- _ _ _ _ - _ _ _ _ _ _ _ . . . . O Consumers Power James W Cook Vice PresiJnut - Projects, Engineesing and Construction General offices: 1945 West Parnell Road, Jackson, MI 49201 + (517) 788-0453 . February 10, 1984 83-09 #3 \ PRINC18f.LFfAFF RA* 0Ff(P ' ]{}E l Mr J G Keppler, Regional Ariministrator gjag US Nuclear Regulatory Commission A/RA /_ j dSF Region III iC~ / dea 799 Roosevelt Road P A_O / 1\S Glen Ellyn, IL 60137 gA/ y.LL_ _ _ _ _ 5 : Si re MIDI AND ENERGY CENTER DOCKET NOS 50-329 AND 50-330 REVIEW AND CONTROL OF Q LISTED DRAWINGS AND SPECIFICATIONS FILE: 0.4.9.81 SERIAL: 27998 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 This letter, as were the referenced letters, is an interim 10CFR50.55(e) report on a deficiency in the system for processing field changes involving project design documents. The attachments to this letter provide a description of the deficiency and the corrective actions being taken to resolve this problem. Another report, either interim or final, will be sent on or before April 6, 1984 | a , JWC/AHB/lr Attachment: (1) MCAR-73 Interim Report 3, dated January 19, 1981 CC: Document Control Desk, NRC Washington, DC RJCook, NRC Resident Inspector Midland Nuclear Plant DSHood, US NRC 8402220193 840210 {DRADOCK05000g2 _g Office of NRR res 151984 ;[ INP0 Records Center OC0184-0056A-MP01 i L . .
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O ConsumersPowerJames W CookVice PresiJnut - Projects, Engineesingand Construction
General offices: 1945 West Parnell Road, Jackson, MI 49201 + (517) 788-0453.
February 10, 1984 83-09 #3
\PRINC18f.LFfAFF
RA* 0Ff(P'
]{}ElMr J G Keppler, Regional Ariministrator gjag
US Nuclear Regulatory Commission A/RA /_ j dSFRegion III iC~ / dea799 Roosevelt Road P A_O / 1\SGlen Ellyn, IL 60137 gA/ y.LL_ _ _ _ _
5 : Si reMIDI AND ENERGY CENTERDOCKET NOS 50-329 AND 50-330REVIEW AND CONTROL OF Q LISTEDDRAWINGS AND SPECIFICATIONSFILE: 0.4.9.81 SERIAL: 27998
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
This letter, as were the referenced letters, is an interim 10CFR50.55(e)report on a deficiency in the system for processing field changes involvingproject design documents.
The attachments to this letter provide a description of the deficiency andthe corrective actions being taken to resolve this problem.
Another report, either interim or final, will be sent on or beforeApril 6, 1984
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JWC/AHB/lr
Attachment: (1) MCAR-73 Interim Report 3, dated January 19, 1981
DSHood, US NRC 8402220193 840210{DRADOCK05000g2 _gOffice of NRR
res 151984 ;[INP0 Records CenterOC0184-0056A-MP01 i
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,k 24
-Serial 2799883-09 #3
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OM/0L' SERVICE LIST'
Mr. Frank J Kelley- . Atomic Safety'&' Licensing; Attorney Ceneral of:the Appeal Board
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-State of Michigan- 'U S Nuclear Regulatory CommissionLMs Carole Steinberg, Esq -Washington, DC 20555Assistant Attorney'Ceneral
. Environmental Protection Division Mr C R Stephens (3)=720 Law Building. Chief. Docketing & ServicesLansing, MI 48913 U S Nuclear Regulatory Commission
Office of the SecretaryWashington, DC 20555
-Mr Myron M. Cherry, Esq.Suite 3700
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Ms Mary SinclairThree First National' Plaza 5711 Summerset StreetChicago, IL 60602 Midland, MI'48640
-Mr Wendell'H Marshall Mr William D Paton, EsqRFD 10h Counsel for the NRC Staff
: Midland, MI~48640 U S Nuclear Regulatory Commission, _ .
Washington, DC 20555:Mr Charles Bechhoefer, EsqAtomic Safety & Licensing Atomic Safety & Licensing
Board-Panel - Board PanelU S. Nuclear Regulatory Commission. U S Nuclear Regulatory CommissionWashington, DC 20555' Washington, DC 20555
~ Dr. Frederick P Cowan Ms Barbara Stamiris6152 N Verde Trail 5795 North River RoadApt-B-125 .
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Boca Raton, FL 33433. Freeland, MI 48623
I Mr Fred"C Williams Dr Jerry Harbour1 sham,-Lincoln &'Beale Atomic Safety & Licensing1120 Connecticut Ave, NW, Suite 325 Board PanelWashington, DC 20036 U S Nuclear Regulatory Commission
Washington, DC 20555
Mr James E Brunner, Esq' Mr M I Miller,~Esq,
JConsumers Power Company- Isham, Lincoln & Beale.212 West Michigan Avenue Three First National Plaza' Jackson, MIi49201 52nd Floor
Chicago, IL 60602
Mr D=F Judd Mr John Demeester, EsqBabcock & Wilcor. Dow Chemical Building.PO Box ~1260 Michigan DivisionLynchburg, VA 24505 Midland, MI 48640
Mr Steve Cadler, Esq Ms Lynne Bernebei2120 Carter Avenue Government Accountability ProjectLSt Paul, MN'55108 1901 Q Street, NW
PROJECT: Hidland Plant Units 1 and 2Consumers Power CompanyBechtel Job 7220
Introduction
This report addresses problems with inconsistent processing and review ofField Change Requests (FCRs)/ Field Change Notices (FCNs) against projectdesign docunents.
Description of Deficiency
It was found that in some cases project design change documents(FCRs/FCNs) were not attached to the proper base design documents orreviewed by the appropriate quality organization. (Ref: CPCo AuditMSA-83-32)
Bechtel Field Procedcres FPD-1.000, FPD-2.000, and FID-2.100, ProjectEngineering Procedure 4.62.1 and Administrative Departnent Procedure andInstruction ADP-2.12 and ADI 2.12.10 describe the process of initiating,reviewing, approving and processing FCRs and FCNs. Although theindividual organizations complied with their respective procedures, theoperations involved in these procedures were not fully integrated toachieve 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. (Ref: 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 consistentlyreviewed and indicated either approval or disapproval of the entries madeby field engineering in the "other drawings or specifications affected"block on the FCR and FCN forms. (The FCR and FCN forms are included as
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Interim Report 3i h n 9 0 t. Page 2w w 1
14023SAttachments 1 and 2.) Furthermore, field engineering assumed that ifdesign engineering did not comment on the entrice in the "other drawingsor specifications affected" block, design engineering concurred with theentries; however, this was not always the case.
Desiga engineering sometimes referenced related documents in the" remarks" block (which is reserved for design engineering use) on the FCRand FCN forms. The design office Document Control Center (DCC) keyedoniv on the " remarks" block for entering other related design documentsin the FCR/FCN registers. On the other hand, Field Document ControlCenter (FDCC) personnel keyed on documents listed in the "other drawingsand specifications affected" block, rather than the " remarks" block,whether or not the " remarks" block mentioned other documents.
PEP 4.62.1 identified the requirement for quality organization review ofFCRs/FCNe to Q-listed specifications. In some cases FCRs/FCNs werewritten against Q or non-Q documents and then other Q-listedspecificatiens were added to the "other drawings or specificationsaffected" block or the " remarks" block without obtaining the appropriatequality organization review and approval for the added Q-listed documents.
Analysis of Safety Implication ,
As described in the corrective action section of this report, all FCRswith at least resident (des'gn) engineering interim approval and all FCNswith at least project field engineering approval have been reviewed to |
6determine the base design documents that they should be posted against.These FCRs and FCNs have also been reviewed to identify those cases wherc |the quality organization review and approval was required but notperf o rmed . Appropriate review and approvals have been obtained. The | c
above reviews have included an evaluation as to the possibility ofincorrect hardware installation.
While there was a lack of integration between the procedures describedpreviously, no safety concern has been identified at this time.Consumers Power Company (CPCo) has reported this item to the NRC underthe rules of 10CFR50.55(e) on October 22, 1983.
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MCAR 73Interim Response 3
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Root Cause '
The root cause was the lack of integration between field procedures /instructions FPD-1.000, FFD-2.000, and FID-2.100, Project Engineering
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Procedure (PEP) 4.62.1 and Administrative Department Procedure ADP-2.12and Administrative Department Instruction ADI 2.12.10, which govern theinitiation, review, approval, and processing of FCRs and FCNs.
Corrective Action
1. A program has been established and documented in FCR/FCN Review andResolution Program (FID-2.400) to: a) identify the proper basedesign documents which the YCR and FCNs are to posted against, b)encure required quality organization review and approvals wereobtained, and c) to evaluate whether or not any lack of the aboveresulted in hardware deficiencies. The program also provides foroverview and verification by the Midland Project Quality AssuranceDepartment of these actions. To date, each of the 52,627 FCRs andFCNs have been reviewed under this program. From this review, a <
total of 10 NCRs have been initiated and are under appropriate reviewat this time. This review will include evaluation of safety concerns.
In addition to this program, the Field Procedures, ProjectEngineering Procedures and Administrative Department Instructions andProcedures associated with FCRs and 7CNs have been reviewed andrevised as necessary to provide integration. Bechtel personnel havebeen instructed in the use of these revised procedures in accordancewith their departments' respective training procedures. .I
Actions are now underway to provide that FCRs/FCNs are posted againstthe proper controlled design documents on the Midland project.
2. Review Bechtel department procedures (e.g., Administrative Services,Project Engineering, Construction) for consistency at points ofinterface with each other and Consumers Power Company procedures, andidentify and correct any potential problems similar to the FCR/FCNinterface problem. A system to maintain this integration shall alsobe developed.
A plan describing steps to accomplish this review together with aschedule for accomplishing the plan has been developed and is underreview. Upon approval, the plan will be attached to the next report.
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Interim Report 3,
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140239Reportability
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The conditions described in this report were reported to the NRC bytelecon under the rules of 10CFR50.55(e) on Octo r 22, 1983.
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*//l[ts/ Submitted by* es -M_-
#AssistantProjectManager. C Boos
Approved by: - d- ',
. Poser.
Project Engineering Manager
Concurrence by: * AdE.H. SmithEngineering Manager
Concurrence by:.
b bd'r(er- M. A. Dietrich /
Project Quality Assurance Engineer
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