ML19329F312
| ML19329F312 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/29/1976 |
| From: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Keepler J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19329F303 | List: |
| References | |
| HOWE-174-76, NUDOCS 8006250397 | |
| Download: ML19329F312 (6) | |
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General Offices: 212 West Michegan Avenue. Jackson, Michigan 49201 November 29, 1976 Howe-174-76 i
~ Mr. J. G. Keppler, Regional Director Office of Inspection and Enforcement US Huclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDIAND NUCLEAR.PIAUT iiRC ITEMS OF N0HCOMPLIARCE -
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INDPECTION REIORT HO. 76 DOCKETS ICS. 50-329 AND 50-330 This letter is in response to your letter of October 20, 1976 which transmitted the results of your inspection of the Midland construction site on August 9 to September 9,1976, and which requested our written response on three ite=s of 1
' noncompliance.
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.8 006250 l
DEC 11976
B CONSUMERS POWER COMPANY RESPONSE TO ITEMS OF NONCOMPLIANCE DESCRIBED IN NRC INSPECTION REPORT #76-08 V
I.
FIELD ENGINEERING PROCEDURES AND INSTRUCTIONS NOT PROPERLY REVIEWED AND APPROVED A.
Description of the Noncompliance 1.
From Page 2 of Inspection Report #76-08:
" Contrary to Criterion VI of Ap'endix B to 10 CFR Part 50, field engineer-p ing procedures and instructions were not classified, reviewed, and
' approved in accordance with the field engineering procedures or the Bechtel Corporation Nuclear Quality Assurance Manual.
This infraction applies to both Unit 1 and Unit 2."
2.
From Page 14 (ltem No. 4) of Inspection Report #76-08:
"The process and issua'ce of field engineering procedures were identified n
not to be in compliance with p'rocedural requirements established by Bechtel NQAM, and Field Procedure General, FPG-1, Rev. 4, dated May 12, 1975, ' Procedure for Initiating and Processing Field Procedures and Instructions'. The lack of control of Bechtel FIs and fps is considered in noncompliance with the requirements of Criterion VI of Appendix B to 10 CFR Part 50."
B.
Background Infordation Pertinent to the Noncompliance
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Weagreethatcertaininconsistenciesinthecontroloffieldprocedures/
instructions did exist betueen the Ecchtel Huelear Quality Assurance Manual (ECM4), the field procedure for preparation of the procedures (FPG-1) and the existing field procedures. However, a decision had been made on this pr ject not to use procedures prepared by Construction Engineering (when it 5ccame a NQM4 requirement) because field procedures were available and in use at Midland. A N0jul amendment was made on October 22, 1975 to allow procedure preparation in the field.
Through an oversight that amendment did not remove the requirement for certain approvals (which were no longer
" pertinent).
Bechtel had recognized that the field procedure for initiating and pro-cessing field procedurcs and instructions (FPG-1) needed to be revised to be consistent with current practices and were in the process of revising FPG-1.
Also, Bechtel Quality Assurance had identified that Bechtel Quality Control has not been approving field procedures in accordance with the NQAM.
Quality Assurance Discrepancy Report No. 114 was issued on July 15, 1976 (prior to the NRC inspection) to obtain corrective action.
This report required Quality Control to review and approve all existing and future "Q" related field procedures and instructions, and required Field Engiacering to revisc FPG-1 to include Quality Control in the review cycle.
Finally, Bechtel Quality Assurance had reviewed all procedures that they had determined needed review in accordance with their interpretation of 7-~g the NQAM.
This interpretation was documented in a letter of understanding from G. L. Richardson to W. Holub dated September 4, 1975.
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I.
FIELD ENGINEERING PROCEDURES AND INSTRUCTIONS NOT PROPERLY REVIEWED AND APPROVED (Contd)
C.
Corrective Action An additional amendment to the NQAM has been prepared to clarify procedure preparation, approval, and classifications.
This is to be issued to the jobsite by December 15, 1976.
In addition, field procedure FPG-1 has been revised by Bechtel and transmitted to Consumers Power for comments.
This procedure is to be issued by December 1, 1976.
Finally, Bechtel Quality Assurance made an additional check of procedures needing QA review
.and determined that additional procedures should be reviewed. This review will be complete by December 1, 1976.
II.
FAILURE OF BECHTEL QUALITY CONTROL ENGINEER TO IMPLEMENT INSTRUCTIONS A.
Description of the Noncompliance 1.
From Page 2 of Inspection Report #76-08:
" Contrary to Criterion V of Appendix B to 10 CFR Part 50, deficiencies, relative to concrete form work, were not documented in accordance with QC Instructions following a pre-placement inspection performed on August 19, 1976. This infraction applies to Unit 2 only."
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2.
From Pages 14 and 15 (Item No. 5) of Inspection Report #76-08:
"The inspector examined rebar and form installation prior to concrete placement for the Containment Building Unit 2 Missile Shield Walls A, B, and C sections with Pour Identification No. CC (607.0)a'.
- Gaps, as wide as 3/8 inch, were identified in various locations between the wood forms.
The gaps were created by shrinkage of the wood forms as a result of drying during the long delay of concrete placement after
- the forms were erected.
Bechtel representat,1ves stated.that they had earlier found the gaps and had wet the forms to expand the wood and reduce the gap dimensions.
The inspector subsequently concurred with the engineering justification (Bechtel Project Engineer letter BEBC-ll59, dated August 19, 1976) that the reduced gap was acceptable, however, failure of the Quality Control Engineer (QCE) to document his original identification of the problem was considered to be in noncompliance with requirements."
B.
Background Information Pertinent to the M n,anmpliance At the time the 3/8" gaps in the wood forms were noted by the NRC inspector, the hardware problem had been identified by Bechtel Quality Control and corrective action was underway (this consisted of soaking the wood forms with water to cause them to swell and close the gaps).
Corrective action was taken on the same shift that the problem was identified.
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since corrective action was not complete, the problem should have been
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recorded in accordance with the-procedure stated in the Quality Control procedure for nonconforming items.
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FAILURE OF BECHTEL QUALITY CONTROL ENGINEER TO IMPLEMENT INSTRUCTIONS (Contd)
C.
Corrective Action The responsible Quality Control Engineer was instructed to write a dis-crepancy report which was prepared on August 19, 1976.
In order to pre-clude repetition a training session was held cn the procedure for reporting
' incomplete items and discrepancies.
This session was attended by the NRC inspector during the course of his inspection.
Corrective action was complete prior to the completion of the NRC inspection.
III.
INADEQUATE TENDON SHEATH STORAGE PROTECTION A.
Description of the Noncompliance 1.
From Page 2 of Inspect' ion Report #76-08:
" Contrary to Criterion XIII of Appendix B to 10 CFR 50, revised measures established to control the site storage of post tension embedments are not sufficient to provide reasonable assurance that damage or deterioration will be prevented.
This infraction applies to both Unit 1 and Unit 2."
2.
From Pages 15 and 16 (Item No. 6) of Inspection Report #76-08:
"During a previous IE:III site inspection, some tendon sheath end covers were observed blown off.
The matter was considered unresolved as recorded in IE:III Inspection Reports No. 050-329/76-02 and No.
050-330/76-02.
Follow up inspection identified that the storage require-ments were revised in Bechtel document F-1-199 Rev. 3, dated July 21, 1976.
The storage requirements for post tensioning embedments (semi-rigid) sheathing, couplers, trumpet assembly, and funnels are as follows:
' 1.0 Maintenance and inspection activities 1.1 Perform and document a visual inspection of storage conditions for compliance to storage level requirements and notes 2.1 through 2.3 at intervals not to exceed 30 days.
1.2 Correct and document any deficiencies.
2.0 Notes 2.1 Semi-rigid sheathing shall be stored on dunnage in the as receiving condition.
Protective caps or end covers installed by vendor may be removed or retained during the storage period.
2.2 Items received in cardboard boxes shall be stored outdoors
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and do not require,portection from the rain or snow.
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boxes shall be replaced.
2.3 Items in contact with soil or water are acceptable since l
this contact is not detrimental to the material.
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.4 II.
INADEQUATE TENDON SHEATH STORAGE PROTECTION a
A.
Description of the Noncompliance 2.
(Contd)
Inland-Ryerson letter to Bechtel, dated June 11, 1974,
Subject:
Purchase Order 7200-C-2-AC, Post Tensioning System, recommends that ends of tendon sheath bundles should be covered by tarps during shipment and storage.
The revised storage specification provides no protection to the tendon sheath bundle ends or other post tensioning embedments.
The inspector determined that there is no engineering evaluation which justifies deviating from the manufacturer's recommendations.
I The inspector determined that the licensee's storage and inspection procedures do not provide reasonable assurance that post tensioning embedments are protected from damage and material deterioration as required by Criterion XIII of Appendix B to 10 CFR 50."
B.
Background Information Pertinent to the Noncompliance Criterion XIII of 10CFR50(B) states in part:
" Measures shall be established to control the handling, storage,. shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions gs to prevent damage or deterioration." These requirements for the subject
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material n're met by Bechtel documents F-1-199 and F-1-348 (storage require-ments) and by Specification 7220-C-2 (the specification for the post-tensioning systems) as revised by Specification Change Notice C-2-6001 dated April 13, 1976.
The Specification Change Notice represents the engineering evaluation of the storage of these items and was given to the NRC inspector during his inspection.
The inspection report states that storage requirements did not meet the recommendations in the Inland-Ryerson letter of June 11, 1974 with regard to end protection.
This recommendation is taken out of context to the intent of the letter.
The letter states:
. extra cost involved in recovering the ends of bundles with the visqueen.
. or with tarps is nominal and is all that is necessary to protect the ends of sheaths in storage."
And "..
the cost of covering the sheaths with a single visqueen or tarp cover is nominal..."
In both statements, Inland-Ryerson was contending that alternata methods of covering the sheathing ends, in lieu of the original sperification requirements to furnish caps, were adequate for the intended purpose and less costly. _In summary, the June 11, 1974 Inland-Ryerson letter was intended to suggest altcrnatives to a commercial difference and not to define manufacturer's storage procedurcs; this understanding has been confirmed by Inland-Ryerson (now INRYCO) personnel.
In view of the fact that storage procedures were evaluated and approved by the Project Engineering (and Inland Rycrcon concurred) and that those pro--
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cedures have been followed, we do not believe that any item of noncompliance
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i III. INADEQUATE TEIDON SIEATH STORAGE PROTECTION (Contd) j.
C.
Corrective Action In view of the explanation in "B" above we do not believe any corrective action is required.
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