ML19329F315

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Discusses NRC 760813 Notice of Violation Listing Five Items of Noncompliance.Submits Comments on Positive & Mitigating Circumstances Re Dowel Placement Instruction & Insp Documentation & Deficiency Documentation
ML19329F315
Person / Time
Site: Midland
Issue date: 10/29/1976
From: Howell S
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Thompson D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML19329F303 List:
References
HOWE-157-76, NUDOCS 8006250402
Download: ML19329F315 (5)
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ilC,g.17 General Omces: 212 West MicNgan Avenue.. Jackson. MacNgan 49201 October 29, 1976 Howe-157-76 Mr. Dudley Thc=pcon Acting Director Division of Field Operations Office of Inspection and Enforcement US Nuclear Regulatory Cc==ission Washington, DC 20555 MIDIAND NUCIFAR PIANT DOCKETS #50-329 & 50-330 Your letter dated August 13, 1976 to Mr. John Selby of Consu=ers Power Coc p y enclosed a " Notice of Violation" which listed five items of non-o=pliance. Your letter states that in view of ccrrective actions already ken or co==itted to by Consumers Power Company, no response to those ite=s of nonco=pliance is necessary. Ecwever, we do not feel that the de

-iptions cf the ite=s of nonce =pliance in the enclosure to your letter

  • fuu.y describe all the circu= stances at the time which tend to explain posi-tive and citigating circu= stances. Most, if not all, of these items had b:en discussed with the Nuclear Regulatory Cc==ission personnel but have not appeared in any published report or letter, and we would like to take this opportunity to present them.

l 00NSDERS PCWER COMPANT'S CCEENTS ON RRC "IOTICE OF VIDIATICIT' OF AUGUST 13, 1976 l

t Infraction #1 "10 CFR Part 50, Appendix 3, Criterion V, states in part, ' Activities affecting quality shall be prescribed by documented instructions, proce-(ures, or drawings....'

' Contrary to this require =ent, documented instructions were not available for the drim g and placement of reinferce=ent steel dowels which were n

1 eing i= bedded in the concrete structure to replace omitted rebar."

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While docu=ented instructions were not available for perfor=ing the i

V "dri.12.<ntt nna place =ent" of devels, Bechtel 0.uality Control did have

' cu.cuted instructions fcr the hspection of this activity,

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Q-v In a~ ditien to the documented instructions for inspection of this activity, b.

d other i=portant parameters for performing the work were also docu=ented in that engineering personnel defined the required depth of devel installation, and site personnel did follow =anufacturer's instructicas for grouting.

These instructions were on the bag of grout =aterial.

c.

The questien of whether or not docu=ented instructions are required for specific work activities is often not cleer-cut. A great deal of judgment is required. It should be noted that the above citation frc= Criterion V of 10 CFR 50, Appendix B, stops just short of the key words "of a type appropriate to the circumstances." It is this phrase of "of a type appro-priate to the circumstances" which calls for judg=ent. It should be pointed out that Bechtel personnel at the Midland construction site have had a proce-dure which provides guidance as to when docu=ented instructions are appro-priate.

Based on this guidance Bechtel cencluded that docu=ented instruc-tions were not necessary. Subsequent to being notified of this "inhaction" Bechtel has re-reviewed its position and continues to believe that documented

$nstructions are not necessary. In an " honest difference of opinion" Consumers Power has concluded that documented instructicas are desirable; and, therefore, Bechtel is in the process of preparing these instructions.

d.

To our knowledge, all drilling and place =ent of rebar devels have been prop-erly perfor=ed even though documented instructions were not available.

I raction 5-2 "10 CFR Part 50, Appendix B, Criterion V, states in part, ' Activities affecting quality shall be prescribed by docu=ented instructions, procedures, or drawings...

and shall be acco=plished in accordance with docu=ented inntrnetions, procedures, or drawings....'

"Bechtel Power Corporation Field Inspection Procedure G-3, which i=plements the

, requirements of Criterion V, states in Section 4.10.1 and 4.10.3 that, 'The PFQCE (Project Field Quality Control Engineer) sbil route a copy of the ce=pleted

' ECR to the organization responsible for control of the activity which apparently caused the nonconfor=ance. Each such organization will e aluate the feedback i

infor=ation provided by the UCR and initiate whatever cerective action =ay be warranted to prevent recurrence.' and 'The FFQCE shall aL:o route a copy of the co=pleted NCR to the site CAE for his evaluation and use in deter =ining the need for corrective action to prevent recurrence.

  • Contrary to these require =ents, nonconfor=ance reports concerning reinforce =ent l

steel deficiencies were not adequately evaluated to determine the need for cor-rective action to prevent recurrence, either by the orgar.ization responsible for control of the activity or by the quality assurance engineer."

,b

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Cc== ente s-Upon review of the cited section of Field Inspection Procedure G-3, it was decidcd that the routing of "a copy of e.yleted NCR" was not an appropriate r=chcn$ss for initiatica of corrective actica to prevent recurrence. Therefore,

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'the problem here, in part, is not so =uch that Bechtel personnel did not imple=ent their procedures but that the procedures did not describe a very effective =echanism to develop a program of corrective action to preclude repetition.

b.

While the cited section of Field Inspection Procedure G-3 did not define a very effective =echanism to develop a program of corrective acticn to preclude repetition, there have been other =echanisns which have been used to develop progra=3 of corrective action to preclude repetition.

These progra=s have been developed based pri=arily en consu=ers power and Bechtel Quality Assurance Depart =ent reviews of 3echtel ITenconfer=ance Reports. When either of these organizations observed that corrective ac-tion to preclude repetitlen should be taken in response to either single or multiple instances of nonconfor:ances, those steps have been taken to modify the Quality Assurance program to preclude repetition of the noncon-formances.

c.

The need for corrective action to preclude repetition of concrete reinforce-ment steel deficicneies was identified by both Consumers Power and 2echtel Quality Assurance Organizations and forceful corrective action taken.

(Ref: CPCo NCR QF-36 which resulted in Stop Work Order #FSW-6 dated Dece=ber 5, 197!+ and Stop work order #FsW-7 dated March 22, 1976 based on Bechtel NCR's (V

  1. 396, 398 and 399; and Bechtel McAR plo dated March 3,1975 based on 3echtel 7

NCR's #295 and 326) We brought each of these deficiencies to the attention of the IGC I&E Region III office at the time. 7nere subsequent proble=s with reinforce =ent steel place =ent arose, previous corrective actions to preclude repetition were re-evaluated and, when appropriate, vere i= proved.

Infraction #3 "10 CFR Part 50, Appendix 3, Criterion X, states ia part, 'A program for inspec-

, tion of activities affecting quality shall be established and executed by or for the organizatien performing the activity, to verify confc:- ance with the docu=ented instructions, procedures, and drawings for acec=plishing the activity....

Exc=ina-tions, measurements, or tests of =2terial or products processed shall be perfor=ed for each work operation where necessary to assure qualitf.... '

  • " Contrary to the above, in sc=e instances installation of reinforcement steel on cafety-related structures requiring inspectica were not adequately inspected to verify conformance with applicable drawings."

l Co==ents a.

It should be noted that while so=e rebar placements were not adequately inspected, a review of nonconfor=snees related to =issing rebar showed that i

less than 0.1 percent of the required rebar was missing in the installed structures.

In each instance where rebar was found to be =issing, either

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t'ae bar in questien was installed er an engineering analysis de=enstrated i

th.t the rebar was not necessary. In sc=e cases =cre bar than that required F, ogiricering drawings was included in concrete place =ents.

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I about missing rebar up to this time have been precipitated by Consumers Power informing the IEC about the proble=s.

Infraction 55 "10 CFR Part 50, Appendix B, Criterion XVII requires in part that, ' Sufficient records shall be maintained to furnish evidence of activities affecting qualit'f.

The record shall include at least the following:

Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses.... Inspection and test records shall, as a minimum, idenbify the inspector or data recorder, the type of observation, the results, the accept-chility, the action taken in connection with any deficiencies noted. Records shall be identifiable and retrievable....'

  1. Contrary to this requirement, the results of revie13, interim inspections and monitoring of reinforce =ent steel installatiens were not docu=ented with regard to the type of observation or the findings, nor did they contain the action taken in connection with any deficiencies noted."

Crtments At the time of the IaC inspection, Bechtel personnel had been exceeding the require =ents of their program by marking up copies of drawings with rebar equire=ents during their in-process inspections. These marked up drawings then were documentation of " interim inspections and monitoring of reinforce-ment steel installations." In response to this " infraction" 3echtel Quality Control has =cdified its program to require this activity to be perfor=:d.

The point is that the activity was being perfor=ed, however, on an "infor=al" basis. The effect of the " infraction" has been to formalize this activity.

'b. This infraction relates to the lack of docu entation for interim inspections.

The Bechtel Quality Control program has also required a final inspection and the documentatica of this inspectiori and this has been perfor=ed.

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