ML20082H648
| ML20082H648 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/21/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, 26608, 83-09-#1, 83-9-#1, MCAR-73, NUDOCS 8312010235 | |
| Download: ML20082H648 (9) | |
Text
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- a Consumers Power Company 0""L*** _,,.j,g.g.,-.,
and Construction l
General Offices: 1945 West Parnell Road, Jackson, MI 49201 * (517) 788-0453 November 21, 1983 83-09 #1 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission 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:
26608.
This letter is an interim 10CFR50.55(e) report on a deficiency in the system for processing field changes involving project design documents. This condition was reported by telecon to the NRC on October 22, 1983.
The attachments to this letter provide a description of the deficiency and the corrective actions being taken to resolve this problem.
q Another report, either interim or final, will be sent on or before January 6, 1984.
L
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JWC/AHB/rlm Attachments:
(1) Management Corrective Action Report MCAR-1, Report No 73 dated October 27, 1983 (2) MCAR-73 Interim Report 1, dated November 11, 1983 CC:.Docuuient Control Desk, NRC Washington, DC RJCook, NRC Resident Inspector Midland Nuclear Plant DSHood, US NRC Office of NRR gg
,83 INPO Records Center OC1183-0035A-MP01 8312010235 831121 PDR ADOCK 05000329 S
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OM/0L SERVICE LIST Mr Frank J Kelley Atomic Safety & Licensing Attorney General of the Appeal Board State 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 September 6, 1983 OC1183-0035A-MP01
QUALITY ASSURANCE PROGRAM i
l 3 2 9 WNAGEMENT CORRECTIVE ACTION REPORT MCAR 1 REPORT NO. 73
. g.,.
JOB NO. 7220 Q NO.
DATE 10/27/83 l* DESCRIPTION (including references):
As a result of Midland Project Quality Assurance Department (>PQAD) Audit MSA-83-32, the following deficiencies were cited regarding the review and control of Midland project Q-listed drawings and specifications which are requested or nottfled to need change by fleic initiated Field Change Requests (FCRs) and/or Field Change Notices (FCNs):
Continued on page 2
- RECOMMENDED ACTION (Optiona!)
1)
Perform In-depth review to determine extent of the problem.
2)
If, as a result of item I) above, hardware deficiencies are noted, document on NCR and determine impact on the safety of operations at Midland.
3)
Take appropriate corrective actions based on detailed findings from item 1) above. Review and revise procedures as necessary.
4)
Reinstruct appropriate personnel on proper procedures for review, control and distribution of project change documents.
5)
Deterraine root cause of problem and take eppropriate action to prevent recurrence.
6)
Issue a report, either interim or final, by November 4, 1983.
REFERRED TO DE ENGINEERING G CONSTRUCTION O OA MANAGEMENT O
O PROCUREMENT ISSUED BY k n/>
to,-
10-27 93 NOTE: This deficiency was reported to the NRC Project O4 Engineer Date on 10/22/83 by CPCo.
A il REPORTABLE DEFICIENCY NO 0 NO E)YES
/d 81-Project Manager [
/ Dat'e 111 CAUSE CORRECTIVE ACTION TAKEN AUTHORIZED BY Date STANDARD DISTRIBUTON ADDITONAL DISTRIBUTON
- AS APPROPRIATE ENGINEERING MANAGER FORMAL REPORT TO CLIENT DMSION OA MANAGER Date MANAGER OF OA BPC PROJECT ENGINEER (if SectionII Applies)
GPD OA MANAGER OE SUPERVISOR LAPD OA MANAGER CONSTRUCTON MANAGER SFPD OA MANAGER PROJ SUPT /PROJ CONSTR MANAGER PRCUECT MANAGER CHIEF CONSTR OC ENGINEER CLIENT CORRECTIVE ACTION IMPLEMENTED DMSON PROCURENT MGR PROJ PROCUREMENT MGR PROCUREMENT SUPPLIER QUAUTY MGR AND DIV SUPPUER QUAUTY MGR VERIFIED BY Project G A Engineer Date
- Describe in space provided and attach reference document.
AAPD-0161
MANAGEENT CORRECTIVE ACTION REPORT Report No. 73 l}{g Page 2 Description (continued) l)
There is a possibility that pertinent FCRs and FCNs may not have been attached to the proper base design documents in the field. This condition could result from the following Inconsistencies:
a.
Both Field Engineering and Project Engineering (in sepe ate actions) document on the face of the FCR or FCN other drawings or specifications which are affected by the change. In some cases the lists are difforent.
b.
Field Document Control Conter and Design Of fice Document Control have maintained separate and Inconsistent registers for drawing attachments (FCRs and FCNs) based on i
their procedures for handling FCRs/FCNs.
2)
There Is a possibility that appropriate quality organization reviews may not have been performed on FCR/FCNs requesting or notifying changes to Q-listed specifications. This condition could result from the following inconsistencies:
a.
FCRs or FCNs written against Q specifications must be reviewed by Quality Assurance. In some cases of FCR/FCNs written against non-Q documents, Field Engineering and/or Project Engineering may have listed Q specifications on the f ace of the FCR/FCN as being affected. These FCR/FCNs may not have been reviewed by WQAD for their impact on the added Q specification (s).
i j
b.
Additional Q specifications may also have been added to the face of FCR/FCNs written against Q documents. In these cases, WQAD review may also not have been performed on l
the added Q specification.
As a result of the above conditions, Stop work Orders FSW-33 through 41 have been issued.
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I34579 Bechtel Associates Professional Corporation
SUBJECT:
MCAR 73 13458i INTERIM REPORT 1 DATE:
November 11, 1983 PROJECT:
Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220 Introduction This report addresses problems with inconsistent processing and review of Field Change Requests (FCRs)/ Field Change Notices (FCNs) against project design documents.
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 reviewed by the appropriate quality organization.
(Ref: CPCo Audit MSA-83-32)
Bechtel Field Procedures FPD-1.000, FPD-2.000, and FID-2.100, Project Engineering Procedure 4.62.1 and Administrative Department Procedure and Instruction ADP-2.12 and ADI 2.12.10 describe the process of initiating, reviewing, approving and processing FCRs and FCNs. Although the individual I
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:
i a)
FCRs and FCNs may not have been attached to the proper base design documents.
(Ref: CPCo Audit MSA-83-32) f 1
b)
Quality organization review of FCRs/FCNs affecting Q-related design f
documents may not have been performed where required.
(Ref: CPCo 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 mcde by field engineering in the "other drawings or specifications affected" block on the FCR and FCN forms.
(The FCR/FCN form is included as Attachment 1.)
j 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.
c 134579 Bechtel Associates Professional Corporation MCAR 73 13458I Interim Report 1 Page 2 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 Center (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 As described in the corrective action section of this report, all FCRs with at least 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 reviews will include an evaluation as to the possibility of incorrect hardware installation. To date, only one case has been identified where an NCR may be required.
While there was a lack of integration 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 10/22/83. Completion of the review of FCRs and FCNs will allow conclusions to be drawn as to whether there are indeed any safety implications.
Probable Cause l
l The probable cause was the lack of integration between field procedures / instructions FFD-1.000, FPD-2.000, and FID-2.100, Project l
Engineering Procedure PEP 4.62.1 and Administrative Department Procedure and Instruction ADI 2.12.10 and ADP-2.12 which govern the initiation, review, approval and processing cf FCRs and FCNs.
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l34579 Bechtel Associates Professional Corporation 13458i 1
Corrective Actions 1.
A program has been established and documented in FCR/FCN Review and Resolution Program (FID-2.400) to: a) identify the proper base design documents which the FCR and FCNs are to be posted against, b) ensure required quality organization review and approvals were obtained, and c) to evaluate whether or not any lack of the above resulted in hardware deficiencies. The program also provides for overview and verification by the Midland Project Quality Assurance Department of these actions.
In addition to this program, the Field Procedures, Project Engineering Procedures and Administrative Department Instructions and Procedures associated with FCRs and FCNs will be reviewed and revised as necessary to ensure integration. Bechtel personnel will receive formal instructions in the use of these revised procedures.
2.
Review Bechtel department procedures (e.g., Administration Services, Project Engineering, Construction) and Consumer Power Company procedures for consistency at points of interface and to identify and correct any potential problems similar to the FCR/FCN interface problem. A system to maintain this integration shall also be developed.
Reportability The conditions described in this report were reported to the NRC by telecon under the rules of 10CFR50.55(e) on 10/22/83.
Submitted by:
f Boos Msistant Pro ect Manager i
?
l Approved by:
Cr:L4L_
E.B. Possr ' \\)
Project Engineer l
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d4 r-Concurrence by:
.A. Dietrich u
Project Quality Assurance i
Engineer oc T
Concurrence by:
E.H. Smith Engineering Manager i
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J AttcChmsn* 1 134579 134581 i
PAGE1 OF FIEl.D CHANGE REQUEST JOB NO.
DR AWING OR SPECIFICATsON SHEET REV OITEM TITLE OF DWG OR SPEC NO, NO.
SYM.
YE5 NO 7220 O
O cms.l. G E PREPARED BY AND DATE CHANGE PPE SIG" ATURE AND DATs, DISPOssT&DN OF PROPOSEO APPROVED FCR REQUIRED FCR I YEs O NO O l l REASON FOR CHANGE l
i EXISTING CONDITION l
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DESCRIPTION OF CHANGE h
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INTERIM APPROVAL BY SIGN AAO CONTACT: DATE RESIDENT ENGINEER:
DATE NAME OTHER CIVIL ELEC1 AI AL IN51 AUME NTATION MECHANICAL P8 PING WEL DING OR DWGs OR Or,4ERS SPECS l
AFFECTED Of0CED SY FIELD LDE O*Cm10 SY PE CR SUPV PROJECT ENGINEER SIGNATURE AND DATE FCR APPROVED YES NO RE MAnsts l
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Attachm nt 1 134579 1345RI PAGE1OP pcp FIELD CHANGE NOTICE JOS NO.
D AWINGCA SPECJPICAT3ON EET RE Q TEM TITLE OF DWG CR SPEC g
O O CHANJI" PREPARED SY AND Daft CHANGE PPE SIGNAT4JRE AND DATE.
PROPCSED
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