ML19340E045

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Responds to NRC Re Violations Noted in IE Insp Repts 50-329/80-31 & 50-330/80-32.Corrective Actions: Training Sessions for Key Personnel to Be Conducted Re Proper Handling of Part 21 Repts
ML19340E045
Person / Time
Site: Midland
Issue date: 12/17/1980
From: Jackie Cook
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19340E043 List:
References
10086, NUDOCS 8101060272
Download: ML19340E045 (1)


Text

' O Consumers Power James W Cook Voce PresnJent - hojects. I npnre.,ng and Constructson General Offices 1945 W est Patna i Rosi.1 Jackson, MI 49201 * ($17) 7d8 0453 Dece ber 17, 1950

'r J G i.eppler, Eegicnal Pirecter Office of Inspection and Enforcement US I;uclear Regulatory Oct.issien Regicn III 799 Ecosevelt Ecal Glen Ellyn, IL 60137

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II;SFEC~O:. EEF0ET :;0 50-329/60 _31 A::D 50-330/80-32

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Reference:

(1) G Ficrelli letter to J W Cook, dated !;ovember 19, 1950 This letter, along with its attachment, p ovides Censu ers Power's response tc the iter of ncncctpliance concerning the handling of a Fart 21 report that was received on the ?.'idland Site, i s s u s k l. Y L

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Attach.ent:

"Consr.ers Power Cctpany Response to the Infraction Described in the Inspection Report No 50-329/80-31 and 50-330/80-32" i

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E Cock, US:;EC Resident Inspector I

Midland Nuclear Flant (1)

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Attachment Serial 10086 4

CONSUMERS POWER COMPANY RESPONSE TO THE INFRACTION DESCRIBED IN NRC INSPECTION REPORT NO 50-329/80-31 AND 50-330/80-32 INFRACTION - DELAY BY CONTRACTOR IN NOTIFYING CONSUMERS POWER COMPANT OF THE RECE7"T OF 10 CFR PART 21 INFORMATION l

DESCRIPTION OF INFRACTION appendix A of Report No 50-329/80-31 and 50-330/80-32 provides the following:

Appendix A 3

NOTICE OF VIOLATION Consumers Power Company Docket No 50-329 Docket No 50-330 Based on the results of an NRC inspection conducted on October 1-31, 1980, it appears that certain of your activities were not conducted in full compliance with NRC requirements as ncted below. This item is an infraction.

10 CFR 50, Appendix B, Criterion II, states, in part, that, "The applicant shall establish at the earliest practicable time,

.a quality assurance program which complies with the requirements of this appendix. This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions."

Bechtel Nuclear Quality Assurance Manual Section V, Procedure 10 states, in part, 3

"4.2 Deviations Reported to the NRC by Suppliers Under 10 CFR 21

" Supplier notification t) Bechtel of 10 CFR 21 reports to the NRC shall be brought, without delay, to the attention of the Project Engineer by the individual in receipt of such notification."

"The Project Engineer shall evaluate the conditions of the Part 21 report for reportability under 10 CFR 50.55(e)."

l "The Project Engineer shall then notify the Manager of Division Engineering and the Project Manager. The Project Manager shall notify the Client Project Manager and request that the PQAE notify the MPQAM immediately."-

l Ccatrary to the above, the Resident Inspector determined that substantial delay (September 26 to October 24, 1980) was encountered in making 10 CFR I

l 50.55(e) reportability determinations based on site specific 10 CFR rp1280-0086a102 l

l L

2 Part 21 information pertaining to possible defects in the emergn cy diesel generator engine link rods.

Also, the information was not immediately disseminated to the client (Consumers Power Co) and other responsible parties.

RESPONSE

Transamerica Delaval Inc sent a letter, dated September 22, 1980, to Bechtel Power Corporation at the Midland Site, which transmitted as an attachment to a " standard commercial letter", a copy of the Part 21 notification sent the the NRC on September 19, 1980.

This was contrary to the purchase order instructions to direct such correspondence to the project manager in Ann Arbor, as well as to notify him immediately by either telegram, telex or telephone. The Bechtel site recipient read the letter, but not the attachment, and so did not recognize the fact that it constituted a Part 21 report. The correspondence was routed through routine channels for ultimate investigation by engineering personnel.

Subsequently, it was repsrted to Consumers Power Company.

As a result of this improper handling of a Part 21 report, Bechtel Power Corporation has initiated the following corrective actions:

1.

They will issue letters to all active suppliers reminding each of the correct correspondent to whom such reports should be addressed in future. This will be accomplished by the end of December 1980.

2.

They will conduct training sessions at the jobsite for key personnel, including the personnel involved in this incident, to alert them to the possibility of such reports coming their way by misdirection, and teaching them to recognize a letter which constitutes a Part 21 Report, even if it is not so identified.

This will be completed in December 1980.

w tely 90 dav intervals to 3.

They will issue memoranda at ap a

jobsite personnel, to reinforce -

training sessions.

The above corrective actions will achieve compliance with require,aents.

rp1280-0086a 10 /