ML20084L084
| ML20084L084 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/25/1984 |
| From: | Quamme D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Harrison J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20084L081 | List: |
| References | |
| CSC-7667, NUDOCS 8405140334 | |
| Download: ML20084L084 (3) | |
Text
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.O)l Consumers I(
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M41end Project: PO Box 1963, Mdtand. MI 48640. ($17) 6318650 j
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Mr J J Harrison ENF U S Nuclear Regulatory Commission Region III 7,99 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER GWO 7020 DOCKET NOS 50-329 AND 50-330 REQUEST FOR RELEASE FROM CCP TO DO WORK ASSOCIATED WITH THE EMERGENCY DIESEL GENERATORS File: 0655.1, Bl.7 Serial: CSC-7667
Reference:
JWCook to JGKeppler CSC-7187 dated February 1, 1984 The purpose of this letter is to request your concurrence to perform specific work on Bechtel interface components to meet the commitments outlined;in.the referenced letter.
The work to be performed includes removal of Bechtel piping systems, prior to Phase 2 release to gain access to vendor equipment to perform complete inspec-tions.
The affected equipment listed below was supplied by a subvendor to Transamerica De Laval, Inc., American Air Filter, Inc.
Exhaust Silencers Exhaust System Expansion Joints Intake Air Filters Intake Air Silencers Intake Air Flexible Connectors The Bechtel interface piping will be left disconnected after the inspection to allow accessibility to those listed components in the event that the inspections reveal the requirement to do modifications. As stated in the reference, the work will be performed under the Construction Work Plan (CWP) program once we obtain your concurrence. The CWP will include the Quality Work Package (QWP) which will identify and require the appropriate quality inspectiions and func-tions to be performed. The Construction Completion Program inspections of the Bechtel interface piping will be done after Phase 2 release and reinstallation.
DLQ/ BHP /JSK/jmr 8405140334 840509 DRADOCK05000g
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M Rubenstein, MPQAD BLHarshe, P24-618 EBPoser Bechtel Ann Arbor D Horvath, Bechtel Ann Arbor GAHierzer, Bechtel. Site RJCook.. Senior Resident Inspector, Midland Site D Hood, USNRC JGKeppler,' Regional Administrator, Region III e
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!POV(er James W Cook Vice President - Projects, Engineering and Construction General oNieest1945 WesrPornell Road, Jackson, MI 49201 * (517) 7s8 0453
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February 1, 1984 N
Mr J G Keppler, Regional Administrator U S Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER GWO 7020 DOCKET NO 50-329 AND 50-330 - AMENDED MIDLAND PROJECT RESPONSE TO NRC, REGION III LETTER DATED MAY 23, 1983 File: 0485.16, 0.4.2 UFI: 42*05*22*04, 70*01 Serial: CSC-7187
REFERENCES:
(1) J W Cook letter to J G Keppler dated July 12, 1983, Serial CSC-6781 (Amended Response)
(2) J W Cook letter to J G Keppler, dated June 24, 1983, Serial CSC-6764 (Amended Response)
(3) J G Keppler letter to J W Cook, dated May 23, 1983 (Request forAddi)ionalInformation)
This letter provides a status of the progress made towards meeting the commitments outlined in the July 12, 1983 amended response.
An extension in meeting the full compliance commitment dates is requested because of errors in the manufacturer's (TDI) inspection procedures and because the current Stop Work Orders have caused a postponement in the component inspections required to meet the commitments of the letter.
k JWC/ BHP /JSK Attachments CC:
RJWarnick, NRC Region III 5
JJHarrison, NRC Region III
-RNGardner, NRC Region III RBLandsman, NRC Region III RJCook, NRC Senior Resident Inspector, Midland' Site BLBurgess, NRC Resident Inspector, Midland Site FEB 151184
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CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329/50-330 g
Letter Serial CSC-7187 Dated February 1, 1984 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 letter serial CSC-7187 dated February 1, 1984 from J W Cook to J G Keppler.
CONSUMERS POWER COMPANY
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By A
t J W Cook, Vice President Pro ts, Engineering & Construction s
/Iaa u, 1984.
Swotn and subscribed before me this
/3 day ofs 2
f SAw]D Notary Public My Commission Expires
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t Status of the Amended Response to J G Keppler letter to J W Cook dated May 23, 1983 The status of the amended response to J G Keppler letter to J W Cook dated May 23, 1983 is submitted in the following format:
NOV Item B Identification Number A.
Statement of Original Violatign (from J G Keppler letter to J D Selby dated February 8, 1983: Notice of Violation EA 83-3.)
B.
Request For Additional Information (from J G Keppler letter to J W Cook j
dated May 23, 1983.)
C.
Status of Items Requiring Completion to Achieve Full Compliance i
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OC0184-0000A-CN01 i
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2 NOV Item B-2.a (82-22-08)
A.
Statement of Original Violation
" Measures were not established for the selection and review for suit-ability of application of "Q" materials associated with the diesel generator exhaust muffler in that design drawings and specifications did not indicate the material identity of the installed muffler saddle sup-ports and plates."
B.
Request For Additional Information "Regarding Item B.2.a. we reiterate our position that the lack of design documentation which specified the material requirements for the diesel generator exhaust mufflers constituted an item of noncompliance. Please provide any additional information supplied by the vendor regarding the traceability of the exhaust muffler materials, and as appropriate, your corrective actions and the results achieved, corrective actions taken to avoid further noncompliance, and the date when full compliance will be achieved."
C.
Status of Items Requiring Completion to Achieve Full Compliance Section C.5 of the Amended Response letter of July 12, 1983, Serial CSC-6781, identified five items requiring completion before full comp-liance would be achieved in the matter of lack of design documentation specifying material requirements for the diesel generator exhaust silen-cers. These five items and their current status for completion are described below.
5.a Statement from Amended Response Receipt of the exhaust silencer Material Certificate of Compliance and completion of the fabrication inspection is expected by October 15, 1983.
A schedule for any subsequent rework as a result of the inspection will be established at that time.
i Status t
l A material certificate of compliance for the exhaust silencer was received from TDI on August 5, 1983. TDI has certified the exhaust silencer as being fabricated from ASTM A-36, ASTM A-285 grade C and ASTM A-569.
(Copy is attached) i In order to determine the acceptability of this certification, a review was conducted of licensing commitments on quality assurance i
requirements for the Midland Plant, and industry requirements. The results of this review are summarized as follows:
a.
The Midland position on Regulatory Guide 1.123 commits to comp-liance with ANSI N45.2.13, Draf t 3, Revision 3 (which was accep-ted by the NRC in its letter to CPCo dated August 12, 1977).
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b.
ANSI N45.2.13, Draft 3, Revision 3, Section 10.2 states:
"Where not precluded by other requirements, documentary evidence may take the form of written certificates of conformance which identify the requirements met by the [ procured] items."
l Section 10.3.3 of the standard states:
"In certain procurement actions which do not involve direc inspection by the Purchaser, the Purchaser may accept an item or service from a supplier based only on a Supplier's certificate of conformance.
. when the item or service is of simple design involves standard materials, processes, and tests."
c.
A certified material test report (CMTR) is required for certain piping and components constructed to ASME Section III or for special application where the material's particular properties are essential to the piping or component's application. The latter cese is determined by the responsible design engineer and the requirement for a CMTR is reflected in the item's procurement documents.
d.
The diesel exhaust silencers are not constructed to ASME Section III or to any other nationally recognized construction code.
(The interconnecting piping is Seismic Category I, ANSI B31.1.)
Consistent with current industry practice, and because the exhaust silencers are of simple design and constructed using standard materials, processes, and tests, the procurement documents do not require a CMTR.
Therefore, because the TDI material certificate of compliance meets or exceeds a certificate of conformance, it is concluded that this first step in establishing the exhaust silencers as components of acceptable quality for their function has been completed.
A fabrication inspection procedure for the exhaust silencers was received from TDI on September 1, 1983. This inspection has not yet been initiated because of a current hold on Q-related construction activities.
Inspec-t tion completion is expected to be within three months of release of the current hold on Q-related construction activities.
If any deficiencies i
are identified, a schedule for their resolution will be developed at that time.
5b Statement from Amended Response The exhaust silencer saddle support and center support plate exten-sions are replaced and NCRs 4693 and 4994 are dispositioned.
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Status Replacement of the end support and center support plate extensions
.has been delayed because of the current hold on Q-related construction activities. The NCRs were dispositioned on November 13, l
1983.
i The replacement activity is expected to be completed within four months of release of the hold on Q-related construction activities.
l 5.c -Statement from Amended Response NCRs M-01-9-3-158 and 4955 will be resolved by October 15, 1983. A schedule for any subsequent rework resulting from this resolution 4 -
will be established then.
Status
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TDI, in its letter of August 2, 1983 to Bechtel, confirmed that only these four items of equipment (in addition to the exhaust silencers)
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i and no others (requiring safety-related status) were supplied without i
adequate quality assurance documentation. Consistent with the j
approach taken to upgrade the exhaust silencer, material certificates j
of compliance and fabrication inspection procedures were requested L
and received from TDI on August 5, 1983 and September 1, 1983, respectively.
Implementation of the fabrication inspection procedure (as the next step in resolving the two NCRs) is delayed by the current hold on Q-related construction activities.
Inspection is expected to be completed within three months of the release of the hold.
If any deficiencies are identified, they will be resolved on a schedule to be developed at that time.
5.d Statement from Amended Response Further investigation to ascertain if there are any additional suspect items in the package provided by TDI is expected to be 8
complete by August 15, 1983.
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Status TDI letter of August 2, 1983 to Bechtel identified no other safety-related equipment items (beyond those described in Section 3 f
above), as lacking adequate quality assurance documentation. There-i fore, this action item is complete, j
5. e.
Statement from Amended Response The review program and schedule described in part 4 and the subse-quent review is completed and any findings are addressed.
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Status A review program was developed and initiated on September 16, 1983.
115 specifications / material requisitions were identified as requiring review and to date the review of 113 has been completed without identifying any new concerns. The review of the remaining two specifications / material requisitions is still in progress and is expected to be completed by March 30, 1984.
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