ML19329E786
| ML19329E786 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/23/1973 |
| From: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19329E785 | List: |
| References | |
| NUDOCS 8006170940 | |
| Download: ML19329E786 (4) | |
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Generes Omces: 212 West Micrugen Avenue. Jackson, Micrugen 49201. Area Code 517788 0550 November 23, 1973 i
o MIDLAND PLANT AEC Audit Find 7i gs Docket Nos 50-329 and 50-330 Mr. James G. Keppler, Regional Director Directorate of Regulatory Operations i
Office of Regulation i
United States Atomic Energy Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Keppler:
The attached information is submitted in response to the discrepancies which you found in your audit of the Ann Arbor-Bechtel engineering offices on Septe=ber 10 and 11,1973, and which you identified in your letter to me dated October 24, 1973 We believe that this infomation is responsive to the quest, ions which you have
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raised, delineates the corrective measures taken to prevent recurrence, and specifies the dates by which these actions will be ec=plete.
Yours very truly,
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MIDLAND PLANT UNITS 1 & 2 JOB NO. 7220 4
RESPONSE TO AEC LETTER TO CPCO DATED OCTOBER 24, 1973 AEC Finding No.1 10 CFR Part 50, Appendix B, Criterion-II, states, in part, that: ".
This program shall be documented by written policies, procedures, and instructions..
Criterion XVII of 10 CFR Part 50, Appendix B, states in part that: " Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location, and assigned responsibility."
Contrary to the aboire, the Bechtel Corporation Nuclear Quality Assurance Manual does not include a requirement for retention of records common to activities affecting quality. Furthermore, other quality assurance program documentation dealing vith record retention requirements was unavailable during the course of the inspection.
Bechtel Corrective Action No.1 The Nuclear Quality Assurance Manual is currently undergoing revision to incorporate the requirements for retention of records co= mon to activities affecting quality. Scheduled completion date is March 27, 197k. As an interin measure, a project amendment to the HQAM incorporating record retention is being processed and vill be issued by December 17, 1973.
Bechtel standards and procedures vhich provide requirements in compliance to Criterion II and XVII of 10 CFR,Part 50 and N-45.2 9 are:
1.
Bechtel Engineering Standards, Volume G, " General."
2.
Bechtel Internal Procedures Manual, Midland Units 1 & 2.
3 Bechtel Corporate Record Retention Schedule, dated October 30, 1973.
Requirements contained in the aforementioned manuals, procedures, and standards describe the program for record retention including; location, duration of retention, and assigned responsibilities.
In an inter-office memo from the Manager of Engineering, dated November 2, 1973, project personnel vere directed to comply to the requirements con-tained in the Corporate Record Retention Schedule. Additional controlled copies of Bechtel Engineering Standards, Volume G, have been requested for project personnel and the applicable requirements therein vill simul-taneously be presented to project supervisory personnel.
Full compliance j
to AEC Criterion II and XVII regulations for record retention vill have been ' completed by approximately March 15,197h. Subsequent to March 15, i
the Project Quality Engineer and his staff vill perfom surveillance to assure project's compliance to these requirements.
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AEC Finding No. 2 10 CFR Part 50, Appendix B, Criterion V, states, in part, that: " Activities affecting quality shall be prescribed by docu=ented instructions, proce-dures, or drawings of a type appropriate to the circumstances and shall be accanplished in accordance with these instructions, procedures, or drawings."
The Bechtel Power Corporation Internal Procedures Menual for Midland Units 1 & 2, Section T.5, titled, " Drawing Control and Stick Files" requires that the current revision of each drawing be maintained in the stick files.
Contrary to the above, current revisions of certain drawings were missing fzom the stick files.
Bechtel Corrective letion No. 2 Measures were tchen on September 18, 1973 by Quality Engineering to review all stick files on the project. The stick files were updated in accordance with tho Midland drawing control log.
t Further corrective action taken was a revision to Section 7.5 of the Midland Internal Procedures Manual which now reads in part:
"It is the responsibility of each group to update and maintain its own stick file."
Project personnel direction was provided by the Project Engineer to all project supervisory personnel requiring that this procedure be performed weekly. Additionally, the Project Administrator has been assigned respon-sibility for maintenance of the project record print file (which is the master stick file) in accordance with the Division Engineering Standards, Volume G.
The Project Quality Engineer and his staff vill perform a monthly surveil-lance of the project record print file and the discipline stick
- files to assure adherence to the latest Midland Drawing Control Register.
AEC Finding No. 3 10 CFR Part 50, Appendix B, Criterion V, states, in part, that : " Activities affecting quality shall be prescribed by docusented instructions, procedures, or drawings of a type appropriate to the circumstances.
Contrary to the above:
a.
Procedures to prescribe control of interface activities between design groups were not available for review by the inspector at the time of inspection.
b.
Procedures to prescribe control, issuance, and changes to the Bechtel Corporation Internal Procedures Manual for Midland Units No.1 and No. 2, were not available for review by the inspector during the j
inspection.
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_Page 3 Bechtel Corrective Action No. 3a Requirements regarding design office interface activities are provided in the Nuclear Quality Assurance Menual, Section 2, Procedure No. 6.
SFO Divisional Quality Assurance Management is presently amending the NQAM to include a more detailed definition of engineering design inter-face requirements. This amendment is scheduled for issuance on December 17, 1973. Detailed interface requirements for Project Engineering person-nel are presently included in the Divisional Engineering Standard (Volume G) in Sections 1.3 and G-200 and in the individual Discipline Engineering Standards. The requirements contained in these documents are being incorporated into an engineering department procedure which is also scheduled for issuance December 17, 1973 Bechtel Corrective Action No. 3b The Bechtel Internal Procedures Manual for Midland Units 1 & 2, Revision 1 - now has control serial numbers. Distribution is controlled by a fomal control list for assignments of the manual showing applicable serial numbers and assignments of the manual by recipients name. The Internal Procedures Manual was revised and reissued in accordance with this control procedure on October 19, 1973. All superseded manuals have been withdrawn from use. The Project Quality Engineer and his staff has perfomed and vill continue to perforn periodic surveillance and spot checks to insure that only Internal Procedures Manuals with the latest revisions are in use. A revision block with date and approvals has also been provided.
AEC Finding No, h The AEC Finding indicated that Quality Assurance specifications No.
7220 " 20,-No. 7220-G-21, and No. 7220-G-22 were being used for vendor control in lieu of exhibits 3.6A.1, 3.6A.2 and 3.6A.3 as specified in the Nuclear Quality Assurance Manual (NQAM).
Bechtel Corrective Action No. k As discussed with the AEC Inspector, the appropriate actions to amend the HQAM had been taken prior to the audit. Approval of the use of Specifications No. 7220-G020, 21 and 22 had been granted by Quality Assurance Mana6e=ent and the mechanics for change had been set in motion. The NQAM will be amended by December 17, 1973 deleting references to exhibits 3.6A.1, 3.6A.2 sad 3'.6A.3 Additionally, to preclude repetition of the above finding, the amendment vill provide Midland Project Engineering with the flexibility to respond to changing Quality Assurance require =ents via QA specification changes with proper Quality Assurance approval.
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