ML19290C637

Responds to NRC 791002 Ltr Re Violations Noted in IE Insp Repts 50-546/79-18 & 50-547/79-18.Corrective Actions:Load Rate Verification Performed Twice Daily & QA Program Revised

ML19290C637
Person / Time
Site:	Marble Hill
Issue date:	12/12/1979
From:	Shields S PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19290C634	List: ML19290C637
References
NUDOCS 8001220300
Download: ML19290C637 (5)

Text

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PUBLIC SERVICE December 12, 1979 INDIANA S. W. Shields Vice President . Electric System Mr. James G. Keppler United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Docket Nos.: STN 50-546 Glen Ellyn, Illinois 60137 STN 50-547

Dear Sir:

In accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, Public Service Indiana offe.rs the following additional information in response to items of noncompliance contained in inspection report 50-546/79-18, 50-547/79-18 as previously addressed in Public Service Indiana letter number 1102795065 of November 1, 1979.

Item of Noncompliance (546/79-18-01; 547/79-18-01)

Marble Hill PSAR, Chapter 1, Section 1.7, commits to Regulatory Guide 1.28 (June 7, 1972) and therefore to ANSI N45.2-71. ANSI N45.2-?l, Section 6, states that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of the type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Contrary to the above, the RIII inspector observed the following:

a. The loading rate applied to two compressive strength concrete cylinders were observed to exceed the 20-50 psi loading rate specified in ASTM C39.

b-f. (Previously addressed on November 1,1979).

g. Four occasions in which UST Level II personnel were evaluated for certification, other UST Level II personnel. This is not in accordance with UST Frocedure No. UST-TQ-1, Revision 9,Section IV, paragraphs 1.5 and 1.6.

h. Five occasions in which UST personnel were certified to Level I requirements prior to completion of the -interview and practical demonstration of their proficiency. This is not in accordance with UST Procedure No. UST-TQ-1, Revision 9,Section V, paragraph 4.1.

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i. Two occasions in which UST personnel were certified to Level I requirements prior to receiving visual e::aminatione. This is not in accordance with UST Procedure No. UST-TQ-1, Eevision 9,Section V, paragraph 5.0.

j. Four occasions in which the required physical and visual re-examinations were overdue for periods up to two months. This is not in accordance with UST Procedure No. UST-TQ-1, Revision 9,Section V, paragraph 7.2.

k. At least seven UST personnel were certified to Level I that did not meet experience requirements. This is not in accordance with UST Procedure No. UST-TQ-1, Revision,Section V, paragraph 3.2.

Corrective Action Taken And Result? Achieved Reported by PSI on November 1, 1979

a. The cylinders in question were for non safety related concrete po urs . To assure this condition does not occur when testing safety related concrete, U.S. Testing has instructed technicians breaking cylinders to verify the rate of load a minimum of twice a day, for a minimum of ten second intervals. This verification will be recorded in the remarks section of the break sheet for the cylinder tested.

g-k. U.S. Testing documented these discrepancies on ICAR #1036-67.

U.S. Testing is presently in the process of evaluating these problems to determine the corrective actions necessary. This evaluation will be completed by December 15, 1979 at which time corrective actions and corrective actions to prevent recurrences will be described.

Updated Corrective Action Taken and Results Achieved

a. No change.

g. U.S. Testing Level III personnel performed a review of their Level II personnel evaluated by other Level II personnel. The Level III personnel found that the Level II personnel were adequately qualified. This review and the acceptability of the qualifications of the Level II personnel were documented or.

appropriate qualification records by the U.S. Testing Level III personnel.

h. U.S. Testing performed a review of all Level I qualifications and found that even though there were a few people that were certified prior to completion of their proficiency evaluation, no technicians in the past or present performed any " record" tests until the proficiency eva'luation form had been completed.

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e i-j. U.S. Testing reviewed all personnel qualifications to determine the number of physical or visual examinations which were missed or past due. Past Jue physical and visual examinations were performed. Results of these examinations showed that the physical and visual capabilities of technicians were satisfactory.

k. U.S. Testing reviewed all personnel qualifications and found that all personnel met the requirements of UST-TQ-1 Revision 9 in that paragraph 3.2 references paragraph 3.1.2 which states experience requirements shall not be treated as absolute when other factors provide reasonable assurance that a person can competently perform a particular task. The personnel found not to be qualified as a Level I to perform General testing and inspection duties were given a proficiency evaluation to qualify them for a specific test to be performed only under the supervision of a qualified Level II.

Corrective Actions to Prevent Recurrence Reports on November 1, 1979

a. U.S. Testing Co. has written a letter dated 10-29-79 requesting the purchase of a loading pacer for the DRQC 200 comparison machine.

The above mentioned pacer is in process of being procured by P3I.

g-k. Corrective action to prevent recurrence has not been finalized because U.S. Testing Co. is in the process of evaluating its overall inspector qualification program. Additional time is requested to complete this action.

Updated Corrective Actions to Prevent Recurrence

a. U.S. Testing Co. has purchased a loading pacer for the DRQC 200 compression machine. The pacer was installed and put into operation the week of 11-26-79.

g-k. U.S. Testing has implemented a tickler file which will be checked on a monthly basis to pre.clude the recurrence of missed re-e xamina t ions .

The U.S. Testing site supervisor has indicated that personnel errars in meeting UST-TQ-1, Revision 9 shall be monitored by him to assure they do not recur and that the practice of certifying personnel prior to completion of their proficiency evaluation will not be used and has not been used since May 1979.

Additionally, PSI shall perform surveillance of U.S. Testing qualifications and require correction of any deficiencies fouad.

Such surveillance shall be continued on a periodic basis.

Dates When Full Compliance Will be Achieved

a. Full compliance was achieved on December 3,1979.

g-k. Full compliance is expected by January 14, 1980.

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Item of Noncompliance (546/79-18-03; 547/79-18-03)

The RIII inspector noted the fol!owing examples of nonconformance reports which had not received the proper design organization evaluation as required by ANSI N45.2-1971, Seccion 4.4.

a. PSI FCAR No. 69, dated December 22, 1977

b. PSI FNR No. 018, dated February 21, 1978

c. N-MH FCR No. 314, dated January 8, 1979

d. N-MH No. 316, dated January 16, 1979

e. N-MH NCR No. 183, dated June 8, 1978 Corrective Action Taken And Results Achieved Reported an November 1, 1979 Engineering evaluation of these nonconformance reports has been include (

within the scope of an overall evaluation of nonconformance reports to assure completed work is adequate. This overall evaluation is not completed yet and additional time is requested to complete this action.

Updated Corrective Action Taken And Results Achieved A three man review team made up of representatives from Engineering, Quality Assurance, and Construction disciplines was formed to review all Field Corrective Action Requests (FCAR), Field Nonconformance Reports (FNR), Deviation Control Records (DCR) and Contractor Nonconformance Reports (NCR) . The review team x iewed 2724 reports, identified each report reviewed, and maintained records of each report requiring engineering review or disposition. Each report requiring such engineering review or disp)sition has been considered as remaining open pending engineering review and is subject to Site Design Control Group review in the same manner as newly initiated nonconformances.

A total of 212 nonconformance reports out of the 2724 reviewed have been identified as requiring engineering review.

Corrective Action To Prevent Recurrence Reported on November 1,1979 PSI is in the process of developing and implementing procedural and organizational changes to its nuclear project. These changes are not complete and additional time is requested to address action to prevent recurrence.

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0 Updated Corrective Action to Prevent Recurrence The PSI Quality Assurance Progtam is being revised to reduce the number of forms used to report nonconforming conditions and eliminate confusion. The accompanying procedures for ut e of nonconformance forms have also been changed to clearly require Englaeering review and approval of:

a. All Nonconformance Reports for items in PSI custody.

b. Contractor Nonconformance Reports dispositioned use-as-is or repair.

Dates When Full Compliance Will be Achieved Review of nonconformance reports by the three man team is complete.

Engineering re-review of nonconformance reports identified by the review team will be complete by January 2, 1980.

Revisions to the PSI Quality Assurance Program addressing handling of nonconformances shall be approved and issued for use by January 2,1980.

Sincerely, S. W. Shields Vice President-Electric System SWS:aaa cc: J. J. Harrison E. R. Schweibinz, P. E.

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