ML20083H009

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Responds to NRC Re Violations Noted in IE Insp Repts 50-329/83-23 & 50-330/83-24.Corrective Actions: Nonconformance Rept Qar RS-00024 Re Omission of Calibr Stickers on Hydraulic Meters Initialed
ML20083H009
Person / Time
Site: Midland
Issue date: 12/20/1983
From: Jackie Cook
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20083H001 List:
References
CSC-7066, NUDOCS 8401060500
Download: ML20083H009 (4)


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Vice President. Projects, Engineerirr; and Construction General o f fices: 1945 West Parneil Road, Jackson, 6.91 49201 *(517) 788 0453 f PRINCJPAL !

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December ?0, 1983 3/RA I ~ ~ ~~

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'l_____gri10 4 Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER GWO 7020 INSPECTION RFPORT NO 50-329/83-23 (OSC) AND 50-330/83-24 (OSC)

File: 0485.16 UFI:

42*05*22*04 Serial: CS*:-7066 70*01 i

REFEREhCE:

(1) R F Warnick letter to J W Cock, dated November 17, 1983 Inspection Report No 50-329/83-23 (OSC) and 50-330/83-24 (OSC)

This letter, including Attachment 1, provides our response to Reference 1, which transmitted the subject In.rection Report and requested our response to the Notice of Violation.

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Attachment cc: hFWarnick,1:RC Region III JJHarrison, NRC Region III FNGardner, NRC Region III RBlandsman, NRC Region III RJCook, NRC Senior Resident Inspector, Midland Site RLBurgess, NRC Resident Inspector, Midland Site 8401060500 840104 DR ADOCK 03000329 eon 4+j D

OCl283-0001A-CN01

CCNSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329/50-330 Letter Serial CSC-7066 Dated December 20, 1983 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Er. orgy 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 November 17, 1983.

CONSUMERS POWER COMPANY By J W Cook, Vice President Pro cts, Engineering and Construction Sworn and subscribed before me thir;,7d day of

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m=b Notrry Public My Commission Expires

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Serial CSC-7066 CONSUMERS POWER COMPANY'S RESPONSE TO US NUCLEAR REGULATORY COMMISSION, REGION III INSPECTION REPORT NO. 50-329/83-23 (OSC) & 50-330/El-24 (OSC)

Appendix (Notice of Violation) to Inspection Reports No. 50-329/83-23 (OSC) and 50-330/83-24 (OSC) provides an Item of Noncompliance to 10 CFR 50, Appendix B.

The NRC statement and our response are given below:

NRC STATEMENT 10 CFR 50, Appendix B, Criterion V, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or draw-ings.

. and shall be accomplished in accordance with these instructions, procedures, or drawings."

CPC-1A, Policy No. 5, Instructions, Procedures and Drawings, states, in part,

" Instructions for controlling and performing activities affecting quality of equipment or activities such as.

inspecting.

. are documented in instructions, procedures, specifications, checklists and other forms of documents."

Contrary to the above, the Project Quality Control Instructions (PQCI) for the inspection of (1) the static cone penetrometer tests at OBS-4 and (2) the calibration of the hydraulic meters, failea to require the verification that the calibration stickers were affixed to the apparatus as required by UST Procedure QCP-21.

As a result, calibration stickers were not affixed to the hydraulic meters measuring penetromecer reciatance rendering the accuracy of the instruments to be indeterminate.

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:

CPCo has initiated a nonconformance report, QAR No. RS-00024, regarding the omission of calibration stickers at the subject equipment. The equipment was calibrated in accordance with Project requirements and documentation was on file certifying this. The PQCI required a review of calibration records and verification that the instruments had been calib-rated prior to use.

This review was completed per requirements on the subject equipment. Therefore, the accuracy at the time of use was not indeterminate. However, the omission of the calibration sticker on the equipment was contrary to U.S. Testing requirements and the PQCI did not require verification that the sticker had been applied.

A requirement for calibration stickers has been added to the U.S. Testing technicians checklist for load cell calibration and tl.e P0CI for Inspection of Static Cone Penetrometer Test has been revised to require a OCl283-0001A-t"P1

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QC Inspector check that a calib7ation sticker has been affixed. Calib-ration stickers have been affixed to the equipment in question.

2.

Corrective Action to be Taken to Avoid Further Noncompliance:

The inclusion of the calibration sticker requirement in the Load Cell Calibration Checklist will require a technician to affix the sticker and the Static Cone Penetrometer PQCI will require a OC Inspectors check of this quality attribute in the future.

3.

Future Compliance will be Achieved as Follows:

Closure of QAR RS-00024 on November 19, 1983, indicated that the subject nonconforming condition had been brought into compliance with Project r

requirements and satisfactory measures had been taken to prevent reoccur-rence.

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OC1283-0001A-CN01

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