ML19329F299
| ML19329F299 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/21/1976 |
| From: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19329F297 | List: |
| References | |
| NUDOCS 8006240664 | |
| Download: ML19329F299 (4) | |
Text
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Stephen H. Howell M
Vice Presodent General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201 May 21, 1976 Mr J. G. Keppler, Regional Director Office of Inspection Enforcement US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDIAND NUCLEAR FIANT NRC ITEMS OF NONCOMPLIANCE INSFECTION REIORT UO 76-02
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DOCKETS #50-329 & #50-330 This letter is in response to the two items of noncompliance addressed in your letter of April 20, 1976 which transmitted the results of your inspection of the Midland construction site on March 16-18 and 24-26,1976.
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G CONSUMERS PO'4ER COMPANY RESPONSE TO T40 ITEMS OF NONCOMPLIANCE DESCRIBED IN NRC INSPECTION REPORT #76-02 I.
FAILURE OF THE VICE PRESIDENT OF_ ENGINEERING INSPECTION FOR US TESTING
'IO AUDIT TEST REPORTS A.
Descriptions of the I!oncompliance (1) From Page 2 of Inspection Report #76-02:
" Contrary to 10 CFR 50, Appendix B, Criterion V, and the U.S. Testing Company QA requirement, the Vice President of Engineering Inspection did not audit test.oports issued to Bechtel."
(2) From Page 8 (Item No 1) of Inspection Report #76-02:
"The U.S. Testing Company QA Manual, in Section 3 5, states in part, that 'The Vice President of Engineering
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Incpection reviews the work of the field group by auditing
\\m, the test reports issued to Bechtel'; contrary to this, no documentation was available to establish that this require-ment had been implemented."
B.
Corrective Steps Taken and Results Achieved In response to this item of noncompliance, the commitment of the US Testing Company QA Manual that "The Vice President of Engineering Inspection reviews the work of the field group by auditing the test reports issued to Bechtel" has been analyzed and determined to be inappropriate.
These test reports should be reviewed during audits but it is not necessary that the Vice President of Engineering In-spection perform the review.
In view of this analysis, US Testing's Audit Reports #1-#8 vere reviewed (Report #9 was being prepared during this review).
In each audit report, the auditor addressed review of test reports issued to Bechtel, but'at no time 11ad the auditor been the Vice President of Engineering Inspection. Audit Reports 1, 2, 3 and h had been sent to the Vice President of Engineering Inspection.
Audit Reports #5-#8 show sign-offs indicating that the reports had been reviewed by the Project Manager.
C.
Corrective Action Taken To Avoid Further Items of Noncompliance
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In order to preclude repetition of similar instances of noncompliance, it has been decided to modify the US Testing QA Manual to delete
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\\--l the require =ent for the Vice Ptesident of Engineering Inspection to audit the test reports issued to 3echtel.
Section 19 of the US Testing QA Manual vill contain the following co==it=ent : "A co=prehensive sys-ten of. planned and docu=er.ted internal audits shall be carried out to annually verify cc=pliance with all aspects of the Quality Assurance Program and to deter =ine the effectiveness of the progra=."
Since test reports issued to Bechtel are a portion of the US Testing QA progra=,
they will be audited annually.
D.
Date When Full Co=pliance Will Ee Achieved Reyision of the US Testing-QA Manual and approval for i=ple=entation of the Midland Plant site is anticipated to be co=pleted by June 26, 1976. This time period is required because the QA Manual is undergoing a =ajor revision.
II.
CORREC?IVE ACTIONS REQUIRED BY THE AUDIT FINDINGS NOT PERPORMED A.
Descriptions of the Jonco=pliance (1) Frc= Page 2 of Inspection Report #76-02:
"Centrary to 10 CFR 50, Appendix B, Criterion xvIII, the U.S.
'"N Testing Co=pany's quarterly internal audits, so=e of the cor-
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rective actions required by the audit findings had not been performed. "
(2) Fro = Page 8 (Ite= No 2) of Inspection Report #76-02:
"After revieving the U.S. Testing Cc=pany's quarterly internal audit report, the auditor's position and qualification could not be deter =ined.
The audit findings and corrective actions taken vere not performed consistently, and so=e audit finding corrective actions had not been taken.
No =anage=ent review and assess =ent of the resolutions were identified.
In addition, audit procedures, handling of audit findings and reaudit requirements are not identi-fied in the QA =anual."
B.
Corrective Steps Taken and Results Achieved In response to this ite= of nonco=pliance, US Testing's Audit Reports
- 1-#8 vere reviewed and the following infor=ation was found:
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(1) Auditor's Position and Qualifications Audit Reports 1, 2 and 5 vere by E. Zadina, Audit Reports 3 and h were by C. Sheridan, and Audit Reports 6, 7 and 6 vere by F. Esposito.
E. Zadina is US Testing's Audit Manager and C..
p Sheridan and F. Esposito work for Mr Zadina. All three auditors
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are not directly responsible for the Midland site activities which they audited. At the time of the audit, each auditor was qualified to the requirements of either the draft ANSI N-h5 2.12 Standard or the draft ANSI N-h5 2.23 Standard.
(2) Audit Findings and Corrective Actions US Testing's audit reports identify two types of audit findings.
The first type is a "nonconformance" based on failure to implement requirements of the QA Program, and the second type is a "recom-mendation for improving the QA Program." All "nonconformances" identified in Reports #1-#8 have been corrected c.nd corrective action has been verified during subsequent audits.
Action has not always been taken in response to " recommendations for improving the QA Program" nor have these items been followed up during subsequent audits, but the audit reports have made it clear that follow-up during subsequent audits was not necessary in that these findings were indicated to be "not an open item."
(3) Panagement Reviev Audit Reports #1-#h had been sent to both the Vice President of
{T Engineering Inspection and the Vice President of Power Generation x,,/
Services.
Audit Reports #5-#8 show review signatures by both the Project Manager and the Vice President of Power Generation Services.
C.
Corrective Action Tak'en To Avoid Further Items of Noncompliance In order to preclude repetition of similar instances of noncompliance in US Testing's auditing program, it was decided that US Testing would re-vise their Quality Assurance Manual to address the auditor's position and qualification, audit findings, corrective action to audit findings, review of audit findings, review of corrective action to audit findings and reaudit of deficient areas.
D.
Date When Full Compliance Will Be Achieved Implementation of the corrective action described in Section "II-B" above is complete. Approval of the revised US Testing Quality Assur-ance Manual for implementation at the' Midland Plant site is anticipated to be complete by June 28, 1976.
This time period is required because the QA Manual is undergoing a major revision.
p HWS/ map 5/19/76