ML19261C374
| ML19261C374 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/01/1979 |
| From: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19261C369 | List: |
| References | |
| HOWE-31-79, NUDOCS 7903220348 | |
| Download: ML19261C374 (4) | |
Text
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'O Consumers Power CO@2ny
a* a H Ha-
Sennor Vact Pressdent Generet Offices: 1946 West Pernait Road. Jockeon, Michigee 40201. (517) 788 4453 February 1,1979 Howe-31-79 Mr. J. G. Keppler, Regional Director e
Office of Inspection and Enforcement US Nuclear Regulatory Coccission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR PLAITI - NRC ITD4S OF NONCOMPLIANCE INSPECTION REPORP NO. 50-329/78-15ANDNO.50-330/78-15 This letter, with its enclosure, is in response to your letter of December 28, 1978 which transmitted the results of your inspection of the Midland construction site on November 1-3, 1978 and which requested our written statement on the items of noncompliance.
c-w d k u
,6 Enclosure 7
31979
'I9032203@
CONSGERS POWER CCNPANY RESPONSE TO THE ITEM OF E0HC0t@LIAUCE DESCBTREn IN HRC INSEECTION RPPORT I.
NONC0!GDR4ANCE TO WELDING REQUIIEMENTS; (50-329/78-15-02; 50-330/78-15-02)
A.
Description of Noncompliance Appendix A of Report No 50-329/78-15and50-330/78-15 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 velding, are controlled.
Paragraph 5 2 of Procedu:ce 9-1 cf the Consumers Power Company Qaality 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 met during the performance of the special process...'
Contrary to the above, on November 1,1978, the inspector determined that several velds placed on the Seismic Category 1 Main Steam Isolation Valves Support Structures were not in conformance with the requirements of drawing C-935 and C-936."
(NOTE: Correct drawing numbers are C-835 and C-836)
The body (Section II, Item 3) of the Inspee^1on Report described three discrepant conditions as follows:
Unit 1 side - three velds, where joint preparation and a.
alignment were complete, had fitup gaps in excess of specificetjon requirements.
b.
Unit 1 side - nine velds, which had not yet been subject to final inspection, were oversize.
Unit 2 side - two velds, which had not yet been subject to c.
final inspection, had insufficient throat.
B.
Consumers Power Company's Response In regard to item a, the three velds had bee.n identified previously by the Field Welding Engineer (WE) as having fitup more than 3/16" and as being in excess of GWS Structural paragraph 4.131. The as had determined the velds to be rejectable prior to the NRC Inspector's
, =..,
2 observations.
documentation, the above statement canSince the FWE doe evidence.
e nonconfomance Inspector identified the rejected fitupsThe Welding QC on. November 2, 1978.
red with the NRC or -
Jield Inspection Report inspects this characteristic on a surThe characteris checked by the FWE.
Rev6,9/25/78) characteristics actually surveilled are noveillance bas The WQCE The velding on the QC Inspection R w recorded (per QCI W-1.oo routinely checked by the FWE. visibility on the effectivenes ecord.
This does provide ~
-process characteristics in Section J of drawing C-835 Subsequent to the above Q) revision 2 were made utilizing as on done with prior Engineering approval (Rfull pene e excess fitup cap.
C-18h5) and the velds vere inspected andesident Engineer Memoran This was In regard to item b, the nine (9) welds accepted by the Bechtel WQ complete were in process and subject to subon the (even though velding was finished, the veld y the Inspector to be sequent final inspection because it was not released to Welding QC b was not considered complete for the final inspection).
It is noted that veJd site is not subjecty Fie to in-process surveillance but it is discrepent prior to the NRC Inspector'to this in-process subject to final inspection.
Due s were not identified as Report was issued upon identification of th s observations.
A Discrepancy dispositioned utilizing specification C 30hThenin screpancy Report was the Field Engineer's report.
, pare 6raph 6 inspection was completed and the welds wThe disposition was "use-as.2.1 (
-is" and the two velds on the Unit 2 side which werIn regard to ite e matter revealed that the to final inspection, in fact had been athroat and which, ught not to have been subject reinspection Corrective ac, tion was taken in that a Cthese two velds were iden Upon training session was held with the respwritten against ordance with PSP G-3 2.
and oversize criteria.
A The two velds identified on NCR 162h as b ionsi undersize were reworked, inspected and accepted b was closed.
e ng y the WQCE and the NCR II.
NONCONMM&NCE TO AWS Dl.1 MDE (50 329/781 Description of Noncompliance 01;50-330/78-15-01)_
A.
Appendix A of Report No following:
50-$29/78-15and50330/8 7 -15 provides the
3 "2.
10 CFR 50, Appendix B, Criterion XVI requires, in part, that measures shall be established to assure that conditions adverse to quality such as.... defective material and equipment and nonconformances are promptly identified and corrected.
Paragraph 31 of Policy No 16 of the CPC QA PTR-CPC-1 states, in part, ' Corrective action is initiated to correct conditions adverse to the quality of items and activities.'
1 Contrary to the above, on November 3,1978, the inspector determined that corrective action taken to repair noncon-forming Nelson Stud veld attachments according.to paragraph 4 30.1 of the AWS Dl.1 code was neither specified nor implemented."
B.
Consumers Pcuer Company Response The above described noncompliance dealt specifically with not implementing a requirement of AWS Dl.1 to bend all studs repaired by velding. Bechtel Project Engineering had provided an accepteble rationale for a "use-ac-is" disposition for other studs identified on NCR 1345 that were embedded. The acceptable, ationale involved a test based on anticipated actual loading. The teet covered all cases, but Project Engineering indicated that, to minimize Code noncompliance, all accessible studs were to be repaired by velding. The exposed studs were repaired by velding with appropriate velding inspection.
g However, they were not bent the 15 required b; the Code.
The following corrective actions were taken:
1.
Consumers Power Company QA issued NCR M-01-9-8-095 identifying that the studs repaired by velding vere not bent, as required.
2.
Bechtel Project Engineering evaluated the identified discrepancy and determined that the studs were cepable of carrying their design loads in their original condition. The additional velding g
to assure a 360 veld fillet is not detrimental and the studs are acceptable without the bend test.
3 The Bechtel response to Fhe NCR was evaluated by CPCo QA based on on dispositions for the embedded studs and the NCR vas closed.
e
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