ML19329E238
| ML19329E238 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/01/1977 |
| From: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19329E237 | List: |
| References | |
| NUDOCS 8006120533 | |
| Download: ML19329E238 (10) | |
Text
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0 f)lCORSun1 BIS Od POW 8r Con 1pany t'oce besidens i
c a.r.' omc... ts4s was rarnen me.a.J.6,on vwa.n 4smot. Area Code 50 7584453 November 1, 1977 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 NUOLEAR PLANT - NRC ITEMS OF NONCOMPLIANCE INSPECTION REPORT NO 50-329/77-09 AND No 50-330/77-12 This letter, with its attachment, is in response to your letter cf October h, 1977 which transmitted the results of your inspection of the Midland construction site on August 30 - september 2 and September 13-15, 1977 and which requested our written statement on the items of noncompliance.
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CONSLEERS POWB COFPANY _ RESPONSE TO THE ITEMS OF NONCOMPLIANCE DB3CRIBED IN NRC INSPECTION RFJORT_
NO. 50-323f77-09 AND NO. 50-330/77-12 I.
Failure to Follow Audit Procedures _
A.
Descriptions of Noncompliance Paragraph 3 from page 11 of Appendix A,Section II of Report No.
50-329/77-09 and No 50-330/77-12 provides the following:
" Review of U. S. Testing Comt.any (UST) Manegement Audits The inspector reviewed an audit performed by UST Management on the Midland Site office and determined the following:
a.
Audit No 11 documented the managerent audit performed on April 21, 22, and 26, 1977 b.
The principal auditors vere from their main office in Hoboken, NJ.
C' c.
The following four findin6s were identified:
b; (1) Inadequate specification of accuracy levels to which measuring equipment was to be calibrated.
(2) Insdequate instructions to the site personnel to provide surveillance to activities of UST subcontractors such as Scientific Glass (calibration of hydrometer ID No. 214) or Forney (calibration of the compression testing machine).
(3) Ineceplete testing personnel records at their main office.
(k) Corrective action had not been recommended on Corrective Action Requests for ik reports; the earliest report was in January 1977 d.
There was no documented indication on the four audit finding reports that corrective action vas initiated. This is con-trary to Paragraph 6.2 of procedure UST Audit-1, Revision 3, which in part states 'The project manager shall submit a written report to audit manager within 30 days from the date the audit report is issued defining the corrective action taken and a date for implementing the corrective action.'
Failure of the licensee to ensure that his contractor LST p
followed his procedure (UST Audit 1, Revision 3) by taking Q
timely corrective action within the period stipulated in the
2 U,.,
procedure is contrary to 10 CFR 50, Appendix B, Criterion V.
This matter is considered an apparent item of noncompliance.
Prior to the conclusion of the NRC inspection, UST obtained the ree.ccended corrective action information; implementation is to be accomplished and verified."
3.
Corrective Action UST has offered the following information which indicates that corrective action had been initiated prior to the NRC inspection; however, the corrective action had not been documented on the four Audit Finding Reports (AFRs).
General Actions Taken to Resolve AFE 1015-11-1 Through h 8/19/77 The individual formerly responsible vas relieved of duties which were assumed by the V.P. of Nuclear Construction Inspection. A Project Engineer was assigned to assist the V.P. of Nuclear Construction Inspection on this project. The Audit Manager advised the Project Engineer as to lack of audit responses.
(O 8/22/77 The Project Engineer telephoned the Site Project V
Supervisor (Lab Chief) to discuss status of audit findings and corrective action.
8/30/77 A meeting was held between the Project Engineer cnd the Audit 1'.aneser on the status of corrective action for audit findings.
Specific Corrective Actions for AFB 1015-11-1 5/03/77 QA Engineers reviewed the accuracy level problem for through all UST projects and determined and documented the 8/18/77 required accuracy levels.
8/19/77 The newly assigned Project Engineer revieved the status of this AFR.
Specific Corrective Actions for AFR 1015-11-2
Background:
This AFR identified the lack of proper documentation for the surveillance of subcontracted calibration services perforned by Forney Company and Scientific Glass.
In the case of Forney Company services, the Site Project Supervisor witnessed the rformance of the service but did not document it.
The Site
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Project Supervisor surveyed this service while training
[V UST personnel on the calibration of the ccepression testing machine during Forney's calibration of the machine.) In the case of Scientific Glass, the hydrometer (ID 214) has not beer. used for acceptance testing since the audit.
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Early A 4 En6 neer was assigned to determine a proposed 1
May 1977 corrective action.
Late The Audit Manager reviewed the proposed corrective May 1977 action and provided corcents and transmitted both to the Project Manager for review.
Mid The Project Meneger reviewed the proposed corrective June 1977 ection and the Audit Manager's concents Late Meetings vere held attended by the Project ManaEer, June 1977 Audit Manager, e Engineer and V.P. of Nuclear Construction Inspection.
Corrective action vas finalized.
7/05/77 Written instructions (AI No. PGS-813(625)-1) for the control of future services were transmitted to Site Project Supervisor. These instructions require that a log of subcontracted services be maintained. In addition, a standard surveillance checklist is provided for documenting the surveillance of sub-contracted services.
/O 8/23/77 The Audit Manager tel(phoned the Site Project Supervisor V
to check on the implementation of the July 5,1977 instructions. The Site Project Supervisor stated that no subcontracted service has been performed since the receipt of the July 5, 1977 instructions.
Specific Corrective Actions for AFR 1015-11-3 5/0k/77 Written instructions (AI No. PGS-770-1) vere transmitted to the Project Manager and Site Project Supervisor.
These instructions swrcarized the responsibilities for the preparation, retention and transmittal of the Document of Qualification, and similar documents, which are described in UST-TQ-1.
Specific Corrective Actions for AFR 1015-11 k Mid The e Engineer was assigned to review outstanding May 1977 Internal Corrective Action Requests (ICARs).
8/26/77 The newly appointed Project Engineer discussed this audit finding vith the Audit Manager.
The Project Engineer provided training on the processing of ICARs to Site Project Supervisor via telephone.
inh 8/26/77 The Audit Manager initiated ICAR 1015-11-2 on the same subject.
8/29/77 The Audit Manager provided training on the requirements of UST-CA-1 to the Project Engineer.
S k
G The Project Engineer telephoned Site Proje,t Supervisor to provide edditional training on UST-CA-1 requirements to the Site Project Supervisor. This telephone conversation included discussions on the resolution and closeout of some of the outstanding ICAR's.
As stated in NRC Inspection Report No. 50-329/77-09andNo.50-330/77-12,Section II, 3.d, last paragraph:
" Prior to the conclusion of the NRC Inspectior., UST obtained t 9 recommended corrective action information; implementation is to be accomplished and verified."
On September 1,1977, the UST Audit Manager documented his approval of the corrective action taken for Audit Findings -1 through -4.
Implementation of the corrective action for these audit findings has been verified in Audit Report 12 conducted on October 19-21, 1977 by Marvin Fisher.
To assure the timely documentation of corrective action and the timely implementation of the corrective action, the Audit ManaEer vill obtain a semi-monthly audit finding status report from the Project ManaEer.
The implementation of the semi-monthly audit finding status report vill begin after the' issuance of Audit Report 12 (November,1977).
g In addition to this, further corrective action was taken for precluding the untimely closures of ICAR's (the subject of AFR 1015-11 h).
The l
Project Manager or his designee vill review the status of all ICARs on a weekly basis and initiate action to resolve any that are outstanding.
The Audit Manager vill perform a monthly surveillance of the Project ManeEer's review. The veekly and monthly review activities were initiated the week of October 17, 1977 II.
Failure to Qualify Stud Welding Procedure Paragraph h from page 12 of Appendix A,Section II of Report No. 50-329/77-09 andNo.50-330/77-12 provides the folleving:
" Observation of Nelson Stud Welding Activities The inspector observed shear connectors (Nelson ettds) being velded to safety related embedment plates on the auxiliary building. The stud velding was being performed to procedure 'P-1 Stud Welding,'
Revision 2, dated July 29, 1976, where in the requirements of AWS Dl.1-72 are specifieg. The inspector observed several Nelson studs without a full 360 vela fillet; several of these studs which hed been struck with a hammer for the routine bend tests appeared to have questionable separations between the veld and the shank. Through his observations and discussions with the licensee and contractor QC personnel, the inspector established that the
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Documentation thet the Bechtel Welding procedure 'P-1 stud velding' vas duly qualified.
Certified results of an independent test laboratory on the Nelson Stud Welds; physical and chemical test certificates on the Nelson Studs vere available.
Pecords to indicate that the stud velding vas being performed within the voltaEe, current and time parameters specified in the velding procedure.
Pecords to indicate that the velding stud gun operator was indoctrinated in the operation of the equipment.
The above conditions are contrary to the following requirements:
Policy No. 9 of Consumers Power Company cality Assurance Program Topical Report CPC-1, Favision h, dated March 1,1977, (initisted by' Control of Special Processes, Fevision 5, dated letter submittal to NBC from R. Sevell, May 23, 1975) titled December 10, 1976, which in PareErsph 1, in part stated 'Whether performed by Consumers Power Company or a principal supplier, special processes are performed using qualified procedures, equipment, and personnel.'
Paragraph 5 2 of Quality Assurance Program Procedure for
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Design and Construction, Control of Special Procedures, Procedure No. 9-1, Revision 3, dated Petruary 29, 1977, which in part states CPCo departments perform special processes using approved qualified procedures end qualified equipment
.... the design documents.
Paragraph 5 3.d, of CPCo Electric Plant Projects Quality Assurance Services Department Procedures, Procedure No. 7, Revision 6, dated June 20, 1975, which in part states
'.... quality documentation is submitted and provides verification of approvals, materials, applicable inspection, and tests.'
The inspector informed the licensee that the above condition vos contrary to the requirements of 10 CFR 50, Appendix B, Criterion IX, and is considered an apparent item of noncompliance.
l The inspector, along with licensee personnel observed, that as a result of hammer test performed approximately 20 Nelson Studs installed broke instead of bending and appeared to exhibit brittle i
fracture type failures.
Except as noted, no items of noncompliance or deviations were identified."
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B.
Corrective Action The following actions have been taken:
1.
The Nelson Stud qualification papers were obtained thmugh Bechtel's Material and Quality Services group. The Nelson Stud qualifications vere on file in Bechtel's San Francisco Office. The Nelson Stud papers are nov on file at the site, r2 Stud qualification papers are expected to be on the site by November k, 1977 The Bechtel velding procedure, P-1, is qualified in accordance with the governing code. The governing code (AWS Dl.1-72) states in Paragraph 51.1 that " Welding procedures which conform in all respects to the provisions of Section 2 - Design of Welded Connections, Section 3 Workmanship, Section 4 - Technique
.... shall be deemed as prequalified and are exempt from tests or qualifications." AWS Dl.1-72 only requires that the procedures be prepared as a written specification. Equipment qualification is done by the equipment manufacturer and is verified by in-process tests as required by the AWS Dl.1 code and by the Bechtel velding proced ures.
2.
Bechtel Quality Control Instruction (4CI) C-5.lO " Installation of Shear Connectors" vas revised to include additional inspection criteria to assure that stud velding is being performed within the n
recommended parameters specified in the velding procedure.
Specifically; a) inspection criteria vere established that provided for a " ringing" (tappin6 vith a hammer) of all studs not bend tested, and b) a check on the length of cable to assure that the manufacturer's recommended cable length is not exceeded. The QCI was reviewed and approved by Consumers Pcuer Company Quality Assurance and has been implemented.
3 Documentation has been generated that indicates vhich craftspersons have received indoctrination in the operation of the velding stud guns. Only craftspersons listed as having received indoctrination vill be allowed to produce stud gun velds. Personnel qualification for stud velding is not required by AWS D1.1-72.
h.
Consumers Power Company, in conjunction vith Bechtel Quality Control, perfomed a special inspection of a total of 170 studs (previously inspected and accepted) in four separate areas of the Auxiliary Building in accordance with the revised QCI referenced in 2, above.
All studs were tapped and passed this test. Visual examination revealed one stud to have a "questionablg" fillet veld size (but still within acceptable criteria and 360 allaround). This stud was subject to a bend test which resulted in a failure in the shank and not in the veld area.
5 Bechtel Quality Assurance conducted an audit betscen August 31 and September 2, 1977 on shear connector installation in which
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k0 studs were observed to be properly velded and tested. The iV audit included a checkpoint that proper amperage and time settings vere being used.
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Itema k and 5 above provide evidence that the stud velding process is under control.
The 20 Nelson Studs which vare broken durire a Bechtel inspection and subsequently observed by the NRC Inspector do not represent a general problem. These studs vere bend tested because the Bechtel inspection process detected that the specific studs (of which these 20 vere a part ) vere questionable during the required visual examination. The unacceptable studs vere attributed to an incorrect amperage. This condition represents an isolated case.
III. Inadeouste Welding Inspection Criteria A.
Description of Noccompliance Paragraph 7 from page 15 of Appendix A,Section II of Report No.
50-329/77-09andNo.50-330/77-12 provides the following:
"_ Review of_ Quality Record s of Safety Pelated Structures Veldira The inspector selected velds on the following safety related structures to ascertain whether the records reflect vork accom-plishment consistent with SAR and applicable AWS D1.1-72 code re quirements.
D a.
At Elevation 652' Beam h10 BT (W21 X 82) to C5 Embed (North)
Beam h10 B8 (W21 X 92) to C5 Fabed (North) l Installation was to Bechtel Drawing C2h2 and Ingall's Drawing E2h2.
b.
At Ele ation 659' Beam E28 B2 (W30 X 132) to C6 Ented (South)
Beam klh B2 (W2h X 68) to C5 Embed (North and South)
Beam 414 B1 (W24 X 68) to C5 Embed (North and South)
Installation was to Bechtel Draving C228 and Ingalls Drawing E228.
The inspector determined the following:
(1) Log No. h196; QCIR No. 304 - 144W indicates that velding Procedure Pl-A LH, Pevision 0, dated October 17, 1974, vos used; velds and velders were identified; visual inspection for size, length, and location of the velds identified no adverse findings.
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(2) Log No. 5893; qCIR No. 304-246W indicates that velding Procedure Pl A-LH, Revision 0, dated October 17, 1974 l
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v was used; velds and velders were identified; visual inspections for size, length, and location of the velds identified no adverse findings.
(3) Review of one quality control velding surveillance log dated June k, 1977, indicated that the velding current parameter of four veldors was checked with a tong type ammeter and determined to be acceptable.
(4)
Qualification of the veldors identified was verified and determined to be current.
At the NRC inspectors' request the velds were reinspected for size and length.
It was determined that the size of several fillet velds were substantially in excess of those specified in the design drawings; the lengths of four velds vere less than those specified in the drawing.
Furthermore, the inspector determined that neither the Bechtel design drawings nor the QC inspection checklists specify any tolerances on either the size or lenEths of the velds.
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The inspector stated that the above condition was contrary to the requirements of 10 CFR 50, Appendix B, Criterion X, and the implementation of Paragraph 1.c of Policy No.
10, Revision 3, dated December 1,1975, of the Consumers Power Company quality Assurance Pro 6 ram Topical Report CPC-1, Revision h, dated March 12, 1976, titled ' Inspection. '
This is considered an apparent item of noncompliance.
The inspector reviewed the following Discrepancy Reports (DRs) on velds:
C304-24hW, dated September 13, 1977 C304-169W, dated August 6,1977 C304-174W, dated July 18, 1977 C30L-282W, dated July 18, 1977 C304-5CW, dated December 15, 1976 C30h-51W, dated December 15, 1976 C304-36W, dated cetoder 29, 1977 The above DRs identified discrepancies related to over sized and unauthorized welds. The DRs were closed by obtaining telephone approvals from Bechtel's Ann Arbor office en6 neering personnel.
1 Corrective action in the form of indoctrination either to assert 7-s adherence to AWS Dl.1-72 code inspection requirements or
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discouraSe placing unauthorized, oversized fillet velds had
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not been considered.
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Except as noted, no items of noncompliance or deviations vere identified."
3.
Corrective Action The following corrective action has been taken or is planned.
1.
Bechtel duelity Action Request SD-43 vas initiated on September 6,1977 requiring Eechtel Engineering to provide the veld acceptance criteria for sizes in a design document.
1 2.
A PSAR change (Number 0149) has been initiated which specifies the application of tolerances to AWS Dl.1-72 velds on structural steel. Consumers Power is currently reviewing the PSAR change.
3 Upon approval of the PSAR change, specification c-304 " Field Fabrication Repair and Erection of Structural Steel and Miscellaneous Metal" vill te revised clarifying allevable veld sizes on structural steel. The specification vill be issued upon approval of the PSAR change and implemented one week after issuance.
4.
Eachtel 4A, prior to this ite= of noncompliance, began trending
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Bechtel QC Discrepancy Reports. The trending vill provide a s
control on recurrent discrepancies and vill provide for corrective action to preclude recurrence.
The specification change is expected to be issued by Novecler 30, 1977 Oy) t
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