ML20083K443

Interim Deficiency Rept Re Inconsistent Processing & Review of Field Change Requests & Field Change Notices Against Project Design Documents.Initially Reported on 831021.Next Rept Expected by 840629

ML20083K443
Person / Time
Site:	Midland
Issue date:	04/06/1984
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
28075, 83-09-#4, 83-9-#4, OL, OM, NUDOCS 8404160173
Download: ML20083K443 (10)

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hh h Vice President - Projects, Engineering and Construction oeneral offices: 1945 West Pernell Road, Jackson, MI 49201 * (517) 788 0453 April'6, 1984 83-09 #4

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PR$CIPA1. STAFF Hr J G Keppler, Regional Administrator OT IDP# l US Nuclear Regulatory Commission g

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HIDLAND ENERGY CENTER y

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N REVIEW AND CONTROL OF Q LISTED DRAWINGS AND SPECIFICATIONS FILE:

0.4.9.81' -SERIAL: 28075

References:

J W Cook letters to J G Keppler, Same Subject

1) Serial 22608, dated November 21, 1983

2) Serial 26648, dated January 6, 1984

3) Serial 27998, dated February 10, 1984 This ictter, as were the referenced letters, is an interim 10CFR50.55(e) report on a deficiency in the system for processing field changes involving project design documents.

The attachment to this. letter provides a teseription of the deficiency and

.the corrective actions being taken to resolve this problem.

Another reporti either interim or final, will be sent on or before June 29, 1984 s

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Attachment:

-(1) MCAR-73 Interim Report 4, dated March 19,.1984 CC: Document Control Desk, NRC DSHood, US NRC Washington, DC

.0ffice of NRR RJCook, NRC Resident Inspector INPO Records Center.

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Mr Frank J Kelley Atomic Safety & Licensing Appeal Board

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Attorney General of the

. U S Nuclear Regulatory Co:nmission State of Michigan

' Ms Carole Steinberg Washington, DC 20555 V

l" Assistant Attorney General i

Environmental Protection Division

-Mr C R Stephens (3)

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720 Law: Building' Chief, Docketing & Services 4

Lansing, MI 48913 U S Nuclear Regulatory Consaission l

Office of the Secretary a

Washington, DC 20555 L

Mr Myron M Cherry, Esq.

Ms Mary Sinclair

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Suite 3700 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 j

Washington, DC 20555

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.Mr Charles;Bechhoefer,'Esq

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-Atomic, Safety & Licensing Atomic Safety & Licensing Board Panel'_

Board Panel

-U S Nuclear Regulatory Commission EU S Nuclear Regulatory Commission

. East-West Towers, Room E-413 Washington, DC 20555

'Bethesda, MD.20014' Ms Barbara Stamaris-t Dr. Frederick'P Cowan 5795 North River Road 6152 N Verde Trail Rt 3 I

Apt B-125 Freeland, MI 48623

~ Boca Raton, FL 33433 U

Dr Jerry. Harbour-

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-Mr Fred C Williams

-Atomic Safety & Licensing.

Isham, Lincoln & Beale Board Panel.

'1120 Connecticut Ave, NW,' Suite:840-

U S Nuclear Regulatory Commission Washington, DC 20036 '

East-West. Towers, Ro m E-454 Bethesda, MD 20014 iMr James'E Brunner, Esq-

. Consumers Power Company.

,Mr M I Miller, Esq.

212 Weet, Michigan Avonne

.Isham, Lincoln & Beale Three First National Plasa JacksonfMI'49201.

52nd Floor-

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3 Serial 28075 83-09 #4 Mr D F Judd' Babcock & Wilcox PO Box ~1260 Mr John Demeester, Esq

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Michigan Division Midland MI 48640

Mr Steve Cadler, Esq 2120 Carter Avenue s

St Paul, MN 55108 Ms Lynne~Bernabei 1

Government Accountability Project Mr P. Robert Brown.

1901 Q Street, NW

-Clark, Klein & Beaumont.

Washington, DC 20009 1600 First-Federal Bldg Woodward Ave Detroit, MI 48226-3/14/84 s.

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Serial 28075

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SUBJECT:

MCAR 73 145538 INTERIM REPORT 4 DATE:

March 19, 1984 PROJECT: Midland Plant Units 1 and 2 Consumers Power Company 1

Bechtel Job 7220 Introdoction This report addresses problems with inconsistent processing and review of Field Change Requests (FCRs)/ Field Change Notices (FCNs) against project design documents.

Description of Concern g

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--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) 4 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 organisations compiled with their respective procedures, the i

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:

a) In some cases FCRs and FCNs were not attached to the proper base 4

design documents.

(Reft CPCo Audit MSA-83-32) b) In some cases quality org ntsation review of FCRs/FCNs affecting

- Q-related design documeucs were not performed where required.

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CPCo Audit MSA-83-32)-

Historical Backaround and Summary of Investination 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" block on the FCR and FCN forms.

(The FCR and FCN forms are included as

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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 reeerved 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 PCR/FCN registers. On the other hand, Field Document Control Center (FDCC) personnel keyed on documents listed in the "other drawings p

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 l;

specifications were added to the "other drawings or specifications affected" block or the " remarks" block without obtaining the apprcpriate

. quality organteation review and approval for' the added Q-listed documents.

Analysis o_f 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 have been reviewed to determine the base design documents that they should be posted against.

These FCRs and FCWu have also been reviewed to identify those cases where the quality organization' review and approval was required but not performed. Appropriate review and approvals have been obtained. The above reviews have included an evaluation as to the possibility of

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incorrect hardware installation.

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While.there was a lack of integration betweeni the procedures described

. previously, no safety. concern has been identified at this time.

Consumers Power Company (CPCo) has reported this -ites to the NRC under the rules of 10CFR50.55(e) on 'etober 22, 1983.

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i i 45675 xCAx 73 Interim Response 4 145538 rase 3 Root Cause The root cause was the lack of integration between field procedures /

instructions FPD-1.000, FPD-2.000, and FID-2.100, Project Engineering Procedure (PEP) 4.62.1 and Administrative Department Procedure ADP-2.12 and Administrative Department Instruction ADI 2.12.10, which govern the initiation, review, approval, and processing of FCRs and FCNs.

_ Corrective Action 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) l l

ensure required quality organization review and approvals were obtained, and c) to evaluate whether or not any lack of the above resulted ic hardware deficiencies. The program also provides for overview and verification by the Midland Project Quality Assurance

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Department of these actions. A total of 52,627 FCRs and FCNs have been reviewed under this program. From this review, a total of 10 NCRs (see Attachment 3) have been initiated and are under appropriate l

. review at this time. This review will include evaluation of safety concerns.

f Associated with the resolution of the FCR/FCN process, related document control' activity problems were identified and were documented via MPQAD MCAR/R DAT-1.

In addittoa to this program, the Field Procedures, Project Engineering Procedures and Administrative Department Instructions and i-Procedures associated with FCRs and FCNs have been reviewed and l

revised as necessary to provide integration..Bechtel personnel have been instructed in the use of these revised procedures in accordance with their departments' respective training proceduns.

! Actions are=now underway to provide that FCRs/FCNs are posted against the proper contro11ed' design documents on the Midland project.'

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A procedura interface program has been estabitshed to review the following -

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Bechtel project quality related procedures for const; u;:y at points of interface with eacn 'other. and. interfacing Consumers Power Company's procedures.

'2. Problems similar to the FCR/FCN interface problem.

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1 145675 MCAR 73 interim Report 4 i45538 page 4 This program is currently being implemented and as a result, 30 areas requiring investigation have been identified to date. Appropriate corrective action will be taken based on the results of the investigation.

The review of these 30 areas 1,s scheduled to be completed by August 15, 1984. A final report summarizing the results of this review and any additional areas reviewed is scheduled to be issued by March 15, 1985.

Procedure PPM, Section IV-17, interface control for interorganization -

process has been drafted and is scheduled to be issued by April 30, 1984. A copy of this procedure will be attached to the next interim report.

Reportability The conditions described in this report were reported to the NRC by telecon under the rules of 10CFR50.55(e) on October 22, 1983.

ubmitted by:

Boos sistant P e

Manager Approved by:

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Project Engineering Manager P

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C-E.H.-Smith

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Engineering Manager Concurrence by:

heJ8th fer" N.A. DietricK ' Assurance Fagineer Project QuaFity 4

Attachneate:

1. FCR Form

2. FCN Form

3. NCR. List l

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