ML19261C374

Responds to NRC 781228 Ltr Re Violation Noted in IE Insp Rept 50-329/78-15 & 50-330/78-15.Corrective Actions: Corrective Action Rept Written for Welds & Welded Studs Found to Be in Conformance

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: ML19261C374
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.

, u c-w d k

,6 Enclosure 7 31979

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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:

a. Unit 1 side - three velds, where joint preparation and 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.

c. Unit 2 side - two velds, which had not yet been subject to 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, evidence. the above statement canSince the FWE does e nonconfomance Inspector identified the rejected on. November 2, 1978. or - fitupsThe red with the NRC Welding QC Jield Inspection Report inspects this characteristic onbyathesurThe checked FWE. characteris Rev6,9/25/78) characteristics actually surveilled are noveillance The WQCE The velding '.

bas on the QC Inspection R ecord. w recorded (per QCI W-1.oo routinely checked by the FWE. visibility This does provide

-process characteristics on ~the effectivenes in Section J of drawing C-835 Subsequent to the above done with prior Engineering Q) revision 2 approval were made (Rfull utilizingpene as on 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 processy and subject the Inspector to be to subon the (even though velding was finished, the final sequent veldinspection because it was not for the final inspection). released to Welding QC was not consideredb complete to in-process surveillance It butisit noted is that veJd site is not subjecty Fie discrepent prior to the NRC subject to final inspection. this Inspector'to Due in-process s were not identified as Report was issued upon identification of th s observations. A Discrepancy dispositioned utilizing specification the Field Engineer's report. -

screpancy Report was C 30hThenin

, pare 6raph 6 inspection was completed and the welds wThe disposition -is" and the was "use-as.2.1 (

two velds on the Unit 2 side which werIn regard to ite e matter revealed that the to final inspection, in factughthad reinspection not tobeen have been athroat subject and which, Upon Corrective ac, tion was taken in that a Cthese two velds were iden training session was held ordance and oversize criteria.

with with thePSP respwritten G-3 2. A against undersize was closed. The twoinspected were reworked, velds identified and accepted on NCR ebng 162h as b ionsib II. y the WQCE and the NCR NONCONMM&NCE TO AWS A.

Dl.1 MDE (50 329/781 01;50-330/78-15-01)_

Description of Noncompliance Appendix A of Report No following:

50-$29/78-15and50330/8 -

7 -15 provides the

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"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 withg appropriate velding inspection.

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 ing their original condition. The additional velding 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.

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