESPONSE In accordance with this Notice of Violation, explanation of corrective action is as follows; 1.
Corrective Action Taken and the Results Achieved Each of the aforementioned discrepant hangers has had corrective action i
taken as follows; RP1083-0J05A-CN01
Attachment I to Serial CSC-6962 Hanger 1-601-2-16 B&W Construction Company (BWCC) has written NCR #4265 documenting this discrepancy. The disposition of this NCR is to remove the hanger and replace it.
Hanger 2-611-1-35 BWCC has written NCR #4261 documenting this discrepancy. The disposition of this NCR requires that the proper NDE be performed.
Hanger 2CCA-1-2-H2 BWCC has written NCR #4298 documenting this discrepancy. The disposition of this NCR requires that the weld be ground and rewelded to the design configuration.
Hanger 2CCA-1-2-H3 BWCC has written NCR #4299 documenting this discrepancy. The disposition of this NCR requires that the hanger parts be disassembled and restocked for potential reuse as this hanger has now been voided.
2.
Corrective Action to be Taken to Avoid Further Noncompliance Subsequent to this finding of discrepant hangers by the NRC inspectors, an internal (Bechtel) reinspection of other BWCC hangers has revealed additional hanger discrepancies. The Bechtel reinspection has been fol-lowed by CPCo (MPQAD) and BWCC QC reinspections. Both the MPQAD and BWCC reinspections reached the same conclusion as the Bechtel reinspection, i.e., that the findings had generic implications. BWCC QC has, as a result of this information, stopped all BWCC work on hangers.
As a result of this work stoppage, a comprehensive review and upgrading of the BWCC Training Program has been performed.
Procedures for fab-rication and inspection of hangers have also been reviewed for proper requirements and attributes.
This work stoppage will continue until CPCo is satisfied that BWCC has properly retrained its people for compliance to procedures for fabrication and inspection of hangers. Additionally, a 100% reinspection of all BWCC completed hangers will occur.
3.
Full Compliance will be Achieved as Follows Full compliance of the intent of this Notice of Violation will be imp-lemented when BWCC has demonstrated the previously mentioned training and is released to go back to work on hangers which will permit closure of the NPR's.
4 f
RP1083-0005A-CN01
,