ML19331A867
| ML19331A867 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/06/1976 |
| From: | Thompson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML19331A868 | List: |
| References | |
| NUDOCS 8007230901 | |
| Download: ML19331A867 (2) | |
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me Consumers Power Company Docket No. 50-329 ATTN: -Mr. Stephen Howell Docket No. 50-330 1
1 Vice President 1945 West Parnall Road
- THIS. DOCUMENT CONTAINS Jackson, Michigan 49201 P00R QUAUTY PAGES Gentlemen:
We have reviewed your letter of October 29, 1976 discussing mitigating circumstances regarding the items of noncompliance identified in our letter of August 13, 1976.
In view of~the several meetings and ex-change of correspondence between the Nuclear Regulatory Commission and the Consumers Pover Company regarding the noncompliance items identified in the " Notice,of Violation," we are con'cerned~that an apparent mis-caderstanding exits relative to the issues involved.,(In this regard, we wish tofreiterate our basic concern that the Consumers Power Company quality assurance / quality control program did not identify the cause or recurring nature of the improper placement of reenforcasent steel in safety-related concrete structures such that repetition could be pre-vented. Although we agree that your explanation of mitigating circumstances is not completely documented in our reports and corres-pondence,,dit is our position 'that your explanation of mitigatin;;
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circumstances does not change the noncompliance.
As Messrs. Hayes.and Jordan of our Region III office discussed with you by phone on November 17, 1976, we are not in complete agreement with several of the comments contained in your letter. However, l
based on your stated understanding of our concerns and the need for l
'the corrective action detailed in your letters of June 18 and June 24,'1976, further correspondence relative to these matters does not appear necessary or warranted.
Should you have any further questions, we' will be pleased to discuss them with you.
Sincerely, 40072SobU /
1 Thompson, Acting Director
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Fons AEC-318 (Rev. 9-53) ATcM 0240 W v. o. aos==> sat paawrimo omesi aere sae t es
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- IE Reading File 1
Coordinators: Region 1, II, III, IV, V
.RQ Coordinator:
K. Whit L. Crocker, RL State of Michigan IE Files (2)
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'J. F. Murray, ELD J. R. Metsger (3) i 4
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In a'ddition to the docu=ented instructicas fo inspection of this activit'/,
other i=portant para =eters for performing the verk were also docu=ented in that engineering personnel defined the required depth of devel installation, and site personnel did follev manufacturer's instructions for grouting.
These instructicas were on the ba6 of grout =aterial.
c.
The questien of whether or not docu=ented instructions are required for specific work activities is often not clear-cut. A great deal of judg=ent is required. It should be noted that the above citation frc= Criterion V of 10 CFR 50, Appendix 3, steps just short of the key verds "of a type appropriate to the circumstances." It is this phrase of "of a type appro-priate to the circu= stances" which calls for judg=ent. It should be pointed out tht Bechtel persennel at the Midland ccustruction site have had a proce-dure which provides guidance as to,d en 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 " infraction" Bechtel has re-reviewed its positica and continues to believe that docu=ented instructions are not necessary. In an " honest difference of opinien" Consumers Pcuer has concluded that docu=ented instructiens are desirable; and, therefore, Bechtel is in the process of preparing these instructio s.
d.
To our kncvledge, all dr4714ng and place =ent of rebar devels have been prep-erly perfor=ed even though docu=ented instructions were not available.
Infraction #2 "10 CFR Part 50, Appendix 3, Criterion V,' states in part, ' Activities affecting quality shall be prescribed by docu=ented instructions, procedures, or drawings...
and shall be accc=plished in accordance with docu=ented instructiccs, precedures, or drawings....'
"Bechtel Power Corporation Field Inspection Precedure G-3, which i=ple=ents the require =ents of Criterien V, states in Section 4.10.1 and 4.10.3 that, 'The PM.CE (Project Field Q,uality Control Engineer) sh t11 route a copy of the ec=pleted
' RCR to the organication responsible for centrol of the activity which apparently caused the nonconfer=ance. Each such organicatica vill e n.luate the feedback
- infor=ation provided by the NCR and initiate whatever ec-ective actic: =ay be warranted to prevent recurrence. ' and 'The PMCE shell aL:o route a copy of the co=pleted UCR to the site CAE for his evaluation and use in determining the need for corrective action to prevent recurrence.
Contrary to these requirements, nonconfor=ance reports concerning reinforce =ent steel deficiencies were not adequately evaluated to deter =ine the need for cer-rective action to prevent recurrence, either by the orga: ication responsible for control of the activity or by the quality assurance engineer."
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Upon leview of the cited section of Field Inspection Frocedure G-3, it was decifcd thei the routing of "a copy of ce=pleted UCR" was not an apprcpriate rachen$ss for initiation of ccrrective action to pre.ent recurrence. Therefere, w-at t-
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