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t NUCLF AR REGULATORY COMMISSION e
MEGDON III Pee acosavsLT acao v
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February 24, 1983 4
" " " " POR:
R. F. Warnicdt, Acting Director, Office of Special Cases 1MSEI W. D. Shafer, Chief, office of special Cases, Section 2 FROBIs R. J. Cook, Sealer Reside:t Inspector, Midland Site
SUBJECT:
GOVEltiMENT AGOUtr!ABII.ITY FMDBCT, FOIA DATED FISBRERY 16, 1983 the Midland Site Resident Inspector office has no information pertaining to any " July 1982 Stop work Order issued to the Midland Nuclear Power Plant by the Nuclear Regulatory Comadesion" referenced in the February 16, 1983 letter 4
to the Director, office of A& ministration from sillie Gards, Director, GAP Citizens Clinic.
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i R. J. Cook Senior Resident Inspector Midland site i
ccs S. L. Burgess C. A. Crosby I
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Rec ord the time in c.:in hours, rn::.ded t o I! c :.r:irca.1 15 c.inut es, for all x.tions taken.
Inclu ie the number of *pages rc;n c.ducen.
l Your clerical overhead factor,will be adde'd by the f01NPA Branch.
Negative result.s time will be reported to t.his office by telephone.
REW.t TORin TO:
Direi. tor, Di, vision of Rules and Records, Ranm f riBB-4?)0.
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U.S. NUCLEAR REGULATORY Ish!ON l
REGION !!!
OUTGOING TRANSMISSION SERVICE REQUEST Date M A Y / F T Nusttr of Pages
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FOR WP & D/C USE E/W Towers System 6 (WP)
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Tl Ext #728 Silver Springs FTS (WillsteBldg)
Cosmercial Landow Bldg.
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Time Completed Region II Trans. Time Region IV pctual Minutes)
Region V Operator Resident at NSAC INP0 Corportate Office (Identify recipient & fax number Other (Designate-include fax numer I
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933 5 i GB3' 4
Docket No. 50-329 Docket No. 50-330 i
Consumers Power Compa.ny ATTN:
Mr. James W. Cook Vice President Midland Project 1945 West Psrnall Road Jackson, MI 49201 3
Gentlemen:
Thank you for your letter dated May 13, 1983, informing us of the steps you have taken to correct the noncompliance which we brought to your attention in Inspection Reports No. 50-329/83-05; 50-330/83-05 forwarded by our letter dated March 4, 1983. We will examine these matters during a subsequent inspection.
3 Your cooperation with us is appreciated.
Sincerely,
" Orig!r.a1 Ip::d I;7 R. F. LSrnick" R. F. Warnick, Director Office of Special Cases cc w/ltr dtd 05/13/83:
4 DMB/ Document Control Desk (RIDS)
I Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB i
The Honorable Frederick P. Cowan, ASLB i
The Honorable Ralph S. Decker, ASLB William Paton, ELD Michael Miller l
Ronald Callen, Michigan Public Service Commission l
Myron M. Cherry Barbara Stamiris
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Mary Sinclair Wendell Marshall Colonel Steve J. Gadler (P.E.)
I Howard Levin (TERA)
Billie P. Garde, Government-Accountability Project RIII RI A
RIII RIII' l
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ft RPDW fcT{t) f Gardner/sv La ad man Harrison Warnick i
05/27/83 Y (o o6 i
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Vice President - Projects Engineering and Constracriam I.. '. "' a r':,L :iT9,N
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i oeneral officas: 194s West Parnell Road, Jackson, MI 40201 e (517) 7ss 0453 g -**;-
,.ig-9 May 13, 1983
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Mr. J. G. Keppler, Regi)nal Administrator
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g 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER GWO 7020 INSPECTION REPORT NO. 50-329/83-05 (OSC) AND 50-330/83-05 (OSC)
File:
0.4.2 UFI: 70*01 Serial: CSC-6701 0485.16 42*05*22*C4
REFERENCE:
(1)
R. F. Warnick letter to J. W. Cook, dated March 4, 1983 Inspection Report No. 50-329/83-05 (OSC) and 50-330/83-05 (OSC)
This letter, including Attachment 1, provides our response to Reference 1, which transmitted the subject Inspection Report and which requested our written response to the item of noncompliance therein.
Consumers Power Company By b
James W. Cook Sworn and subscribed to before me on this O day of 't?Jdu 1
, 1983.
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Notary Public (///
My commission expires 3-Y- [b JWC/ BHP /dmh cc: RFWaraick, NRC Region III l
JJHarrison, NRC Region III RNGardner, NRC Region III I
RJCook, NRC Senior Resident Inspector, Midland Site RBLandsman, NRC Region III BLBurgess, NRC Resident Inspector, Midland Site c- -
MM 18 N DVQCl
A bec RCBauman, P14-314B WRBird, P14-418A FWBuckman, P14-113A JEBrunner, M-1079 NRC Correspondence File, P24-517 1
MLCurland, Midland GAHierzer, Bechtel-Midland MADietrich, Bechtel-Midland GFEwert, Midland FDField, Union Electric I
WJFriedrich, Midland MEGibbs, IL&B WDGreenwell, Bechtel Ann Arbor Dehorn, Midland 4
EMHughes, Bechtel AA KEMarbaugh, Midland QA/NO BWMarguglio/DJones, JSC-220A/206B JKMeisenheimer, Midland DBM111er, Midland (3)
JAMooney, P14-115A JARutgers, Bechtel Ann Arbor PSteptoe. IL&B DATaggart, Midland RAWells, Midland FCWilliams IL&B Washington REWhitsker, Midland e
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-erial: CSC-6701 CONSUMERS POWER COMPANY'S RESPONSE TO US NUCLEAR RECULATORY COMMISSION, RECION III INSPECTION REPORT NO. 50-329/83-05 (OSC) & 50-330/83-05 (OSC)
Appendix (Notice of Violation) to Inspection Report No. 50-329/83-05 (OSC) and 50-330/83-05 (OSC) provides an item of noncompliance to 10 CFR 50, Appendix B.
The 4
NRC statement and our response are given below:
1 NRC STATEMElfr "10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
Bechtel Specification for Installation, Inspection and Documentation of ASME Sec-i tion III Pipe Supports, Hangers and Restraints for Piping in a Nuclear Power Plant, Specification No. 7220-M-362(Q) states in section 5.13.5, "After instal-lation, the snubber assembly shall be protected from physical damage due to nor-mal construction activities by providing wooden, heavy cloth, or other similar suitable protective covers."
Contrary to the above, mechanical snubbers installed in Unit I and 2 contain-ments were not protected from physical damage due to normal construction activi-ties by providing the required protective covers.
This is a Severity Level IV violation (Supplemen* II)."
CONSUMERS POWER COMPANY RESPOPSE In accordance with this Notice of Violation, an explanation of corrective action is as follows:
1
- 1) Corrective Action Taken and The Results Achieved NCR M01-9-3-157 was written on May 11, 1983 by MPQAD to document the non-conformance. Bechtel maintenance form F-10-359 is being written to cover j
maintenance of all installed Q and non-Q mechanical snubbers within their
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jurisdiction.
f B&W Construction Company is preparing a Field Construction Procedure (FCP i
to address maintenance of mechanical snubbers within their jurisdiction.
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- 2) Corrective Ac; ion To Be Taken To Avoid Further Noncompliance t
A 100% initial inspection of all installed mechanical snubbers will be performed by Bechtel & B&W.
Periodic inspections will be performed on a continuing basis theree';er.
l A Bechtel Task Force was formed on May 9, 1983 to structure, scope and l
eventually form a permanent storage / maintenance team. In addition to hav-ing responsibility for implementation of the storage /mainenance program, this team will perform an investigation to ensure that all types of mater-ials and equipment are adequately covered by the storage / maintenance pro-gram. Full implementation of the above will avoid further noncompliance.
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- 3) Full Compliance Will Be Achieved As Follows:
Bechtel maintenance form F-10-359 will be implemented by May 23, 1983.
B&WCC will have their FCP issued for implementation by June 1,1983.
The 1007. initial inspection will be completed by both Bechtel and B&WCC by July 1, 1983. The investigation of other types of materials and equipment will be complete by August 1, 1983.
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UNITED STATES o
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NUCLEAR REGULATORY COMMISSION e
REGION ill a
o 790 ROOssVsLT MOAD oLEN sLLYN,ILLINOls s0137 MAY 2 7 G83 Docket No. 50-329 Docket No. 50-330 Consumers Power Company ATTN:
Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI 4?201 Gentlemen:
This refers to the routine safety inspection conducted by Messrs. J. Simon and A. Sather of this office on March 29-31 and April 1,1983, of activities at the Midland Nuclear Power Plant, Units I and 2, authorized by NRC Construc-tion Permits No. CPPR-81 and No. CPPR-82 and to the discussion of our findings by Mr. R. J. Cook and the inspectors with Mr. B. Peck and others of your staff at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix.
A written response is required.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s) will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the re-quirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosure (s), and your response to this letter will be placed in the Public Document Room.
The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
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2 Consumers Power Company We will gladly discuss any questions you have concerning this inspection.
Sincerely,
" Orig!nal :I;n:d 1.y..'.. F. IJcralck" R. F. Warnick, Director Office of Special Cases
Enclosures:
1.
Appendix, Notice of Violation 2.
Inspection Report No. 50-329/83-06(OSC);
No. 50-330/83-06(OSC) cc w/encls:
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB William Paton, ELD Michael Miller Ronald Callen Michigan Public Service Commission Myron M. Cherry i
Barbara Stamiris Mary Sinclair Wendell Marshall Colonel Steve J. Gadler (P.E.)
Howard Levin (TERA) i Billie P. Garde, Government
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Accountability Project t
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RI RI I RIII RIII n/ya yy g
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jp her Gardner H
ison Wa S
1 05/18/83
t APPENDIX i
NOTICE OF VIOLATION Consumers Power Company Docket No. 50-329 Docket No. 50-330 As a result of the inspection conducted on March 29-31 and April 1,1983, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violation was identified:
10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions."
B&WCC Quality Assurance Policy 9-QA-18 (Audits) Paragraph 11 states, in part, "The entire program shall be audited annually at each project site."
B&WCC Quality Assurance Policy 9-QA-07 (Control of Purchased Material and Services) Paragraph 4.6 states, in part, "An audit of a supplier shall be conducted every twelve months as a maximum."
Contrary to the above, B&WCC placed purchase orders and received material from suppliers which had not been audited for periods of up to thirty-four months, exceeding the twelve month requirement as specified in procedures 9-QA-18 and 9-QA-07.
This is a Severity Level IV violation (Supplement II).
Purruant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, it. eluding for each item of noncompliance: (1) cor-rective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance 6
will be achieved. Consideration may be given to extending your response time I
for good cause shown.
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MM 2 7 I Dated R. F. Warnick, Director i
Office of Special Caeds
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U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-329/83-06(OSC); 50-330/83-06(OSC)
Docket No. 50-329; 50-330 License No. CPPR-81; CPPR-82 Licensee:
Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Plant Inspection At:
Midland Nuclear Plant Site, Midland, MI Inspection Conducted:
March 29-31 and April 1, 1983 N
Inspectors:
J. A. Simon
_5faL6 93 A. S
_ Gfd-3 )d3 J.hlcrison, Approved By: J Section 2, Midland Sfy3)S3 hief Inspection Summary Inspection on March 29-31 and April 1, 1983 (Report No.
50-330/83-06(osC))
50-329/83-06(OSC);
Areas Inspected:
Routine inspection by NRC personnel of licensee actions manuals and inspection of hanger installations.on previously identifie a total of 58 inspector-hours onsite by two NRC inspectors.This inspection involved Results:
Of the three areas inspected k
tions were identified in two areas; one, no items of noncompliance or devia-in the remaining area (failure to follow procedures - Paragraph 2 item of n 5
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i, DETAILS i
1.
Persons Contacted i
f Consumers Power Company (CPCo)
- B. H. Peck, Construction Superintendent
- M. L. Curland, MPQAD
- D. Vokal, Construction Engineer Babcock and Wilcox Construction Company (B&WCC)
- V. N. Asgaonkar, Site Manager
- T. T. Davis, Construction 1
- S. Taulbee QC Bechtel Power Company j
- A. Wagle, PQAE f
Other licensee and contractor personnel were routinely contacted during the course of the inspection.
- Denotes those attending the exit interview.
1 I
2.
Licensee Action on Previously Identified Items a.
(open) Open Item (329/83-01-02; 330/83-01-02): The licensee had 2
reopened previously closed Nonconformance Reports (NCR's). As previously reported, NCR's which have been reviewed by the licensee had been revised to include the required information needed to justify the "use-as-is" disposition. No rework of completed con-struction was required as a result of this review. Review of the remaining NCR's is scheduled for completion by June 30, 1983. This item remains open pending the completion of the licensee's review.
I b.
(0 pen) Unresolved Item (329/83-01-03): Cracks were identified in' the Unit 1 Containment Building. The licensee has presented a brief-report acknowledging the existence of the cracks. This item remains l
open pending review of the licensee's report.
t c.
(Closed) Unresolved Item (329/83-04-01; 330/83-04-01): Audits of 5sWCC suppliers. During this inspection, the licensee presented a 4
list of suppliers audited and dates of the audits..It was deter-mined that all purchases of material for the Midland project were made from approved vendor lists.
B&WCC Quality Assurance Policy 9-QA-18 (Audits) Paragraph'11 states.
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in part, "The entire program shall be audited annually at each project site." Policy 9-QA-07 (Control of Purchased Material and i
Services) Paragraph 4.6 states, in part, "An audit of a supplier l
shall be conducted every twelve months as a maximum."
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i B&WJC issued twenty-seven purchase orders to nine suppliers in the three year period between February 1980 and February 1983. Contrary to the above, eleven purchase orders were placed with six suppliers which had not been audited within the preceding twelve months as required by B&WCC procedures 9-QA-07 (Control of Purchased Material and Services) and 9-QA-18 (Audits). The mean elapsed time between an audit and the placement of a purchase order was twenty-seven i
months and the maximum elapsed time was thirty-four months.
The inspectors informed the licensee that this unresolved item is to be escalated to an item of noncompliance as described in the l
Appendix of the report transmittal letter.
(50-329/83-06-01; 50-330/83-06-01) 3.
Review of Babcock and Wilcox Quality Manuals l
The inspectors reviewed the Babcock and Wilcox Construction Company (B&WCC) " Quality Control Manual CT49," Volumes I and II, dated March 7, 1980 and B&WCC " Quality Assurance Manual for the Fabrication and Installation of Class 1, 2, 3 and CS Items, CPC Units I and II "
dated June 13, 1979. A complete review was made of selected items within each manual. Information provided by this review formed the basis for additional inspections.
i No items of noncompliance or deviations were *.dentified.
4.
Inspection of Hanaers and Review of Associated QC Records A field inspection was made of hangers 1CCA-2-4-H1 and 2CCA-107-1-H5 to determine if these components were fabricated and are being installed in accordance with procedures.
The following QC records pertinent to the above hangers were examined i
to determine conformance with the Quality Assurance Criteria of Appendix B of 10 CFR 50 and the Consumers Power Company Quality Aa-urance program Manual for the Midland Nuclear Plant CPC-1-A, Revision 12.
Hanger 1CCA-2-4-H1 I
l Field Construction Procedures Number 255B Weld Control Records B&WCC Form Number 3885 L
Filler Metal Issue Sheet B&WCC Form Nisaber 31965 l
Certification of Performance Welder Qualification Test Filler Metal Certification Welding Instruction Sheet 1
NDE Inspection Records 0
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Certification of NDE Personnel Qualifications Drawing No. FSK-M-1CCA-2-4-H1 Hanger 2CCA-107-1-H5 (installation has not been completed). This hanger l
has been put on hold by B&WCC.
Field Construction Procedure Number 701B 4
Drilling Permit Number 00524 1
l Receiving Inspection Report for Hanger Material NDE Inspection Report i
Inspection Check List for Expansion Type Concrete Anchors Interim Drawing Change Notice 5279 I
Drawing No. FSK-M-2CCA-107-1-H5 No items of noncompliance or deviations were identified.
A 5.
Exit Interview The inspectors met with the licensee representatives (denoted in the Persons Contacted section of this report) on April 1, 1983, and summarized the scope and findings of the inspection activities. The licensee acknowledged the inspectors' findings.
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