ML19253C533

Responds to NRC 791010 Ltr Re Violations Noted in IE Insp Repts 50-329/79-20 & 50-330/79-20.Corrective Actions: Procedures Re Formal Design Changes Revised by Bechtel

ML19253C533
Person / Time
Site:	Midland
Issue date:	11/06/1979
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19253C532	List: ML19253C533
References
HOWE-289-79, NUDOCS 7912060015
Download: ML19253C533 (3)

Text

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Consumers Power Stephen H. Howell Senior Vsce Presdent General Of fices: 1945 West Pernall Rosa, Jackson, Michigan 49201 * (517) 788-0453 November 6, 1979 Hove-289-79 Mr J G Keppler, Regional Director Office of Inspection and Enforcement US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR PLANT -

INSPECTION REPORT No 50-329/79-20ANDNO50-330/79-20 The enclosure to this letter is a response to your letter of October 10, 1979, which transmitted the subject Inspection Report and which requested our written statement on an item of noncompliance.

-  :--WI wRs/lr

Enclosure:

Consumers Power Company's Response to Inspection Report No 50-329/79-20 and No 50-330/79-20 1506 355 NOV 15 @B 7912060 0 7

- ' Enclosure to Howe-269-79 Consumers Power Company Response to the Notice of Violation I Described in NRC Inspection Report No 50-329/79-20 and No 50-330/79-20 A. LACK OF CONTROL FOR SPECIAL PROCESSES RELATIVE TO WELDING ACTIVITIES (329/79-20-01; 330/79-20-01)

1. Description of Noncompliance Appendix A of Report No 50-329/79-20 and 50-330/79-20 provides the following:

"1. 10 CFR 50, Appendix B, Criterion IX, requires, in part, that measures shall be established to assure that special processes, including welding are controlled.

Paragraph 5.2 of procedure 9-1 of the Consumers Power Company Quality Assurance Program Topical Report (CPC QA PTR) CPC-1 states, in part, 'Special processes are accomplished with written process sheets, procedures, checklists or equivalent which describe parameters to be metrduring the performance of the special process...'

Contrary to the above, the following discrepancies identified relative to the anchoring of safety 'related 4.16KV switchgear indi-cate that welding activites may not have been adequately controlled; these documents went through several reviews and were approved.

a. Quality Control Inspection Record (OCIR) #C304-288W specifies that the switchgear be anchored to the embeds by plug welds; Note 13 on the installation drawing C-195(O) requires fillet welds. This indicates that the manufacturer's recommendations were not followed.

b. The QCIR specifies the use of Weld Procedure Specification (WPS)

Pl-A-Lh (structural) for plug welds; this WPS is prequaliited to AWS Dl.1-76 requirements which excludes 7/8" diameter plug welds. This indicates that an incorrect WPS was specified and apptoved.

c. The inspection records indicate that " plug velds" were inspected and determined acceptable. ,

d. On August 23, 1979, subsequent to the NRC inspection, corrections were made to the above record without the benefit of procedural requirements.

e. Visual inspection of the welds and discussion with the various site personnel indicate that they may be fillet welds."

. 1506 356

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2. Consumers Power Company Resnonse

a. Drawing No C-197(Q), Rev h for h.16 kV Switchgear Distribution Centers specified fillet velds to secure the unit frames to the embeds. A memo from Project Engineering stated in part, "This veld may be plug velded." The Quality Control Inspection Report (QCIR) recorded that plug velds were to be used for the attach-ment. The problem here was that an improper document (a memo) was used to change a drawing and Bechtel Quality Control allowed that situation. As corrective action to help to preclude recur-rence, Bechtel's procedure has been revised, individuals have been apprised, and training sessions have been conducted in requiring a formal design change approval prior to implementation of field chang'es. The action revising Bechtel's procedure is contained in Bechtel's Engineering Department Project Instruction (EDPI) 4.h9 9, Rev 2, dated May h,1979

b. In actuality, fillet velds were used during the velding operation.

Upon completing the circumferential fillet velds, the velder filled in the center hole as allowed by AWS D1.1, Paragraph 2.7.1.3, which states in part, " Fillet velds in holes . . . nay be used to transfer shear . . . . These fillet velds may overlap . ...

Fillet velds in holes or slots are not to be considered as plug or slot velds." There is no problem apparent here.

c. The QCIR indicates the use of Welding Procedure Specification (WPS)

Pl-A-Lh (Structural) for plug velds. The description of the non-compliance states that this procedure is not prequalified for 7/8" diameter plug velds. In clarifying these statements, WPS P1-A-Lh was used for 7/8" diameter velds, but these velds are not plug velds and are considered fillet velds as described in AWS Dl.1,

. Paragraph 2 7 1.3 The WPS Pl-A-Lh (Structural) is prequalified per AWS Dl.1-1976 for P1 materials shielded metal are velding ( A) using low-hydrogen E7018 electrodes (Lh) . The WPS is used on all prequalified joint details specified in AWS D1.1. The circumf,eren-tial fillet veld procedure used in securing the switchgear to the embed is considered prequalified. Ho problem is apparent.

d. The description of the nonconpliance states that the QCIR was not corrected in accordance with an applicable administrative procedure.

The problem here is that, on August 24, 1979, a Level I Quali.ty Control Engineer (QCE) revised the QCIR, but his actions were never reviewed by a Level II QCE as required in SF/ PSP G-7.1.

As corrective action, on Septenber 27, 1979, Bechtel correct ed the QCIR, in accordance with SF/ PSP G-7.1, to redress th: type of velding actually u.ied. To help to preclude recurrence of this problem, the individual QCE involved has been apprised of the errors and trained in the proper method of correcting QCIRs per SF/ PSP G-7.1. Additionally, all QCEs have received training ,

in the requirements of SF/ PSP G-7 1.

The above actions are considered effective to achieve full compliance with respect to this infraction.

1506 357 JLC/jac

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