ML19326D199
| ML19326D199 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/20/1977 |
| From: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19326D196 | List: |
| References | |
| HOWE-132-77, NUDOCS 8006090622 | |
| Download: ML19326D199 (7) | |
Text
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%ce Prevdent j
a.n.,. ome.. 212 West Michsgan Avenue. Jackton. MICh%en 49201 t
j July 20,-1977 Hove 132-77 1
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Mr. J. G. Keppler, Regional Director Office of Inspection and Enforcement US Huclear Regulatory Commission Region III i
799 Roosevelt Road j
Glen Ellyn, IL 60137 i
j MIDLAUD UUCLEAR PLANT.- URC ITEM OF UCUCOMPLIAUCE l
INSPECTION REPORT HOS 77-05, 77-08 j
DOCKETS 50-329 AND 50-330 l
l 1
This letter, with the attachment, is in response to your letter of June 21, 1977 which transmitted the results of your special inspection of the Midland construc-tion site on May 2h-27, 1977 and which requested our written statement on the iten i
of noncompliance, k
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/Q CONSIEiERS F0WER CO?tPANY RESPOUCE TO THE ITD1 OF MONCOMPLIAUCE DESCRIBED IN NRC INSPECTION REFORT 77-05 AND 77-08 I.
Pipe Supports 'ist Inctalled to Snecification A.
Description of Noncompliance Ites A from page 1 of Appendix A of Report No. 50-329/77-05 and No. 50-330/77-08:
"The Bechtel Technical Specification 7720-M-326, states, in part, in paragraph 5 11:
'If the gap (between the steel bearing plates and the concrete vall) exceeds 1/16" or if the clearance exists over more than 20% of the bearing area, grouting is required.
The Pechtel Quality Control Incpection Record (QCIR)
No. P-2.10-610-3 for pipe support 18-1HCB-2-H9 and QCIR
'T P-2.10-610-4 fcr pipe support 3-1FCB-28-H5 requires in C_s/
paragraph 3.4.b that:
' clearances between steel plates s
and concrete surfaces as specified.
(refs.ence Technical Specification 7720-M-326, paragraph 5.11)'
Contrary to the above, on May 24, 1977, the inspector observed that the clearances between the concrete vall and the steel bearing plates for pipe supports 18-1HCB-2-H9 and 3-1FCB-28-H5 exceeded 1/16" inches and that these supports had been incpected and accepted by quality control without grouting."
B.
Corrective Action A specification change notice, SCN 3, dated 6/1/77, was issued to clarify the design and acceptance criteria contained in Specification 7220-M-326Q.
The Quality Control Instruction used in the inspection of the installation of these components (QCI 7220/P-2.10) was modified (Rev 2, 6/6/77) to in-corporate SCN 3 The original Bechtel QC inspection of the installationc g"'s was made to the correct criterion as clarified by SCN 3.
Neverthc1cos, Bech-t
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tel QC hac reinspected the exicting installations to the clarified criterion.
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Subsequent to these initial actions, Bechtel Engineering has completed
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a study which demonstrates that visual inspection of the plate /vall 2
interface perimeter can be used to determine the acceptability of the installation. This improved inspection procedure vill be incorporated in the appropriate documents to be used for future installations.
It is anticipated this vill be completed by August 1, 1977 Prior to the start of the NRC inspection resulting in Report 77-05 and 77-08, CPCo and Bechtel had undertaken a tack to review all the existing Bechtel QCIs.
One of the review criteria is to assure the specificity and clarity of the accept / reject criteria in each QCI. ~ As of July 8,-
1977, review has been completed for 25 of the 52 QCIs.
This review should assure in all QCIs the absence of the " root cause" condition which allowed the original QC acceptance of the hangers.
It is expected that
[a) the results of the review process vill be reflected in revised QCIs for first'line inspection issued by August 15 and for subcontractor surveillance issued by Septe ber 30, 1977 II.
Drawine Chance Control A.
Description of Honconnlianle Item B from page.1 of Appendix A of Report No. 50-329/77-05 and No.
50-330/77-08:
"The Bechtel Quality Accurance Manual - ASME III, Division 1, paragraphs 3313 and 3415 state, in part:
' Revisions to drawings are procecced in the came manner as the original drawing.
Drawings may be modified by means of.
project engineer approved Field Change Reguccts FCR's as described in paragraph 3415....
The FCR provides field engineering with the means of reporting to project engineering discrepan-eies in project drawings, such as interferences or changes in arrangement required by job conditions.
fN Contrary to the above, the inspector observed safety related
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pipe supporte 10-lCOB-23-H2 and 12-lHEC-124-H5 being accembled i
s during the period by 2h-26 with handwritten drawing change:
provided by the field engineering staff that had not been procesced in accordance with the BQAM."
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B, Corrective Action s
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It must be emphacized that Bechtel QC final incpection was being accom-plished to unmarked, officially released drawings only.
A memoranddn dated May 26, 1977 was issued by Bechtel which cuspended further use of Field Engineering handwritten drawing revisions.
In addition, two Field Instructions General (FIG 1 7 10 and FIG 1.7.20) were issued for internal Bechtel review on June 22, 1977 These FIG's contain improved administrative procedures to control field changes.
It is anticipated that formal release of the FIG's vill be by July 31, 1977 III. Audit Renorts A.
Descriution of Noncompliance Item C from page 2 of Appendix A of Report No. 50-329/77-05 and No.
s 50-330/77-08:
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Consumer's Electric Plant Projects QA Services Department
, Procedures No. 10 and No. 12, Sections 5.3.3 and 5 2.3, state, in part:
Within appror.imately ten vorking days after com-pletion of audits, prepare audit report using audit report 4
form (Attachy.ent C).'
Contrary to the above, on May 25, 1977, the inspector found that Audit Report Hos. F-77 h, F-77-1, F-76-58, and F-76-52, had not been prepared and issued although the audits were completed three to seven months earlier."
B.
Corrective Action The four audit reports in question vere issued by May 27, 1977 i
The four reports were the responsibility of a single individual who has been readvised to adhere to procedural time limits for the issuance of audit reports. We have acquired additional Quality Assurance Department personnel which vill help to acsure the timely incuance 4
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of audit reports.
Since the NRC incpection, coven QE/QC personnel have s_,
been employed and an additional four have accepted employment in the
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Quality Engineering and Inspection, Examination & Test Verification fD
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Midland Sections.
An organization chart showing our present manning status is attached.
IV.
Trend Analvnia A.
Description of Nonconformance Item D fro.*a page 2 of Appendix A of Report No. 50-329/77-05 and No.
50-330/77-08:
"Cor,sumer's Midland Project QA Procedure No. M-10, Section 5 0, states, in part:
'The first step in detecting trends is logging of all nonconformances and audit findings since January 1, 1976, on a common document (Deficiency Log, Attachment M-10A)'.... 'the next step is classification. '
. 'The initial division of UCR's and findings into categories is reviewed by the Quality Assurance Superintendent for field deficiencies and by the Midland Quality Assurance Administrator for deficiencies found by General Office Personnel.
Subsequent additions are reviewed quarterly in the same manner.
These reviews are documented by signing the M-10B form. '
.. If a reviev.
reveals that the. e have been
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occurrences of the same problem vithin the specified time span
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which constitute a trend, either a Trend Analysis Report,
, 0C, or a nonconformance report identifying the problem as a trend is completed.'
Contrary to the above, on May 26, 1977, the inspector found that only 61 of 97 UCR's, issued since January 1,1976, were logged.
Only a small percentage of the audit findings had been logged.
No logging or classification had been accom-plished for 1977 Consequently, no review for trends was accomplished in accordance with the procedure."
B.
Corrective Action CPCo nonconformances and audit reports were characterized and analyzed resulting in eighteen (18) Trend Analysis Reports (TARS) being issued by June 6, 1977 Acquisition of the additional personnel and closer a
management attention in this particular area vill help to assure that QA Procedure No. M-10 vill be adhered to in the future.
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Defective Senle A.
Descrintion of nonconformance Item'E from page 2 of Appendix A of Report No. 50-329/77-05 and No.
50-330/77-08:,
" Champion Batch Plant Quality Control Manual, Section 15, states, in-part:
' Measuring equipment found defective shall be tagged and corrective action taken.'
Contrary to the above, on May 27, 1977, the inspector observed that automatic scale, SN 533ho5, was not being used to weigh ice, rather manual scale SH 29742 was used.
It was learned that the automatic scale was found defective the previous day.
The scale was moved one-to-two feet from -
the area where ice was weighed; however, the defective equipment was not tagged as the procedure required."
B.
Corrective Action Prior to the NRC inspection, the defective scale was physically removed frcm the line and an acceptable scale was being used in its place.
The defective scale was tagged immediately after it was recognized that the tagging procedure had not been followed. The scale was then sent offsite for repair and calibration. Bechtel was cautioned in writing to assure the timely tagging of this and similar items in the future.
Bechtel also provided training to its personnel and corresponded with its subcontractors directing them to emphasize the importance of tagging in their training programs.
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QUEin ASUU11JiCd -
PICJECTS, E!:GINELitII:G & CO:;0TliUCTION B. W. !!arguglio, Director J. M. Biele, Eecy.
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H. W. 31rcer (H)+
P J. h. 23:lerer. (h)
P W. R. Dird (11)
M J. L. Corley (11)
P H. W. Sloger (ii)+
P E. W. Sleger +
H P. Golombek, Scey.
(Pending)
P D. A. Teccart +
P D. D. n'. cree, P
L. J. Bidol, Secy.+
P L. J. Didol, Secy.+
(Acting)
Clerk P
D. A. Tec art (11)+
C E. G Ade s P
G. M. Lell (Acting
.C J. M. Decker P
D. Jone.
P D. A. Taggart +
P P. E. Iave (8/1) civit c1 yin P
O. E. Skagga P
Vacancy M'
R. G. Wollney (S)
M D. E. IIorn (Acting) (S)
H G. T. Diock M
G. E. Johnsen M
D. A. D1umenthal*
H D. A. Denns' H
ff. F. DeWitt M
P. Kraus' t_LEGI RICAL/st1GTnW ICS P
D. R. Fecker (S) (6/15)
P P. W. Jacobsen LLEcch1 CAL /ht Lei'RUNICE H
P. H. Kyner (S)
W. !!. Denkert iLUIL6 & 11 Chid 41 CAL g
P H
Vaenney R. E. Whitaker P
Vseeney FLU 1DJ & !1CRWICAL M
D. ft. Keating (S)
H Vocnney
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H Vnenney 6
P H. s. cercha (8/;2)
H Vecency' P
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J. L. Voed H
Vecency' (11) = Sectior. lieed (S) = Group Surerviser P = Farriell Location M = Midland Location EE11'1U U hv;WESTRUJf1VE C = cenpbell *.ccation PAITIAINALILITY EXM11NATIOil
- = Contract Personnel P
vacancy y
y, coney Date. Expected Report Pete for New Hire H
Vacancy
+ = Dual Capacity M
- Vacancy, 7/13/TT
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