ML19329E435
| ML19329E435 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/18/1976 |
| From: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| HOWE-95-76, NUDOCS 8006160237 | |
| Download: ML19329E435 (22) | |
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Stephen H. Howest f 7'
""f Voce Presodent J4'**
-**J General Offices: 212 West MicNgen Avenue. Jackson. Micnigen 40201 June 18, 1976 Howe 95-76 Mr. J. G. Keppler, Regional Director Office of Inspection and Enforcement U.S. fluclear Regulatory Corcission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEA PLA!iT DOCKETS ~
2 & 50-330 The attached documents are the Consumers Pcuer responses to issues which were raised during your exit interview of M 20,1976.
f Mi In accordance with our conversation of June 11, 1976, Consumers Power will prepare a schedule for imolementation of those activities described in the plans of action. This schedule will also indicate which activities must be completed prior to resumption of "Q" listed concrete placements at the Midland site.
We will transmit this scnedule to you prior to resumption of "Q" listed concrete placements.
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TIME BEIVEEN DESIGN COMPLETION AND CONSTRUCTION A.
ISSUE One possible contributor to the number of Bechtel nonconformance re-ports relative to niscing rebar could Le that there is not a sufficient time lapse between the time that a design is released for construction and the time when construction activity (eg, placement of rebar) begins.
This may not allow time for the necessary preparations (eg, inspection plan preparation, fabrication drawing preparation, rebar fabrication and delivery to the site, etc). An even'more likely contributor would be that design can be changed after it is released for construction.
In fact, the design is regularly changed up to the point of construction and in at least one case (NCR 260) was changed after placement of con-crete.
It would appear that some improvement in the system whereby Bechtel Project Engineering assures that design and, in particular, de-sign changes can be implemented before placing concrete is necessary.
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PLAN OF ACTION It has been found that the current lead time between issuing civil drawings for construction and initiation of rebar placement is about h months.
The lead time in the area of piping is 18 months.
It ap-pears that the b-month and 18-month lead times are satisfactory and there vill be no attempt to change or increase the lead time. On the other hand, there is a need for a more formalized approach to control changes to designs which have been released for construction.
Project Engineering personnel vill be procedurally required to de-termine the status of construction activities pricr to the issuance of design changes to designs which have been released for construc-tion. The purpose of this formalized coordination vill be to assure that design changes can be implemented by the construction forces.
This more formalized approach does not mean that the designer need contact the field about every design change if his review of the con-struction schedule can satisfy him that construction has not proceeded past a point at which his design change vould be difficult or impos-sible to implement. Bechtel vill pursue the following:
(1) Project Engineering vill consider, on a procedural basis, the status of construction prior to issuing a change to a design which is released for construction.
If construction is imminent, Project Engineering vill have procedures to either require the design change be reconsidered or place a hold on construction.
(2) In the future if changes are issued after a construction activity is complete, Bechtel Nonconformance Reports will not be written.
The change vill either be accc=plished or a Bechtel Field Change Request vill be initiated.
Consumers Power vill review the procedural changes resulting from this plan of action prior to implementation.
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DRAWING CLARITY Ah*D COMPLETENESS A.
ISSUE Bechtel engineering drawing requirements for any one pour are shown on a large number of engineering drawings. Generally, a list of the engi-neering drawing requiremente can be prepared by starting with one or tvo basic drawings and following the references contained on those drawings to other engineering drsuing requirements which, in turn, reference still further Bechtel engineering drawing requiremants.
A complete tracing down of all engineering requirements as liuced in the refer-ences vill provide a complete list of drawing requirements.. In.at least one case (relative to Bechtel UCR 396) a critical draving reference was missed on the Bechtel field inspection plan for the concrete preplace-I ment and also was not referenced on the elevation drawing for the cen-crete placement. While some problems have been noted relative to the clarity of engineering drawing requirements, it appears that the source Of problem in this instance relates to the drawing references and, in turn, the ability to prepare a complete list of engineering drawing requirements.
B.
PLAH OF ACTION Bechtel responses relative to this issue have indicated that they under-stand the importance of referencing on engineering drawings and Eechtel will include the adequacy of references and drawing clarity as part of
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the chief engineer's design review procedures.
Field Engineering vill prepare a list of all necessary drawings for the concrete placement. Tnis list vill be for the use of both Field Engi-neers and craft supervision.
Since Quality Centrol vill be held respon-sible for the adequacy of the list which they use, they shall prepare a list independent of Field Engineering activities.
If, during the preparation of the Field Engineering or Quality Control list, it is found that Project Engineering has not provided adequate references on engineering drawings, this lack of references vill be documented by Field Change Requests which are forwarded to Project Engineering for resolution.
Bechtel has a procedure which requires maintaining this documentation for purposes of a feedback system to determine if Project Engineering, based on the number of problems encountered, should revise its system for providing references.
Consumers Power vill review the procedural changes resulting from this plan of action prior to implementation.
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DESIGN ENGINEERING REVIEW AND APPROVAL OF FABRICATION DRAWINGS AND CHANGES THERETO A.
ISSUE A revic'v of those nonconformances which relate to missing icbar has dem-onstrated that therr vere cases, where Bechtel nonconformance reports were issued, in which the fabrication drawings or field sketches were in error.
Since,these fabrication drawings and field sketches are used during the installation of rebar and have been used in the inspection of rebar placement, these errors in fabrication drawings may have contributed significantly to the deficient rebar placement.
B.
PLAN OF ACTION Consumers Power has evaluated the Bechtel position relative to review and approval of fabrication drawings.. Bechtel vill change its syst,em to require the Project Engineering group review and approve all fab-r? ation drawings which are used by field forces for the installation and inspection of rebar placements.
In addition, Bechtel vill complete the following studies and provide recommendations to Consumers Power:
(1) Determine if the Project Engineefing grcup in the Ann Arbor office or a Project Engineering group at the Midland site should perform the review and approval of fabrication drawings.
(2) Prepare a list and description of the nature and use of each type of field sketch which relates to rebar placement and determine if Field Engineering or Project Engineering should be respcnsible for review and approval of each type of field sketch.
(3) Determine when the modified review and approval program can be implemented.
Since Bechtel Project Engineering vill review and approve the rebar fabrication drawings used for rebar placement, Bechtel Quality Control may use fabrication drawings for inspection of rebar placement. Also, Quality Control may only use those detailed field sketches chich are reviewed and approveu by Project Engineering.
Consumers Power vill review the chanced procedures and studies resulting from this plan.of action prior to implementation.
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DESICI CHANGE NOTICE IDG3 USED CORRECTIVELY AND EFFECTIVELY A.
ISSUE During a recent HRC inspection at the site, Mr Yin found that each month n'Drawin6 Change Notice (DCU) log was bein6 transmitted to the site.
He was concerned that this log was not being uced to check that all the DCDs had been received during the month.
Therefore, he was concerned that Ann Arbor may haye issued DCNs but that they had not arrived at the site where they sould have to be implemented.
~B.
PLAN OF ACTICN Consumers Power site Quality Assurance personnel have reviewed the Bechtel system for control of DCNs.
It was found that when DCUs are sent from Ann Arbor, they are sent using a 2-part transmittal form.
The field signs the transmittal form and returns one part of the fo,rm to Ann Arbor.
It is' Ann Arbor's responsibility to see that the field returns a signed copy of each transmittal form. If a signed copy is not returned, follov-up by Ann Arbor is necessary. This system for control of drawing change notices is very similar to the system used to control all Quality Assurance documents which must be controlled in accordance with Criterion 6 of Appendix B.
Since the DCU log is used as a serial index and it is only issued once a month, use of the DCU log to verify receipt of DCNs would not contribute substantially to. -
the control of DCUs. This position vill be explained to the NRC inspector.
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QC INSPECTION ADEQUACY A.
ISSUE A common thread associated with missing rebar NCRs was that in each case Bechtel Quality Control failed to detect the missing rebar prior to sign-off of the preplacement inspection plan.
Specifically, it was found that QC did not adequately inspect rebar to verify con-formance to applicable drawing requirements. This improper inspec-tion raises the question as to the adequacy of the training and qualification of QC inspectors.
B.
PLAN OF ACTION As is discussed under Topic 18 " Lack of Attention to Detail," Bechtel Quality Assurance has committed to an overall review of the Bechtel training programs.
Improvement in the training programs resulting from that review will improve QC inspection activities.
During the Consumers Power review of the question of QC inspection activity, consideration was given as to whether Consumers Power should hire a third party quality control organisation to perform inspections at the Midland site. At this time it appears the corrective action which Bechtel Quality Control has developed in response to rebar UCRs as well as in response to the NRC concerns, as expressed in their exit interview, in general, should provide adequate improvement of the 3echtel Quality Control program.
On the other hand, it appears that one of the problems associated with the Bechtel Quality Control inspection activity is that the Bechtel Quality Control Field Inspec-tion Manual assigns the duty of an interpretation and clarification of engineering requirements te Field Engineering.
In some cases, Field Engineering has not properly interpreted or clarified engineer-ing requirements.
Quality Control is responsible for the adequacy cf interpretations and clarifications of engineering requirements which form the basis of their inspection. Therefore, Quality Control shall obtain its documented interpretations and clarifications of engineering requirements from Project Engineering rather than from Field Engineer-ing.
Bechtel Quality Control vill revise the appropriate procedures to address this topic.
A review was also made relative to the need for Consumers Power to continue to perform its overlay inspection of rebar.
It was decided that.as of this time, Consumers Power vill continue overlay inspection of Bechtel Quality Control inspections of rebar placement, at least until the significant portions of corrective action taken in response to rebar problems have been implemented.
Further, we vill continue the overlay inspections for some period after that in order to evalu-ate the effectiveness of this corrective action.
Upon completion of the overlay inspections, Consumers Power Quality Assurance vill perform periodic overlay inspections as a portion of its site audit program.
Consumers Power will review the change to procedures which' vill be made as a result of this action plan prior to implementation.
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QUALITY CONTROL SURVEILLANCE AND INSPECTION DOCUMENTATION A.
ISSUE.
The Bechtel Quality Control pro 6 ram does not require the results of in-process inspections to be documented.
It does not require defi-ciencies found during in-process surveillance 'o be documented.
It does not require the documentation of deficiencies which are found during final inspection but which are corrected prior to completion of the inspection.
b B.
PLAN OF ACTION Bechtel has reviewed its position relative to this documentation and will make programmatic changes.
Preparation of these programmatic changes vill give consideration to development of another deficiency.
reporting mechanism other than that described in the FIM Section G3.~
They will provide mechanisms for recording that which is found ac-ceptable and that which is found unacceptable. The development of their new program will give censideration to the requirements of Criteria 15, 16 and 17 of 10 CFR 50, Appendix B.
Development of this program vill also require review of those problems which the NRC found during inspectionc elsewhere. Consumers Power vill review and comment on the changes to the Ecchtel QC program prior to in-plementation of the changes.
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LACK OF DETECTION OF QC PROBLEMS BY CA A.
ISSUE During a recent NRC inspection at the Midland site, inspectors found that Quality Control was using rebar fabrication drawings for checkout of rebar placements.
Also, the NRC found that QC was not documenting all deficiencies found during i.nspections.
Both of these problems, in the opinion of the NRC, _ should have been detected by either Bechtel or Consumers Power Quality Assurance during their audits and surveillance.
The issue discussed here does not relate to the problems noted by the NRC inspector (these problems and their corrective actions are discussed under other topics) but rather, this issue relates to why neither Consumers Power nor Bechtel Quality Assurance discovered the problems.
B.
PLAN OF ACTION Each of the two instances identified by the NRC has been reviewed by Consumers Power to determine why neither Consumers Power nor Bechtel Quality Assurance had detected the problems during their activities and to determine how future similar problems can be detected. Fol-loving are the results of these reviews:
(1) QC use of fabrication drawings.
On March 3, 1975 Bechtel Quality Assurance issued Management Corrective Action Report (MCAR) Ho 10 based on an instance of missing rebar ties in the auxiliary build-ing. In response to this MCAR, Bechtel Quality Control committed to using the design drawing as "the primary acceptance document" but references to the field sketch (ie, rebar fabrication drawing)
"as a supplementary document" could be used. Bechtel Quality Control also ecmmitted to conduct a training session on the use of drawings.
Bechtel Quality Control did not ec==it to use only engineerins drawings to the exclusion of fabrication drawings for inspection.
On the other hand, one of the causes of the missing rebar ties was that the rebar fabrication drawing did not accurately reflect the engineering drawing require =ents.
The Bechtel QC commit-ments relative to the use of design drawings and rebar fabricatics drawings were intended to be responsive to this cause.
When the NRC found that a Quality Control Engineer was using a fabrication drawing as an inspection tool (apparently he was marking up the fabrication drawing when he verified that bar had been placed), they assumed that the QC Engineer was not acting in compliance with the program of corrective action developed in response to MCAR No 10.
j Whether the QC Engineer was in compliance with th'at program of corrective action could not be evaluated by either Bechtel or j
Consumers Power Quality Assurance because no documented pro-l cedure or instruction had been prepared to describe the use of the design drawings and fabrication drawings for inspection I
activities.
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Had Bechtel Quality Control provided procedures or instructions which contained an explanation of what was meant by using fabrication drawings as " supplementary documents" or "for reference only," both Bechtel and Consumers Power Quality Assurance would have been able to verify compliance with Bechtel QC commit =ents.
The problem then is not -- that neither Bechtel nor Consu=crs Power Quality Assurance failed to detect this problem -- but that they (Bechtel) did not require the corrective action com-mitted to in response to MCAR No 10 be described in documented procedures or instructions which clearly defined the use of fabrication drawings.
In response to this problem, in the future, both Bechtel and Consumers Power Quality Assurance personnel vill be given documented (procedure or letter) instructions to review those Bechtel corrective actions which are taken to pre-clude repetition to assure that (when appropriate) these actions are adequately addressed in documented procedures or instructions.
(2) QC was not documenting all deficiencies found during inspections.
When Bechtel QC found deficiencies during its inspection activities and those deficiencies could be corrected prior to sign-off of the inspection plan, they were not documented.- This lack of docu=enta-tion is in compliaace with Bechtel Quality Control procedures (Field Inspection !!anual and QC Notices Manual) in that they permit (but do not equire) writing of Honconformance Reports vhen deficiencies can be corrected prior to completion of in-
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spections. On the other hand, failure to document these de-ficiencies is not in compliance with the requirements of 10 CFR 50, Appendix B, Criteria 15 & 17.
Both the Consumers Power and the Bechtel site Quality Assurance activities verify that Bechtel procedures are being implemented but in this case that verification should also have verified that the implementa-tion met the requirements of 10 CFR 50, Appendix B.
Preceding recent NRC inspections, Consumers Power quality Assurance has placed increased emphasis on the need for site Quality As-surance personnel to verify that the requirements of 10 CFR 50, Appendix B and applicable ANSI Nh5.2 standards are being imple-1 mented. Evidence of the effect of this increased emphasis has been observed in Consumers Power UCRs No QF-Th. -75, -87, -100,
-101 and -103 which are based on the requirements of Appendix B j
or the ANSI standards.
In addition, Consumers Power is initiating a procram to reviev and approve Quality Control Field Inspection Procedures and Project Special Provision Notices.
The review and approval vill be based (in part) on the requirements of 10 CFR 50, Appendix B and the ANSI Nh5 2 standards.
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TREND ANALYSIS A.
ISSUE Had either Consumers Power or Bechtel realized that instanc.es of missing rebar represented a trend of conditions adverse to quality at an earlier date, sufficient corrective action could have been
. developed to climinate or minimize recu' rence.
The NRC takes the r
position that not only should quality assurance personnel be respon-sible for detecting trends but also Field Engineering, Quality Control, and possibly Project Engineering should be responsible for detecting trends.
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B.
PLAN OF ACTION Bechtel Quality Assurance has prepared and is in the process of imple-menting a draft procedure for trend analysis of Nonconformance Reports, Quality Audit Findings, Quality Assurance Deficiency Reports, Suppli~er Deviation Disposition Requests, MCARs and other Bechtel nonconformance reporting mechanisms.
Consumers Power Quality Assurance has provided Bechtel with the CP Co comments on the trend analysis program and will also make arrangements for a feedback to Consumers Power Quality As-surance on the results of the trend analysis program.
In addition to trend analyses, the Bechtel program vill also address single instances -
of nonconformances which represent "significant conditions adverse to quality." This is further discussed in Topic 16.
Quality Assurance is the only Bechtel organization which vill be re-quired to have for=al trend analysis programs. Project Engineering, Field Engineering and Quality Control will not be required to implement formal trend analysis programs.
Consumers Power vill review the changed proce'dures resulting from this plan of action prior to implementation.
In addition to the Bechtel trend analysis program, Consumers Power Quality Assurance vill also begin to conduct formal trend analyses on the Consumers Power nonconformance reports and audit findings. As of this time it appears that the Consuners Power Quality Assurance trend analysis program will be modeled in a similar fashion to the Bechtel trend analysis program.
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9 CP CO INVOLVEMEHT IN BECHTEL SITE UCRK plant!ING MEF1 RINGS A.
ISSUE During the NRC exit interview, Mr Selby indicated some concern as to how Consu=crs Power became aware of plans for construction' activity.
During that meeting, Mr Selby suggested it might be advisable for Consumers Pouer personnel to attend the daily Bechtel work planning meetings.
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B, PLAN OF ACTION The desirability of attending these mee' tings has been reviewed by Midland project management organization personnel with Bechtel per-sonnel.
It is Bechtel's position that Consumers Power is velecte to attend those meetings.
T. C. Cooke has reviewed the mechanisms whereby both Quality Assurance and Project Management Organization personnel are informed of the Bechtel construction plans and har identified five types of routine Bechtel meetings which Censumers Power personnel vill attend, for a trial period, to evaluate the benefits of continued participation.
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FORMAL ASSIGNMENT OF QC ASSIGUMENTS A.
. ISSUE Bechtel Quality Control does not have a formal system for a,ssignment of personnel to such activities as the preparation of inspection plans or for the assignment of personnel to actually perform inspections.
The assignment of responsibilities is informally handled by the Lead Discipline Quality Control Engineers.- While the NRC during their inspections did not find problems in'this area, they indicated that problems could arise in the future.. One example of such problems would be a man conducting inspection on.rebar placement prior to making a pour and that inspection was based on a series of surveil-lances that had been conducted day by day over an extended period of time.- At some time prior to the pour, his assignment had to be transferred due to illness, absence or other cause. The mechanism for informing the nev Quality Control Engineer (who would be complet-ing the inspection) as to the status of the activity is not defined.-
Therefore, the nev Quality Control Engineer might not do everything during inspection that the other Quality Control Engineer would have done had he been available and important inspection activities could be missed.
B.
PLAN OF ACTION
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Bechtel Quality Control has looked at the NRC concerns in this area and vill modify its Field Inspection Manual, Procedure G6, to clarify assignments of responsibility to individual QC Engineers for the preparation, reviev, approval, distribution, use, sign-off and filing of inspection plans and records.
Consumers Power vill review and comment on this modification prior to its implementatica.
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USE OF NCR TO C0!! TROL DESIGN CHAllGES MADE APITR C0f!STRUCTION A.
ISSUE Bechtel MCR 260 represents (in part) a situation where robar placement does not conforn to the requirements of an engineering drawing because the drawing requirements vero changed after the pour was made.
The Bechtel program requires t'.e issuance of a Uonconformance Report when design has changed after an activity is complete. This may not be an appropriate mechanism for handling this situation.
B.
PLAN OF ACTION Bechtel vill change its program so in the future, Nonconfor=ance Reports need not be written when design is changed after en activity is complete.
In lieu of this (using the NCR), Bechtel Field Engineering vill either implement the design change or prepare a Field Change Request.
In addition, the plan of action des'cribed-for Topic 1 vill be useful in preventing further instances of changes to design after completion of construction.
Consumers Power will review the procedural changes resulting from this plan of action prior to implementation.
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FIELD EUGINEERS SHOULD HOT BE MAKING DESIGH DECISIOUS A.
ISSUE During the NRC inspection, the NRC found some evidence that Field Engineers are making decisions which, in their minds, should not be made by Field Engineers but should be made by Project Engineering.
They cited as a specific example Bechtel Honconformance Report 276 which related to an incident in which rebar was cut which would have interfered wi% a liner plate penetration.
In accordance with instructions fron Project Engineering, a sketch was sent to Project Engineering showing what had been done; this was transmitted by letter.
It appears that a Field Change Request should have been sent prior to cutting the bars in question. Project Engineering did concur, in writing, with cutting the bars prior to embedding the bars in concrete.
B.
PLAN OF ACTION In order to assure that Bechtel Field Engineers did not exceed their authority, Bechtel vill review the design-related responsibilities of Field Engineers.
Bechtel vill also review overall job responsibilities for Field Engineers.
CP Co Project Management Organication vill be meeting with Bechtel on this subject to resolve questions and reach agreement.
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- 13. LACT OF CLARITY IN NCR WRITE-UPS A.
ISSUE In reading Bechtel Nonconformance Reports, in some cases it has been found that' the Nonconformance Reports are not written clearly enough to accurately describe the nonconforming condition so that the reader of the report can undergtand the problem.
For example,Ilonconformance Report 260 contained incorrect information as to the extent of the nonconformance.
If nonconformances are not clearly defined, it is difficult to judge the importance of the nonconformance to quality and it is also difficult to determine the necessary disposition of the nonconformance.
B.
PLAN OF ACTION In response to questions relative to clarity of Bechtel Ncnconfor=ance Reports, Bechtel has indicated their Quality Assurance Trend Analysis
- pro 6 ram vill serve as a review of Bechtel !!onconformance Reports for clarity.
In addition, Consumers Power vill develop a formal program for review of Bechtel Honconformcnce Reports.
This formal program vill, among other things, address the subject of clarity of descrip-tion of the nonconforming conditions.
Bechtel Quality Control vill also provide mechanisms to modify Non-conformance Reports when it is found that the description of the nonconforming condition is not sufficiently clear or accurate.
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IHADEQUATE EVALUATIONS OF UCRs FOR 50.55(e) REFORTABILITY BY EECHTEL A.
ISSUE Bechtel NCR 260 represented an instance where significant numbers of rebar were left out of poured concrete. The Bechtel program did not require that an analysis of the safety implications of this nonconform-in6 condition (had the nonconforming condition remained undetected) be made by Bechtel Engineering.
B.
PLAN OF ACTION
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Bechtel has evaluated their system for 50.55(e) Reportability and will '
modify the system for determining when nonconforming ccndition reports should be forwarded to Project Engineering for an analysis of the safety implications of the nonconforming condition.
Prior to sending these, nonconforming condition reports to Engineering for review, however,'a screening process vill be established (based upon requirements of 10 CFR 50.55(e)). It will require Quality Assurance to screen out insignificant nonconfor=ing conditions -- conditions which were caught by the routine Quality Control inspection pro 6 ram and those conditions which cannot be related to the safety of operations of any ccmponent of the power plant. Bechtel vill issue procedures relative to new handling mechanisms for 50.55(e). These procedures will include mechanisms for documenting the reasons why the deficiency is not considered to be reportable.
Consumers Pover vill review the modified procedures prior to implementation.
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15-1 15 LACK OF PROCEDURES AlfD INADECUATE PROCEDURES FOR REPAIR A.
ISSUE NRC inspectors found that Bechtel did not have procedures for drilling and grouting of robar devels.
The issue of whether or not Bechtel should have had procedures for drilling and 6 routing vill be addressed after receipt of the URC inspection report, but the finding decs raise questions as to whether adequate systems are implemented by the project to assure that necessary work procedures are available.
B.
PLAN OF ACTION The Bechtel program for development of field procedures has been re-viewed.
It has been determined that it is difficult to provide ab-solute guidance for when procedures must be prepared. Therefore, in order to resolve thic issue, Bechtel vill develop a list, identifying activities for which procedures must be developed.
Consumers Power-Quality Assurance and Project Management personnel vill reviev and comment on this list.
In the future, copies of site work procedures vill be reviewed and approved by Consumers Power Project Management Organisation (PMO) personnel prior to implementation.
Q-List related procedures will be forwarded by the PMO to Quality Assurance for reviev.
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16.
LACK OF CORRECTIVE ACTION TO PRECLUDE REPETITION A.
ISSUE Bechtel did not implement their procedures (FIM G-3, Section h.10) relative to obtaining corrective action to preclude repetition of missing rebar.
B.
PLAN OF ACTION U.
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Bechtel vill change its Field Inspection Manual Procedure G-3, Para-graph 4.10 to delete the current commitments and to add a description of Quality Control responsibilities for corrective action to preclude 3'
repetition of errors and mistakes made by QC personnel.
In addition to changing the FIM Procedure G-3, Eechtel Quality Assurance vill ad. dress the significance of Eechtel UCRs in their trend anclysis program.
Consumers Power vill review the chan6es to Bechtel procedures which result from this plan of action prior to implementation.
Consumers Power vill also include in its review of Eechtel NCRs, re-tiuirements for consideration of Criterion 16 of 10 CFR 50, Appendix B.
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- 17. METHOD TO GIVE ASSURANCE WAT REBAR IS NOT MISSING ELSDGERE A.
ISSUE Since each missing rebar NCR represents an instance where deficient rebar placement had not been detected by the mechanism defined in the Bechtel QA program (ie, by QC during final inspection prior to pouring concretc), there may be other instances where rebar is raissing in placed concrete. The issue then is, "How can Consumers Power be as-sured that this is not the cese and:if it is the case, how can Consumers Power be assured that the structures' involved are or vill be satisfactory?"
B.
PLAN OF ACTION In order to provide Consumers Power the.'ecessary assurance that the structures will perform their safety-related functions, Bechtel vill,
(to the extent practicable) have its QC groto reinspect all exposed 7ebar at construction joints (ie, that rebar'which protrudes out from prev;ous pours) utilizing both design drawings and rebar fabrication drawings.
Utilizing the results of this study, Bechtel Engineering vill demonstrite that there is an adequate degree of confidence that the study is repre-sentative of the installed structure, Consumers Power vill review the results of the Bechtel studies.
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18.
LACK OF ATTENTION TO DETAIL A.
ISSUE The instances of missing rebar indicated lack of attention,to detail on the part of Field Engineers, craft supervision and Quality Control Engineers.
It is possible that the reasons for this lack of attention to detail may be related to inadequate preparation (ie, training, skills, and qualifications) of Bechtel personnel.
B.
PLAN OF ACTION In response to this problem, Bechtel Qu'lity Assurance vill conduct a
an in-depth review of the training and qualification programs of all Bechtel organizations involved in implementing the Midland Quality Assurance Program. The basis of this in-depth review vill be the Bechtel NQAM,Section V, No 6.
In this review, the following Consumers Power criteria for Bechtel training programs for persons implementing the Quality Assurance Program on the Midland Project shall be addressed:
(1) Establish training requirements for each type of position. These training progre=3 vill not only relate to the Quality Assurance aspects (eg, Bechtel Quality Assurance Policies and Procedures) but also vill relate to those technical aspects of the position where training in addition to experience and educational require-ments is considered necessary by Bechtel.
(2) Training in QA problems experienced to date.
(3) The Bechtel program for training must establish that this training must be given to personnel prior to assigning personnel to the performance of safety-related activitics addressed by the training program.
(h ) The Bechtel program should' establish mechanisms to evaluate the effectiveness of the training program.
(5) Each Bechtel employee performing safety-related activities must have training on the importance of doing his job correctly.
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Consumers Power expects to receive a report from Bechtel Quality Assurance describing the results of their ia-depth review and pro-viding action schedules where these results indicate improvements are necessary in the Bechtel training program. This report vill address all training relative to the Quality Assurance Program.
Consumers Power vill evaluate this report and its recommendations prior to the implementation of the recommendations.
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.a 19 ~ STORAGE PROCEDURES AI!D It'PLEMENTATION A.
ISSUE During a recent NRC Midland site inspection and as the result of Consumers Power Quality Assurance audits and surveillance,.a number of problems have been raised relative to the implementation of the Bechtel progran for stcrage of components at the site. NRC personnel have pointed out instances where tarps' covering NCSS components have been ripped, where spacer blocks betvcen tarps and components have been installed when not called for by procedure and have not been installed when they have been called for by procedure, and Quality Control in-spection procedures have not been fully implemented. Consumers Power Quality Assurance personnel have also identified a large number of deficient storage conditions to Bechtel.
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B.
PLAN OF ACTION Bechtel is preparing a new adequately sized, fenced storage area whi'ch vill be controlled. This should alleviate problems relative to storage maintenance. Eechtel has also reviewed its storage procedures and has eliminated some overcom=itments.
In addition, Bechtel has revised its organization to assign personnel responsible for the maintenance of storage conditions.
'"hese personnel vill be able to draw on workmen to promptly correct deficient storage conditions.
Also, Bechtel has de-veloped a mechanism for documenting stcrage deficiencies in accordance with the requirements of ANSI Nh5.2.2.
Consumers Power vill review the Bechtel activities relative to this plan of action.
q 6/s/76 O'
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20-1 3
20.
CP C0 FIELD AUDITS - ACCOMPLIS 131ENT OF SCHEDULE A.
ISSUE During the URC inspection relative to rebar problems and implementation of previous Consumers Power commitments, NRC personnel foun'd that site Consumers Power Quality Assurance personnel were not fully implen.enting the commitments of the site Quality Assurance schedule.
B.
PLAN OF ACTION Is Another Quality Assurance En6 neer'has been added to the Consumers Powe,r i
site Quality Assurance group.
In addition, a revision to the Quality Assurance Services Department Procedure Ho 12 which relates to site audits will be made to allow mere flexibility in the format of the audit schedule. This revision vill also include a requirement for a letter to the Project Quality Assurance Administrator at the end of each month stating which audits were missed and the reasons for their being missed.
Subsequently, the Project Quality Assurance Administrator and the Project QA Superintendent will f.evelop any corrective action necessary.
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6/5/76
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'v 21.
ENGINEERING TRAINING A.
ISSUE Consumers Power Quality Assurance Program Policy No 2, Section 3.h states:
"To assure that safety-related operations and activities are performed correctly, Consumers Power... requires Principal Suppliers to have formal training programs.
These training programs include general, continuing and specialty training.
Training is accomplished in accordance with documented in-structions with the objectives of indoctrinating personnel in disciplines such as Quality Assurance, testing, operation, maintenance, radiation protection, site emergency situations, industrial safety and security, etc.
" Training is also accomplished to aid in developing specific job skills and updating and maintaining these skills."
Bechtel Engineering Department Procedures do not require that design engineers below the level of the group leader be formally trained.
However, these personnel perform a safety-related design activity.
B.
PLAN OF ACTION As is discussed in Topic 18_" Lack of Attention'to Detail," Bechtel Quality Assurance has committed to an in-depth review of all Bechtel training programs related to the Quality Assurance Program.
Implementation of the results of this review vill improve the training programs for engineers.
There is, however, the additional question as to the level to which Bechtel design personnel should be trained.
It is Consumers Power Quality Assurance Department's position that design engineers below the level of the design group leader should receive formal training.
First, this training should relate to design engineer's implementa-tion of the Bechtel Quality Assurance policies and Engineering Depart-ment procedures relative to their activity.
Second, design engineers should be trained in the use of the Midland PSAR, the use of design criteria documents and the importance of Quality Assurance, especially to the Midland Project.
Consumers Power will review the revised Engineering Department pro-cedures relative to trainin6 prior to implementation.
6/16/76
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