ML20092C205

Forwards Complete Response to Tracked Action Item 088 Re Module 120D in Auxiliary Bldg

ML20092C205
Person / Time
Site:	Midland
Issue date:	06/12/1984
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	STONE & WEBSTER, INC.
References
CSC-7880, NUDOCS 8406210061
Download: ML20092C205 (7)

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CONSDIERS POWER COMPANY p MIDLAND ENERGY CENTER

/329 Transmittal No: CSC- 7880 j Date: June 12, 1984 To: Stone & Webster I P O Box 1963 Midland, MI 48640

/ PRifAIPAL STAFF l V'h &p, 'yna y Q&}

Attached Is: - Partial Response To 3/RA DE -

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1A0 23 For Your Information %A iL nENF ci ic -[p ]

O Other i

Description:

Tracked Action Item 088.

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CC: SJGNeppler~,J[NRC RayItihn.'IIf w/a d JJHarrison, NRC , Region III w/a BLBurgess, NRC Site w[a '

RAWells, MPQAD w/a BHPeck, MEC w/a NIReichel, MEC w/a DDJohnson, MEC w/a 8406210061 840612 JIII 101904 66I PDR ADOCK 05000329 Av i S PDR / I i

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ITEM / HOLD POINT NOTIFICATION FORM i Sheet 1 of 2 TEM NUMBER HOLD POINT NUMBER STONE 4 WEBSTER 088

. CONSTRUCTION IMPLEMENTATION @ TRACKED ACTION ITEM OVERVIEW D TRACKED INFORMATION ITEM N/PIAND #vetEAR MANTJ.O. NO. /4509 0 TRACKED RECOMMENDATION ITEM REFERENCE (S) Checklists No, MP-MIS-096-005, MP-MIS-096- O UNTRACKED ITEM 006, MP-MIS-096-001 O HOLD POINT NOTIFICATION CONDITION DETAILS During the evaluation of Module 1200 in the Aux. Bldg., for release of Phase 2 work, l CIO noted the items listed on Sheet 2 that require response by CPCo. Please provide CIO with details of the corrective action which has been or will be for these items.

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l l PAGE O ves (~O s> 0 NO (See sheet 2 of 2) ATTACHMENTS DATE RESPONSE REQ'D. INI I O OT / / INITIATION PPROVED/DATE

N/A W W bfYf W jffb '

[-7~ 9Y RESPONSE (SEE NOTE) /

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Attached is our Complete response to thic item.

(PAGE O vES NoSi O NO

,3 ATTACHMENTS EST. CORRECTIVE ACTION RESPONDE TITLE -

DATE COMPLETION DATE w) . ,

f$ (sM M h,*.Y b 5 RESPONSE ACCEPTED DATE RESPONSE VERIFIED / CLOSED DATE l

NO7E - FOR TR AC'KED ACflOM ITEMS ONLY. EXPLAIN CLE ARLY OR REFERENCE Af f ACMutNTS FOR.

1) C AUSE OF OSSERVED COM0f fl0M 2) CORRECfivE ACTION T AMEN 3) PREVENilvE ACfl0N TAKEM L mh _

Item 088

.l . Sheet 2 of 2 Condition Details (Cont'd.):

1) Compliance with Procedure FPG-7.500 was not acceptable. Further, this procedure does not address in sufficient detail the present or intended methodology for completing the CCP.

2) Commodity lists provided to CIO contained many inaccuracies and incorrect information.

3) Administrative control of CCP Phase 1 activity was insufficient to assure accurate, complete, consistent results.

4) HVAC seismic support for cooler 2VM54A. The original QCIR, C304-317 W-1, lists six welders for the installation of this support. The QVP - QCIR, VCW1.00-10 documents six different welders for the same welds, these are actually marked on the base metal adjoining the appropriate welds.

The time of weld completion cannot be determined due to lack of rework documentation, thus the qualifications of the welders identified on the welds and in the QVP - QCIR, is indeterminate.

5)

During was verification of small bore support #FSK-M-2HBC-56-1-H2, the following noted:

H.R.P. Procedure N-20 Rev. I and Deviation Request #259 require (in-part) that item / attributes determined inaccessible by the implementing Q.C.E.'s. Supervisor shall be recorded in the CIIA Log.

Contrary to the above inaccessible items noted and concurred with in block 15 of PQCI-2.30 Rev. 5 were not recorded in the CIIA Log. Note QCIR was reviewed and accepted.

6) An unspecified angle.(L - 2" X 2" 7h") attached to the monorail in Module 120D was not addressed during status assessment activities nor was it documented on the punchlist as work to go.

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- -,- . . TRACKED ACTION ITEM 088

- ITEMS 1, 2, AND 3 CCP PROCEDURAL /PROGRAMM ATIC CHANGES The CIO evaluation of CCP activities in Module 120D identified several procedural and programmatic concerns. These are summarized as follows:

1) Compliance with Procedure FPG-7.500 during the Phase 1 activities

. in Module 120D_was not acceptable. Further, this procedure does not address in sufficient detail the present or intended methodo-logy for completing the CCP.

2) Commodity lists provided the CIO contained many inaccuracies and incorrect information.

3) A'dministrative control of CCP Phase 1 activity was insufficient to assure accurate, complete, consistant results.

In response to these concerns, we plan to modify our program and take action des-cribed as follows. The basis for performing Phase 1 activities and providing an in-tegrated statement of QVP and S/A results, for a system or area, will be a marked up set of drawings. Bechtel will be responsible for defining and providing a com-plete set of all applicable drawings prior to starting Phase I activities. The draw-ings provided will be similar to Status Assessment Prints (SAPS), with a " cut-off" date. For those commodities not completely defined on drawings, such as conduit sup-ports, Bechtel will provide a list. Bechtel and MPQAD will participate in an initial

" mark-up" meeting using these drawings, and other aides, such as MLCS, RVAC forms, walkdowns, etc. to define a complete Phase 1 division of responsibility. Phase 1 activities will then be performed by Bechtel and MPQAD using the same drawings as a basis. MLCS, MIRs and other systems will be updated throughout Phase 1. Any changes to the drawing basis during Phase 1 must be agreed upon by both MPQAD and

. Bechtel. ..

Before proceeding for the release to Phase 2, a final " mark-up" meeting will be held to verify completion of all Phase 1 activities. The final"end product" statement for Phase I will have a common Bechtel/MPQAD drawing mark-up as back-up detail i

to the FinalIntegrated Summary Statement, which is prepared as a management l - summary. MLCS, MIRs and other aides will also receive a final update.

It is planned to change FPG-7.500, FIG-7.520 and related flow charts to define and

_ proceduralize the process described above. For Phase 1 work already in progress, a "backfit" effort will be made to intrgrate the new drawing mark-up approach. It is expected that the required procedural changes can be completed in 2-3 weeks.

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BIIPeck 6/7/84 l

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TRACKED ACTION ITEM 088

• NOTE: This was previously DETAIL ITEM 4 transmitted to CIO via CPCo Transmittal No CSC-7845.

Prior to the inception of the CCP, changes which necessitated rework would L be implemente-d by construction without a formal notification to QC and without a formal "destatusing" of the existing inspection record to indicate that some of the completed attributes may have to be reinspected. After the rework was completed inspection would be requested and the existing record superseded by a new record. The times between initiation of change, completion  !

of rework a'nd reinspection could be substantial and since this process was interrupted by the work stoppage of December 1982, some existing inspection.

records do not reflect the reworked condition in the field. Thus, while [

reinspecting under the QVP, it is possible for the verification record to include data which are different from the existing record. '

s With t.he inception of the CCP all safety-related work and rework is managed by use of the-Construction Work Package, which integrates construction-ow& 'jf/ I and inspection activities. Prior to initiating rework a new inspection 3 .-

record is opened, thus reflecting the need for reinspection before the hardware J #f is actually changed.

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'To DDJohnson, SMO i k

Fnow JTChristy, MPQAD-QCD Consumers  :

Darc June 11, 1984 Power Susacci MIDLAND ENERGY CENTER PROJECT Company >

t STONE & WEBSTER TRACKED ACTION ITEM NO. 088, ITEM S [

INTenNAL F Con =cspoNocNec i MPQAD-QCM-84-113 CC MLHorseman The following is Quality Control's full and complete response to Stone & Webster's i Tracked Action Item No. 088, Item 5. f f

The fact that the inaccessible items noted in block 15 of the QCIR for small  ;

bore support FSK-M-2HBC-56-1-H2 were not recorded in the CIIA log was an oversight by the responsible Quality Control supervisor. The appropriate i entries in the CIIA log have now been completed in accordance with MPQAD Procedure N-20. Quality Control's investigation of this item indicates it was an isolated incident; accordingly, the supervisor has been cautioned to be more careful in the future.

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R2sp:nce to Peregrcph 6., Iton 088, S & W Itsc/ Hold Point Notificatian Form.

The unspecified angle (2 x 2 x7h) attached to the monrail in Module 120D has been determined to be a temporary attachment. Removal of the angle has been added to the Construction Punchlist, Area C0053, to satisfy the 120D CIO finding.

It is Construction's position that all temporary installations will be removed prior to system / area turnover or identified as a turnover exception (TOE) per our current program.

Procedures to be reviewed and revised as required by July 2, 1984. To clarify thus p'osition.

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