ML20093D204
| ML20093D204 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/29/1984 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20093D207 | List: |
| References | |
| 30344, 83-09-#5, 83-9-#5, NUDOCS 8407160173 | |
| Download: ML20093D204 (10) | |
Text
l OC0llSumBIS Power James W Cook C0mO Y
Vice President ~ Projects, Engineering u
and Construction General offues: 1945 West Parnell Road, Jackson, MI 49201 * (517) 788-0453 June 29, 1984 83-09 #5 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER PROJECT DOCKET NOS 50-329 AND 50-330 REVIEW AND CONTROL OF Q LISTED DRAWINGS AND SPECIFICATIONS FILE:
0.4.9.81 SERIAL:
30344
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
- 4) Serial 28075, dated April 6, 1984 This letter 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 description of the deficiency and the corrective actions being taken to resolve this problem. Future reports will provide the results of the remaining corrective actions.
It is noted that the completed extensive investigations have not found any hardware discrepancies representative of reportable safety concerns.
Another report, either interim or final, will be sent on or before December 31, 1984.
JWC/AHB/cd
Attachment:
- 1) MCAR-73 Final Report, dated June 20, 1984.
g\\h CC: Document Control Desk, NRC Midland NRC Resident Office 3%\\,,
Washington, DC Midland Nuclear Plant DSHood, USNRC Office of NRR INPO Records Center OC0684-0046A-MP01 "T g o /
8407160173 840629 PDR ADOCK 05000329 g\\
S PDR
~,
2 83-09 # 5 Serial 303hh OM/0L SERVICE LISE Mr Frank J Kelley Atomic Safety & Licensing Attorney General of the Appeal Board State of Michigan U S Nuclear Regulatory Commission Ms Carole Steinberg Washington, DC 20555 Assistant Attorney General Environmental Protection Division Mr C R Stephens (3) 720 Law Building Chief, Docketing & Services Lansing, MI 48913 U S Nuclear Regulatory Commissicn Office of the Secretary Washington, DC 20555 Mr Myron M Cherry, Esq Suite 3700 Ms Mary Sinclair Three First National Plaza 5711 Summeract 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 Washington, DC 20555 Mr Charles Bechhoefer, Esq Atomic Safety & Licensing Atomic Safety & Licensing Board Panel Board Panel U S Nuclear Regulatory Commission U S Nuclear Regulatory Commission East-West Towers, Room E-413 Washington, DC 20555 Bethesda, MD 20014 Ms Barbara Stamaris Dr Frederick P Cowan 5795 North River Road 6152 N Verde Trail Rt 3 Apt B-125 Freeland, MI 48623 Boca Raton, FL 33433 Dr Jerry Harbour 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, Room E-454 Bethesda, MD 20014 Mr James E Brunner, Esq Consumers Power Company Mr M I Miller, Esq 212 West Michigan Avenue Isham, Lincoln & Beale Jackson, MI 49201 Three First National Plaza 52nd Floor Chicago, IL 60602 OC0684-0046A-MP01
3 83-09 # 5 Serial 303hh Mr D F Judd Babcock & Wilcox PO Box 1260 Mr John Demeester, Esq Lynchburg, VA 24505 Dow Chemical Building Michigan Division Mr Steve Gadler, Esq Midland MI 48640 2120 Carter Avenue St Paul, MN 55108 Ms Lynne Bernabei 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 OC0684-0046A-!!P01
r~
- ~
154086 153S96 seri 1 303h4
SUBJECT:
NCAR 73 FINAL REPORT DATE:
June 20, 1984 PROJECT: Midland Plant Units 1 and 2 Consumers Power Company Bechtel Job 7220 Introduction 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 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)
Bechtel Field Procedurca 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 organizations complied with their respective procedures, the 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 design documents. (Reft CPCo Audit MSA-83-32) b) In some cases quality organization review of FCRs/FCNs affecting Q-related design documents were not performed where required.
(Ref:
CPCo Audit MSA-83-32)
Historical Background and Summary of Investigation 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
184086
{+
P
-MCAR 73 i53998 Fina1 Report l
Page 2
(
[
i Attachments 1 and 2.) Furthermore, field engineering assumed that if I
design engineering did not comment on the entries in the "other drawings or specifications affacted" 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 reserved for design engineering use) on the FCR i
and FCN fqrms. The design office Document Control Center (DCC) keyed I
only on the " remarks" block for entering other related design documents
[
in the FCR/FCN registers. On the other hand, Field Document Control t
Center (FDCC) personnel keyed on documents listed in the "other drawings
[
sad specifications affeeted" block, rather than the " remarks" block, i
whether or not the " remarks" block mentioned other documents.
i PEP 4.62.1 identified the requirement for qvslity 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 specifications were added to the "other drawings or specifications i
affected" block or the " remarks" block without obtaining the appropriate quality organization review and approval for the added Q-listed documents.
[
l Analysis of Safety Implication t
As described in the corrective action section of this report, all FCRs f
with at least resident (design) engineering interim approval and all FCNs with at least project field engineering approval have been reviewed to i
determine the base design documents that they should be posted against.
t These FCRs and FCNs 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 l
incorrect hardware installation.
j f
While there was a lack of integration between the procedures described i
previously, no safety concerns were identified.
L Root Cause t
I The root cause was the lack of integration between field procedures /
l
' 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.
i r
t t
i I
l I
I
MCAR 73 I54086 153SS8 3
Corrective Action
-1.
A program was 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) ensure required quality organization review and approvals were obtained, and c) to evaluate whether or not any lack of the above resulted in hardware deficiencies. The program also provided for overview and verification by the Midland Project Quality Assurance Department of these actions. A total of 52,627 FCRs and FCNs were reviewed under this program. From this review, a total of 10 NCRs (see Attachment 3) were initiated and reviewed and it was determined that no safety concerns exist.
Associated with the resolution of the FCR/FCN process, related document control activity problems (e.g., improper attached documents, etc.) were identified and were documented via MPQAD MCAR/R DAT-1.
In addition to the foregoing, the Field Procedures, Project Engineering Procedures and Administrative Department Instructions and Procedures associated with FCRs and FCNs have been reviewed and 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 procedures.
Actions to provide that FCRs/FCNs are posted against the proper controlled design documents on the Midland project have been taken and are now complete.
2.
A full scope audit (MSA-84-5) was performed by Midland Project Quality Assurance Department, Site Audit Branch, on February 27, 1984
- March 30, 1984. The objective of this audit was to evaluate the adequacy and implementation of Bechtel Power Corporation's design and design change control activities. It was concluded that the design change program does contain the required elements of a proper program. Seven findings and 1 unresolved item were issued to address programmatic concerns in the design change process. These findings and unresolved item are being resolved and corrective action provided by project engineering. This activity is scheduled to be completed by October 31, 1984, and will be tracked by the Quality Action Item List.
3.
An interface program procedure was added to the project procedure manual (reference attached procedure, Part IV, Section 17, issued April 30, 1984) to review the following:
~
MCAR 73 Final Report ISM rase 4 154086
- 1. Bechtel project quality related procedures for consistancy at points of interface with each other and interfacing Consumers Power Company's procedures.
- 2. Potential problems similar to the FCR/FCN interface problem.
l This program is currently being implemented in two phases.
The first phase involves investigations of known concerns. Thirty-two areas have been identified that require investigation. The investigation of these 32 areas and their associated corrective actions are scheduled to be completed October 22, 1984. Any additional concerns identified during this phase will be investigated, tracked, and corrected under this I
program.
The second phase addresses the interface review effort that is currently taking place. Eighty-six quality related processes have been identified by the procedure interface team. Of these, 14 were selected by the procedure interface steering committee for interface review. The last interface review is scheduled to be complete September 4, 1984. All corrective actions are scheduled to be complete December 31, 1984.
Reportability The conditions described in this report were reported to the NRC by telecon under the rules of 10CFR50.55(e), as reportable on October 22, 1983.
Submitted by:
.J.
Boos Assistan Project Manager Approved by:
eet E.~B. Poser Prgect gin e ing Manager j
Approved by:
2m
.H. fmith V J
Engineering Manager Concurrence by:
l g
jet M. A. DietMch Project Quality Assurance Engineer Attachments:
- 1. FCR Form
- 2. FCN Form
- 3. NCR List
- 4. Interface Control for Inter-organizational Processes Procedure TJS/h1 120103
--~
53998 i
i t
i 54 oHELD CHANGE REQUEST
~
s
- 4..
.a
. n.
,,m e
.v 7220 0
sa_u as easPr.eas av ame mata cmamos rea e s==rwas as.e mass o 5, m teo o,-
r M.OrtfSS S A*Pepygg 8
eca M vs O me 0 e,C4 24Ouiatg aan ll RfAsosepoaCMAaena e
ExisTlasG COpectT10se l
l OESCALPTION OF CMApeGE i
l l
I i
l
\\
INTERIM APPROVAL BY SIGN AAC CONTACT: DATT RESIDENT ENGNEER:
DATT Naadt
{
- Tasm ovat eLacTascaA asTasmasarAnose nas chawcAL reuse weta= con t
spe'48 OS D*
g Ofwt85 cs C880CT13 9803857 Mf _LS L DE l
t O ?
- a gy
_r4Cegypv gU Q
yppyp.
=...
1 t
l a.......
~...,,. -.. -,,.. -,, _ _ _.... - _..,.... - - _ _ _. _
~
r A u.= c - c 2 j-154n96 t s o o n c.
IFittDlicHANGE NO.TlCE l
m.2 l
,,,=- =a g g y.
{
wu.
ac
.s
.m....
~
. 'aa
- v. o o
we --
f EK35Tlase CQaa04 TION l
t o
OESCAAFTION OF CMAaeGE 4
I I
\\
l 1
t i
I l
l I
OTw4e Crvik 8 t& cts gab es2 asmaaxTATulpe angewsacAh MMae a r t.s so a puuGS SA UTh!ma yocs i
&## tCT S y
{
pescasoev l
)
eiets toe Cm e C a 8 8.T j
l
\\
i en an WCT smenes sa s4=ATues m oars
=a 0
- aovia vis ao
..~..
l l
ese ro om es,es i
i
154086 153998 to MCAR 73 10 NCRs ISSUED C-00913 H-00113-ZZ I
C-00024 H-00134-ZZ C-00933 H-00135-ZZ C-00934 H-00175-ZZ C-00935 H-00176-ZZ 120103 l
l l
l
..