ML20197G955

Summarizes 840518-0604 Const Implementation Overview Evaluation of Results of Const Completion Program Phase I Activity in Module 120D (Auxiliary Feedwater Pump Room) & Preparations for Phase 2 Work

ML20197G955
Person / Time
Site:	Midland
Issue date:	06/07/1984
From:	Karr J STONE & WEBSTER, INC.
To:	Quamme D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
SWM-140, NUDOCS 8406180226
Download: ML20197G955 (14)

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STONE & WEBSTER MICHIGAN, IN. pg pc\\PAb)[#

RA 11 P. O. Box 1963. MIDLAND, MI 48641-1963 J/RA M

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Mr. D. L. Qua m e June 7, 1984 Consumers Power Company Midland Nuclear Power Plant J.0. No. 14509 3500 E. Miller Road SWM-140 Midland, MI 48640 Docket No. 50-329/330

'CIO Evaluation of Construction Completion Program (CCP)

Activities in Module 120D Construction Implementation Overview Midland Nuclear Power Plant Between May 18 and June 4, 1984 CIO conducted an evaluation of the results of CCP Phase 1 activity in Module 120D (Auxiliary Feedwater Pump Room) and the preparations for commencing Phase 2 work in this module.

The evaluation was conducted in order to determine whether CIO Hold Point Number 007 could be lifted for Module 120D and included:

Evaluation of the Executive Management Review Comittee Meeting on May 18, 1984.

Review of program descriptions and procedures for adequacy and implementation.

Verification of all hardware in the module for location, orientation and final inspection attributes.

Verification of supporting documentation for a representative sample of hardware.

Evaluation of methods and management tools used to integrate Phase 1 results.

Review of open CIO Items and NIRs to determine whether there was any inpact on Module 1200.

Verification that procedures were available, personnel were trained (and certified where necessary) and preparations were in order to begin Phase 2 work.

Individual issues identified during the evaluation have been documented on CIO Item 088 and NIRs 034, 035, and 036 which are forwarded as attachments to this letter.

Item 088 describes general or programatic concerns and the NIRs group specific discrepancies into categories relative to plant hardware, procedural violations and documentation discrepancies.

The assignment of a specific line item to each category is somewhat subjective but was done for reporting purposes based upon the principal area of concern.

It is noted that during the course of the evaluation, MPQAD issued and began processing NCRs and/or QARs which address many of the discrepancies identified by CIO.

Where this is the case the NCR or QAR number has been included for reference purposes and to assist in trackina the reports to closure.

8406180226 840607

%M PDR ADOCK 05000329 Mi S

PDR lall

6, DLQ 2

June 7, 1984 The procedures governing CCP activities should describe the methodology for CCP implementation and the required activities of each interfacing organization in sufficient detail that implementation will result in accurate statements of plant status and to-go work.

Sufficient administrative controls must also be provided to assure procedural implementation and coordination between performing organizations.

With sufficiently detailed procedures in place, implementation must be closely administered by first and second line supervision to preclude incomplete or incorrect implementation and to assure that management is provided with clear and accurate information on plant status.

The major issue resulting from the evaluation is the lack of thesa essential elements of the CCP for Module 1200. Many of the deficiencies identified by CIO are either directly or indirectly attributable to this item.

The governing procedure during the CIO evaluation (FPG 7.500) defined the development, refinement and finalization of a " Commodity List" as the principal scoping document for accumulation of Phase 1 information.

However, i

during the course of the CIO evaluation it became clear that different organizations were developing and/or using different listings of comodities so the refinement of the " Commodity List" did not occur.

From further discussion with BPCo personnel, it appears that the MLCS produced list of commodities is the intended basis for scoping.

This is inconsistent with the present procedural descriptions.

Additionally, sufficient detail is not

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provided on the specific means for implementing the procedures and the methods h

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to be used by organizations other t an t ose per orm ng s a us assessmen.

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CIO has reviewed-draft revisions of FPG 7.500 and the most recent issue of FIG-7.520 which do refer to MLCS and define the role of BPCo in arriving at a finalized plant status.

These procedures, or others, also must address in detail the role of MPQAD and, for a complete list of comodities, should provide direction on status identification for those turned-over items in i

control of GSO.

l The hardware discrepancies identified by CIO are not considered to l

significantly impact plant safety or performance and in general, plant hardware is considered _to be in an acceptable condition.

The specifics should have been identified and documented through the CCP activities, however.

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l Several issues were identified during this evaluation that CIO will pursue as

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separate topics since they are overall plant programs rather than CCP or l

Module 1200 specific.

These relate to perimeter control, material L

traceability, procurement documentation, generic NCRs, the disposition ~ of items ~ in the plant, ' but removed from the design, and rework control.

Each of l

these areas has been identified in the past by various organizations and-sufficient information may exist to allow CIO to close the issues.

In ~ conclusion, the procedural and administrative controls evaluated were insufficient to provide accurate, complete information on plant status.

However, at the present time CIO -is confident that when the corrective action 7

on identified deficiencies 'is completed, an accurate status of Module 120D j

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June 7, 1984 1

will exist. Further, other aspects of the CIO evaluation have been satisfactorily completed and in-process procedures and controls exist to provide confidence that Phase 2 activities can be completed properly and since programmatic issues raised by CIO cannot be resolved for Module 120D CIO Hold Point 007 for this Module is lifted.

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It would be inappropriate, however, to pursue further Phase 2 work until the programmatic issues are satisfactorily resolved.. CIO will review the i

resolutions to these issues and verify implementation prior to releasing Hold Point 007 for further work.

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CIO Program Manager j

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JGKeppler, US-NRC-~ Glen Ellyn,.-IL~

NIReichel, CPCo Midland (site)

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RAWells, CPCo Midland (site) i JJHarrison, US NRC Glen Ellyn, IL BLBurgess, US NRC Midland (site) t I

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ITEM / HOLD POINT NOTIFICATION FORM Sheet 1 of 2 ITEM NUMBER HOLD POINT NUMBER STONE & WEBSTER a

088 CONSTRUCTION IMPLEMENTATION

@ TRACKED ACTION ITEM OVERVIEW O TRACKED INFORMATION ITEM N/Pl4NP nuclear MANTJ.0, No. /4509 0 TRACKED RECOMMENDATION ITEM:

i REFERENCE (S) Checkli sts No. MP-MIS-096-005, MP-MIS-09b-O UNTRACKED ITEM 006, MP-MIS-096-001 O HOLD POINT NOTIFICATlON l

CONDITION DETAILS l During the evaluation of Module 120D in the Aux. Bldg., for release of Phase 2 work, CIO noted the items listed on Sheet 2 that require response by CPCo.

Please provide J

j CIO with details of the corrective action which has been or will be for these items.

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I (P AGE b NO i

O YES NO'S)

(See sheet 2 of 2)

ATTACHMENTS l

DATE RESPONSE REQ'D.

INI 1 /0 D T' INITIATION PPROVED/DATE Jb/Y Y

Q-SY

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N/A

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RESPONSE (SEE NOTE) i i

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(PAGE O YES NO3)

NO ATTACHMENTS EST. CORRECTIVE ACTION RESPONDENT TITLE DATE

. COMPLETlON DATE l

RESPONSE ACCEPTED DATE RESPONSE VERIFIED / CLOSED DATE f

NOTE

• FOR TRACMED ACTION ITEMS CMLY EXPLAIN CLEARLY OR REFERENCE ATTACHMENTS FOR:

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..)) C AUSE OF_OSSERVED CONDITroM 2) CORRECTIVE ACTION T AKEN_3) PREVENTIVE AC,TlCN TAMEN

Item 088 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 fritended 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 verification of small bore support #FSK-M-2HBC-56-1-H2, the following was noted:

H.R.P. Procedure N-20 Rev. I and Deviation Reques-t #259 require (in part) that jtem/ 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" ?? ") attached to the monorail in Module 3

1200 was not addressed during status assessment activities nor was it documented on the punchlist as work to go.

(KA)

SHEET 1 OF 3 l

STONE AND WEBSTER MICHIGAN, INC.

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NONCONFORMANCE IDENTIFICATION REPORT (NIR)

I DATE NONCONFORMANCE OBSERVED CHECKUST NO.

MR NO.

6/5/84 034 l

lDENTIFICATION AND LOCATION OF ITEMS /DOCUENTS/ ACTIVITY:

l Aux. Bldg. Module 120D 1

I DESCRIPTION OF NONCONFORMANCE i

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i During CIO verification of hardware for QVP and status assessment of Module 1200, several nonconforming conditions were observed.

For a description of l

these conditions, see sheet 2 through 3.

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• MP-MIS-097-005 MP-MIS-096-001 MP-MIS-097-004 l

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b-s INITIATOR REVIEWER

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DATE DATE CORRECTIVE ACTION TAKEN

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ACTION VERIFIED: SAT.O UNSAT.O NEW NIR NO.

CONCURRENCE BY CIO PROGRAM MANAGER ClO INSPECTOR:

DATE DATE DATE CIO REMARKS

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M R 034 Sheet 2 of 3 1 - 8" ASME III Class pipe spool #2HBC-22-5-634-4-4 has been removed from line.

1. 2HBC-22 (Dwg. #M-634-4 Rev. 12) and is laying on the module floor, in water, uncapped.

This is contrary to the requirements of Spec. M204, Para.

6.4.2.

(NCR #C-04218 issued 5/31/84) 2 - During verification of small bore supports, the following was noted:

PQCI-P-2.30, Rev. 5 states in part:

verify overall orientation and configuration of support in respect to hanger sketch, etc.

A.

Contrary to the above, a non Q support is attached to FSK-M-2HBC-552-1-H1 and not shown on the hanger sketch nor docu-mented on the related NCR.

B.

Support FSK-M-2HBC-552-1-H3 same as above.

3 - The 4" pipe clamp on support 00603 for conduit 2AC075 has a crack at the unistrut and the conduit identification is stenciled under the 4" clamp at support 00603 making the identification not completely visible.

NCR C-04359 was issued during verification to cover these conditions.

4 - Conduit 2AC090 is less than 1" from non-class' lighting conduit and conduit 2AC153 is less than 1" from an unidentified conduit. NCR's C-04350 and C-04388, respectively were issued during verification to cover these con-ditions.

5 - A piece of 2" X 2" tube steel was tied off to conduit 2AC131.

NCR C-04351 was issued during verification to cover this condition.

6 - The configuration of support No. 00597 does not coincide with the details in drawing E-428.

NCR C04352 was issued during verification to cover this condition.

7 - Support No. 01413 is mounted to the ribbed section of the ceiling in a manner that is not in accordance with drawing E-428.

8 - Support No. 00597 welds have' splatter.

This condition is not covered by NCR C03078.

NCR C03078 will be revised to cover this condition.

9 - Support No. 00843 welds have arc strikes and undercut.

10 - Support No. 00830 welds have splatter, arc strikes, and pin holes.

11 - The spring nut for support No.14995 is not seated on the unistrut and the strap for the same support is resting on the weld.

12 - The following conduit supports have rust on them:

(JMR) i

NIR 034 Sheet 3 of 3 00608 00827 00609 00830 00821 00837 00823 00838 13 - The following equipment was found to be dirty:

2S10A 2LSH9411 25108 2AJ359 2AJ460 2EJ372 2AJ361 Unscheduled Box (2EC019)

Unscheduled Box (28J8048)

' 14 - Box covers are not installed on the following junction boxes:

2AJ460 2EJ372 2AJ361 2AJ359 i

15 - There is rust in level switch 2LSH9411.

16 - For the following conduits, I.D.s are not legiblehisible or are missing:

2AC034 2AC165 2AC054 2AC166 2AC055 2AE054 2AC118 28J8041 2AC147 2EC011 2AC151 2EC019 17 - Conduit No. 2AC118 has rust on exterior surface.

18 - Unscheduled pull box (at conduits 2EC019 to 2510A) has a hole drilled 1

in bottom of box.

19 - Conduits 2AC106 and 2AC131 are being used as supports for "non-Q" conduit and tube steel respectively.

20 Conduits 2AC090 and 2AC174 have missing condulets covers.

I 21 - Conduits 28J8041 and 28J8074 have loose /impr.operly installed hardware.

22 - Conduit 2EC001 is not protected against construction activities.

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(KA) 1 l

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l SHEET 1 OF 2 STONE AND WEBSTER MICHIGAN, INC.

NONCONFORMANCE IDENTIFICATION REPORT (NIR)

DATE NONCONFORMANCE OBSERVED CHECKLIST NO.

NIR NO.

6/5/84 035 l

IDENTIFICATION AND LOCATION OF ITEMS /DOCUNENTS/ ACTIVITY:

Aux. Bldg. Module 1200 mr DESCRIPTION OF NONCONFORMANCE l

I During CIO verification of documentation for QVP and' status assessment of Module 1200, several nonconforming conditions were observed.

For a description of these conditions, see sheet 2.

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• MP-MIS-096-009 MP-MIS-097-005 i

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INITIATOR.

b REVIEWER 6*78[

DATE DATE l

l CORRECTIVE ACTION TAKEN I

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ACTION VERIFIED: SAT.O UNSAT.O NEW NIR NO.

CONCURRENCE BY ClO PROGRAM MANAGER ClO INSPECTOR:

DATE DATE DATE

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CIO FEMARKS 0

NIR 035 Sheet 2 of 2 1

-1)

FSK-M-2HBC-55-1 Rev. 10 shows penetration #45 to be grouted.

2) FSK-M-2HBC-56-1 Rev.10 shows penetration #46 to be grouted.

l 3)

FSK-M-2HBC-183-4 Rev. 6 shows, penetration #29 to be grouted.

4) FSK-M-2HBC-184-4 Rev. 7 shows penetration #30 to be grouted.

a)

Items 1-4 above are not grouted.

b) The above FSK's refer to the penetrations by the wrong numbers, as follows.

1 - FSK reference to #45 is actually #215.

l 2 - FSK reference to #46 is actually #214.

3 - FSK reference to #29 is actually #350.

4 - FSK reference to #30 has not been shown on A-861 sheet 6.

2 - Civil / Structural Verification QCIR's are not properly completed.

Examples are:

1) Corrections not initiated and dated.

2) Scope / location of NIR's either not correct or not sufficient to verify activity covered by the NIR.

3) Writeovers.

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Inspector ID Numbers not listed.

5) Conflicting entries within the same block on the NIR's.

6) NIR Number and page numbers not listed correctly.

7)

Hold points not <hown as N/A.

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8) NCR Number not recorded in proper location.

9)

NCR not referencing NIR's to which it applies.

10)

Generic NCR's not referenced.

l 11)

Required supplemental data sheets not attached to t!'e NIR's.

3 - Electrical verification QCIR's are not properly completed (i.e. Blocks not filled in correctly, descriptions incorrect, typo errors, activities marked N/A that should be verified, incorrect IR Numbart, etc.).

(JMR)

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SHEET 1 OF 4

STONE AND WEBSTER MICHIGAN, INC.

i NONCONFORMANCE IDENTIFICATION REPORT (NIR)

DATE NONCONFORMANCE OBSERVED CHECKLIST NO.

NIR N O.

6-5-84 036 IDENTIFICATION AND LOCATION OF ITEMS / DOCUMENTS / ACTIVITY:

Auxiliary Building Module 1200 l

DESCRIPTION OF NONCONFORMANCE Ourtnc CIO verification of Programs / Procedures for QVP and Status Assessment of l

Module 1200 several nonconforming conditions were observed.

For a description of j

these conditions see Sheets 2 through 4.

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i MP-MIS-096-009 MP-MIS-096-013 l

MP-MIS-097-002 MP-MIS-096-012 MP-MIS-097-005 l

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I REVIEWER lNITIATOR b

DATE DATE l

CORRECTIVE ACTION TAKEN l

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i ACTION VERIFIED: SAT.O UNSAT.O NEW NIR NO.

CONCURRENCE BY CIO PROGRAM MANAGER ClO INSPECTOR.

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DATE DATE DATE

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l CIO REMARKS l

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w NIR 036 Sheet 2 of 4

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1.

FSK-M-2HBC-184-4 Rev.

7, Detail 1.

The orifice flange between field welds Nos.

18 and 19 is shown as having two 1/2" taps welded to the West side of the flange and two 1/2" plugs on the East.

In the field the opposite is

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true, the taps are on the East side and the plugs are on the West.

The following QCIRs cover the four welds and Activity 3.16 " Orientation and Configuration" are signed as acceptable on each.

1)

VP190-FSK-M-2HBC-184-4-40 Rev. 1 2)

VP190-FSK-M-2HBC-184-4-41 Rev. 1 3)

VP190-FSK-M-2HBC-184-4-46 Rev. 1 4)

VP190-FSK-M-2HBC-184-4-47 Rev. 1 (NCR #C-04253 and QAR #RC-00632 issued) 2.-

FSM-M-2HBC-184-4 Rev. 7 1)

The flange at drawing location B-55 has no gasket installed.

2)

The flange at drawing location B-65 has no gasket installed and has two bolts missing.

No irs were ever initiated on these two flanges.

Therefore no QVP or status assessment was ever performed.

Work-to-go on these flanges did not appear on the construction punchlist.

3.

QCIR # FSK-DV1-M-634-4-58 was closed for FW58 (Line 2HBC-22) on August 25, 1981.

In June 1983 a redesign eliminated FW-58 from this system and from FSK-DVI-M-634-4.

FW-58 exists in the field, is listed on the Q Commodity List and has a closed IR against it.

No QVP was performed.

Because FW-58 was not shown on the current revision of the drawing MPQAD simply wrote and issued an NCR (C-02718),

stating that this is not a specified weld.

Although no VP-1.90 QCIR was scoped, the NCR states that Activity 3.101 (No unspecified welds were added) of P-1.90 is the discrepancy.

4.

Drawing M-634-4 Rev. 12, Line 8"-2HBC-22, FW-14.

NCR #C-02526 is a generic NCR written against welder qualifications.

The results of welder qualification tests are to be recorded on a Bechtel

" Welder Qualification Test Record", Form WR-1.

Records show that Welder P-36 made FW-14

However, there is no WR-1 form on record for Welder P-36 covering the time period that the above referenced FW-14 was made, therefore the welder's qualification can not be verified.

Activity 3.7

" Welder's Qualification" on QCIR # VP190-M-634-4-14 is initialed acceptable with no reference to NCR# C-02526.

(QAR RC-00613V was issued) 500-038(EK)

NIR 036 Sheet 3 of 4 5.

During verification of large bore support #2-634-4-2 the following was noted.

PQCI-P-2.30 Rev. 5 and CN # P-2.30-05-2 states, in part:

Review the following documents, applicable to this hanger, to verify that the required quality documentation has been completed and is acceptable.

Previous C-1.10 reports, previous NCRs, etc.

1. Contrary to the above, C-1.10-815 and V-C-1.10-52 were not documented in QCIR Activity 3.18.6.

2. Contrary to the above.

NCR #00960 applicable to this hanger was not documented in QCIR Activity 3.18.9.

Notr.:

NCR#00960 renders the quality of groisted anchor bolts indeterminate.

(Generic NCR).

6.

The following Items were not addressed by the Quality Verification Program or the Status Assessment Program:

1)

Grouted Anchor Bolts for the Monorail Base Plate 2)

Grouted A7chor Bolts and Grout Pad for Hanger No. 2-634-5-118 3)

Grouted Installation of Conduit No. 2 AC034 in the North Wall.

4)

Grouted Installaticn of Conduit No. 2 AC165 in the West Wall.

5)

Grouted Installation of Conduit No. 2 AC172 in the South Wall.

6)

Grouted Installation of 4 Instrument Tubing supports for Instrument Tubing runnir.] to instruments 2PT39000 A1, A2, A3, and A4.

Items 1, 3, 4, and 6 were addressed by MPQAD on NCR No. C-04312-V.

Items No.

2 was addressed by MPQAD on Verification Inspection Report (VIR) No. V-C-1.10-113.

7.

VIR No.

V-C-1.10-51 references IR No. C-1.10-489 as the original IR to which the VIR corresponds for reinspection.

IR No.

C-1.10-1324 also addresses the same Inspection, but this IR is not referenced by the VIR.

8.

VIR No.

V-C-1.10-57, Activity 3.0A indicated that a DIIA has been initiated and the en. tire grout placement is inaccessible for reinspection.

A portion of this placement is accessible and therefore should have been inspected.

9.

VIR No. V-C-1.10-54, lines indicates that the grout placement for Conduit No.

2AC156 was inspected.

The conduit grouted at the location given on Line 6 of the VIR is actually Number 2AC174.

500-038(EK)

NIR 036 Sheet 4 of 4 10.

PQCI E-1.2, Rev.

2, Section B, Paragraph 4 states, "If, during the verification of activity 3.2B, identification numbers on the fittings are not present or visible, the QCE shall attach to the IR a copy of the appropriate page of the vendor catalog used to assure correct fitting was installed.

A reference to this page shall be made in Block 15 of the IR."

Contrary to the above, the spring nuts for the following supports are not identified and the inspection reports do not contain the appropriate page of the Vendor catalog:

00612 00613 00614 00615 00616 11.

There are no provisions in the QCIRs or PQCI E1.0 to verify the bend radius of scheduled flexible conduits.

12.

Conduit 2AC034 and support 00604 were not status assessed.

QAR RC-00621V, Rev 1, and NCR C04278 were issued.

13.

The training records for one CPCo individual were not in accordance with CPCo's training matrix.

500-038(EK)

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