ML20082J483
| ML20082J483 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/18/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20082J478 | List: |
| References | |
| CSC-7003, NUDOCS 8312020177 | |
| Download: ML20082J483 (7) | |
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. Consumers Power James W Cook Vice President - Projects, Engineering and Construction oeneral Offices: 1945 West Parnell Road, Jackson, MI 49201 e (517) 788-0453 November 18, 1983 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER GWO 7020 INSPECTION REPORT NO 50-329/83-13 (OSC) AND 50-330/83-14 (OSC)
File: 0485.16 UFI: 42*05*22*04 Serial: CSC-7003 0.4.2 70*01
REFERENCE:
(1) R F Warnick letter to J W Cook, dated October 25, 1983 Inspection Report No 50-329/83-13 (OSC) and 50-330/83-14 (OSC)
This letter, including Attachment 1, provides our responses to Reference 1, which transmitted the subject Inspection Report and Requested our response to the Notice of Violation and Notice of Deviation.
JWC/ BHP /RHW/klw 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 hhh O
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6 OL/0M SERVICE LIST Mr Charles Bechhoefer, 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 Env conmental 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 L
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 Washirgton, 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 OC1183-0005A-CN01
CONSUMEf' POWER COMPANY Midland Units 1 and 2 Docket No 50-329/50-330 Letter Serial CSC-7003 Dated November 18, 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 October 25, 1983.
CONSUMERS POWER COMPANY l
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Attachm:nt 1 Serial CSC-7003 CONSUMERS POWER COMPANY'S RESPONSE TO US NUCLEAR RECULATORY COMMISSION, REGION III INSPECTION REPORT NO. 50-329/83-13 (OSC) & 50-330/83-14 (OSC)
Appendix A (Notice of Violation) to Inspection Reports No. 50-329/83-13 (OSC) and'50-330/83-14 (OSC) provides Items of Noncompliance to 10 CFR 50, Appendix B.
The NRC statements and our responses are given below:
I.
NRC STATEMENT 10 CFR 50, Appendix B, Criterion XVI states, in part, "In the case of sig-nificant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."
CPC-1A, Policy No. 16, Corrective Action 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 recurrence are a matter of judgment, but the following conditions are always evaluated:
d.
Repetitive minor problems or defects which may be symptomatic of a larger problem... g.
Unsatisfactory conditions identified by the NRC."
Co'ntrary to the above, the licensee failed to take adequate corrective action to assure that the cause of document control problems in the remedial soils area were determined and sufficient corrective action taken to preclude repetition. The inspector informed the licensee of recurring document control problems on four different occasions, by identifying four items of noncompliance over the past year and a half.
CONSUMERS POWER COMPANY RESPONSE In accordance with this Notice of Violation, explanation of corrective action is as follows; 1.
CorreEtive Action Taken and the Results Achieved:
CPCo has initiated QAR F-326, dated 6/20/83 regarding the number of unincorporated drawing attachments. NCR M01-9-3-174, dated 7/20/83, has been written regarding the time required for incorporation of attachments. Also QAR 355, Rev. 1, dated 7/20/83, has been written regarding timely retirement of one time deviation attachments to specifications and drawings, timely removal / incorporation of design changes from related drawings and specifications, and addressing the large amount of dnincorporated specification attachments.
In addition, a site wide Stop Work Order was issued on 10/22/83 regarding discrepancies between Project Engineering and Field Drawings with respect to drawing attachments. The two QAR's and NCR are being addressed for corrective action.
Inspection Report Nos. 50-329/83-13 and 50-330/83-14 refer to IE Inspector Reports Nos. 50-329/82-21, 50-330/82-21, 50-329/83-03, 50-330/83-03 concerning use of uncont-rolled PQCI's and an out-of-date drawing. These items have been OC1183-0005A-CN01
Attech int 1 Serial CSC-7003 responded to previously in CPCo's responses to 50-329/82-21, 50-330/82-21, 50-329/83-03, 50-330/83-03, in CPCo letters Serial 19107, dated 12/10/82 and Serial CSC-6688, dated 5/6/83, respectively.
2.
Corrective Action to be Taken to Avoid Further Noncompliance:
In response to QAR F-326, QAR F-355, Rev. 1, and NCR M01-9-3-174, and the October 22, 1983 Stop Work Order, a comprehensive review of drawing changes and attachments underway. CPCo management has direc-ted, in conjunction with the stop work order, that the entire design change process be reviewed to identify other processes that need corrective action. A management level steering committee is presently meeting to determine when such corrective action will be taken.
Schedules will be established for corrective action prior to lifting the stop work.
3.
Full Compliance will be Achieved as Follows:
Deficiencies noted in the Notice of Violation will be corrected with resolution of the items in QAR F-326, NCR M01-9-3-174, and QAR F-355, Rev. 1.
Scheduling of final closure of the QAR's and NCR will be required prior to lifting the October 22, 1983 Stop Work Order. The Site Management office will advise Region III inspectors when full compliance is achieved regarding this issue.
II. NRC STATEMENT 10 CFR 50, Appendix B, Criterion V, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings... and shall be accomplished in accordance with these instruc-tions, procedures, or drawings."
QA Procedure B-3M-1 states, in part, " Appropriate Level III personnel shall approve specific lesson plans and examination banks, as required by Procedure B-2M-1."
Contrary to the above, the civil lesson plan and exam bank for PQCI C-4-10, Batch Plant Inspection, was reviewed by a Level III whose cer-tification is in the mechanical area.
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:
To document this condition and take corrective action NCP M01-9-3-113 was prepared and issued. The part corrective action reqaired a Civil Level III to review the Lesson Plan and Exam Bank and if found accep-table to approve them. The Lesson Plan and Exam Bank were reviewed by OC1183-0005A-CN01
Serial CSC-7003 a Civil Level III, found acceptable, and approved by the Level III..
There was no impact to training and examination previously conducted.
2.
Corrective Action to be Taken to Avoid Further N/,ncompliance:
As part of the process corrective action for the NCR, the MPQAD Training Department developed a matrix indicating Level III's author-ized to approve various lesson plans and exam banks. Also, the MPQAD Training Eranch reviewed all lesson plans and exam banks against this list of Level III's to verify that all previous Lesson Plans and Exam Banks had the required approvals. This list is maintained and is available to Training Branch personnel for their use in establishing approved reviewers.
- 3.. Full Compliance will be Achieved as Follows:
Closure of the NCR M01-9-3-113 on 11/2/83 indicated that there was no impact to the training and examinations performed.
In April, 1983, a complete review of Lessons Plans and Exam Banks indicated that all others had been properly signed. An additional review of all Lesson Plans and Exam Banks will be conducted to verify that this process corrective action is adequate and that the process is being properly maintained. This review will be completed by December 23, 1983.
If any additional items are identified during this review they will be documented and dispositioned.
Appendix B (Notice of Deviation) to' Inspection Reports No. 50-329/83-13 (OSC) and 50-33/83-14 (OSC) provides a Notice of Deviation. The NRC statement and our response.is given below.
I.
NRC STATEMENT During a January 18-19, 1982, audit the licensee committed to bring the lagging boards for the drift excavations up as high as possible to restore lateral. support to the unexcavated soil.
Contrary to the above, it was determined on May 11, 1983, that an incor-rect procedure was being used by the underpinning contractor.
Instead of
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bringing the lagging boards for the drift excavations up as high as l
possible, the upper boards were being omitted and the top of the excava-l tions were being sloped outward.
Subsequently, the licensee issued an FCR to correct all the previous work and to prevent any further overexcavation from being performed.
CONSUMERS POWER COMPANY RESPONSE In accordance with this Notice of Deviation, explanation of corrective action is as follows;.
OC1183-0005A-CN01
Attachssnt 1 Serial CSC-7003 1.
Corrective Action Taken and the Results Achieved:
On May 11, 1983, the subject slope layback activity was stopped in drifts where excavation was in progress. FCR No. C-6099 to Design Drawing No. C-1427, dated 5/23/83, was issued to permit work to resume by eliminating the slope layback and installing lagging boards as high as possible.
In addition, FCR No. 6066 to Drawing No. C-1427, dated S/17/83, and FCR No. 6179 to Drawing No. C-1427-2, dated 6/13/83, were written to address correcting the slope layback condition in a number of locations already excavated. Further excavation proceeded after corrective actions were initiated in the affected areas.
2.
Corrective Action to be Taken to Avoid Further Noncompliance:
The design drawings have been revised to indicate installation of lagging boards for drift excavations as high as possible, with no slope layback provisic s.
Future inspections will be conducted to this revised criteria.
3.
Full Compliance will be Achieved as Follows:
All excavation performed after May 11, 1983, was performed to the complying condition. Drawing C-1427 was revised 6/23/83 to eliminate the slope layback on future drift work. The correction of the past work was completed by 6/20/83.
Attachments i
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