ML20002D415
| ML20002D415 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/07/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20002D414 | List: |
| References | |
| EA-80-056, EA-80-56, NUDOCS 8101200590 | |
| Download: ML20002D415 (13) | |
Text
r Aopendix A NOTICE OF VIOLATION Consumers Power Company Docket Nos. 50-329; (Midland) 50-330 EA-80-56 Based on the results of an NRC investigation during the period March 6 -
July 31, 1980, it appears that certain of your activities were in non-compliance with NRC requirements, as noted Delow.
1.
10 CFR 50, Appendix B, Criterion IV (Procurement Document Control),
states, in part, that " Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material..."
Consumers Power Company Quality Assurance Program Policy No. 4 (Procurement Document Control), Revisi:n 8, states that" Assigned Quality Assurance personnel review prc:urement specifications to verify the adequacy of quality require ents stated therein."
The Bechtel Associates " Technical Specification for Heating, Venti-lating and Air Conditioning Seismic Class I..." (Specification Guide Number 7220-151A(Q), Revision 6, Section 2.0, Codes and Standards), requires that duct fabrica. ion and installation methods, materials, and workmanship shall corfc m to the ASTM standards.
American Society for Testing and Material (ASTM) material specifi-cation designation A527-71, paragrapn 3.2, states that orders for material to this specification shall include certain specified information, as necessary, that adecua ely describe the desired product.
The Zack Company Quality Assurance ManJal, Amendment 1 to Section 5, Revision 0, paragraph 3, states that "All Purchase Orders initiated by the Zack Company are subject to revies by the Zack Company Quality Assurance Department."
Contrary to the above, measures did nc. assure that adequate quality was suitably specified in material prc:urement documents, as evidenced by the following:
Zack Company Purchase Order No. C-743, dated October 12, 1979, for steel coils was not stamped to show completion of review by Zack Company Quality Assurance to insure that it contained all purchase requirements, and The Zack Company Purchase Orders No. C-743 and No. C-642, dated January 12, 1978, did not include the information required by ASTM A527-71 to adequately descrice the desired product.
Appendix A (Continued) This is an infraction (Civil Penalty - $3,500).
2.
10 CFR 50, Appendix B, Criterion V (Instructions, Procedures, and Drawings), states that " Activities affecting the quality shall be prescribed by documented instructions, procedures, or drawings... and shall be accomplished in accordance with these instructions, procedures, or drawings..."
A.
Consumers Power Company Quality Assurance Program Policy No. 5, (Instructions, Procedures and Drawings) Revision 8, states that
" Instructions for controlling and performing activities affecting quality of equipment or operations during the design, construction and operation phases of nuclear power plants, such as procurement, manufacturing, construction, installation, inspecting, testing, operations and maintenance are documented in instructions, proce-dures, specifications, checklists and other forms of documents..."
(1) The Zack Company Quality Assurance Manual, Section 6, Revision 0, states that "... Fabrication instructions are provided to the fabrication shop (plant or site) by design / drafting in the form of travelers that specifically set forth all necessary data..."
(2) The Zack Company Procedure No. MB-QCP-7, Revision 2, Paragraph 6.6, states that "in addition to the welder placing his identi-fication number on his work, this information shall be docu-mented daily (or as required) by the QC Inspector who shall record the welders identification number and the type of welding performed for each weld on a permanent set of drawings which shall be filed in the Zack Company field office."
Contrary to the above, activities affecting quality were not accomplished in accordance with documented instructions and proce-dures for fabrication, as evidenced by the following:
Review by the NRC inspector during the week of March 17, 1980 of the replacement duct for Duct No. V03-SH2-2-F9437 anc the accompanying documents indicated that the duct was partially completed without a traveler.
Review by the NRC inspector during the week of March 17, 1980 indicated that the installed hanger No. V19-SH1-7 does not resemble the sketch on the traveler (Traveler No. V19-7(1/C893)
F938).
The original hanger (configuration as shown on the tr veler) was fabricated in Zack's Chicago shop.
The new hanger (configuration as installed) was installed without a traveler.
Review by the NRC inspector during the week of March 25, 1980 indicated that the sketch on traveler No. V26-SH1B 11F10807 showed that the angle iron was welded to a 4" x 5.4" x 45*
Appendix A (Continued) channel.
The angle iron, as installed, was welded to a channel approximately 7" deep and 2-1/4" wide.
Review by the NRC inspector during the week of March 17, 1980 indicated that the height of hanger No. V1-3(7/C886)
F916, shown on the traveler, was 43-3/4" and the installed dimension was approximately 37"; furthermore, the angle brace was a 2" x 2" angle instead of a 3-1/2" x 3-1/2 x1/4" angle as required by the traveler.
Review of Zack Drawing No. V26-SH1 by the NRC inspector on March 25, 1980 indicated that the welder's identification number and the type of welding performed for each weld were not recorded.
This is an infraction (Civil Penalty - 54,000).
During the period March 17-28, 1980, it was established that the welders' identification was not recorded on the following travelers:
(a) V26-SH28-46.1-P1515 (f) V26-SH18-12-F10802 (b) V10-42B-F10171 (g) V34-SH1-3-F1306 (c) V10-42B.1-F10172 (h) V34-SH1-4-F1306 (d) V26-SH28-47.1-P1516
_(i) V34-SH1-1-F9395 (e) V26-SH1B-11-F10807 (j) V34-SH1-5-F9396 This is a deficiency (Civil Penalty - 50).
E.
Consumers Power Company, Quality Assurance Program Policy Number 5 (Instructions, Procedures and Drawings), Revision 8, states, in part, that Quality Control Procedures also provide additional.
detailed instructions for carrying out the quality functions.
The Bechtel Technical Specification for Heating, Ventilating and Air Conditioning (7220-M-151A-Q), Revision 6, Section 5.18, requires that marking material be Carboline Co. X-1000-90, Ameron Co. 2032 or Nissen metal marker by Nissen Co.
Contrary to the above, and as of the date of this investigation, an unapproved marking material, Eberhard Faber Marquette, was used to mark sheet steel stock and fabricated items installed in Seismic Class I ductwork without a change approved by the contractor.
This is a deficiency (Civil Penalty - $0).
3.
10 CFR 50, Appendix B, Criterion VII (Control of Purchased Material, Equipment, and Services), states that " Documentary evidence that material and equipment conform to the procurement requirements
Appendix A (Continued).
shall be available at the nuclear power plant... prior to instal-lation or use of such material and equipment."
Consumers Power Company Quality Assurance Program Policy No. 7, Revision 9, (Control of Purchased Material, Equipment, and Services),
states that " receipt inspections are made to verify that the items... conform to procurement requirements...
Documented evidence that the items meet... certification of conformance must be available at the plant site prior to installation or use of the items."
The Zack Company Quality Control Procedure MB-QCP-6 Rev. 3, Sec. 5.3, states that "the assigned QC Inspector, in performing a receipt inspection, verifies that material certification is received and traceable to each container of weld filler metal by heat / lot number or control number."
Section 5.4 states that " items rejected due to documentation problems are placed on HOLD until each problem is resolved."
Section 5.9 states that "each shelf within the weld rod issue room...
including the shelves inside the rod holding ovens, are marked as to the type, heat / lot, and/or control number of weld filler metal con-tained thereon."-
Contrary to the above, documentary evidence that material and equipment conform to procurement requirements prior to installation or use of material at the plant did not exist.
This was evidenced by the fact that on March 12, 1980, E-7018-1/8" weld rod, identified by the number 37G, was stored in the weld issue room warming oven, but material certification did not exist for rod identified by the 37G number.
A portion of the rod stored in the warming oven with unknown and/or questionable identification had been issued for use in the field.
l This is an infraction (Civil Penalty - S3,000).
4.
10 CFR 50, Appendix B, Criterion VIII (Identification and Control of Materials, Parts, and Components), states that " Measures shall be established for the identification and control of materials...
These measures shall assure that identification of an item is maintained by heat number, part number, serial number, or other appropriate means, either on the item or on records traceable to the item, as required throughout fabrication, erection, installation, and use of the item..."
Consumers Power Company Quality Assurance Program Policy No. 8 (Iden-tification and Control of Materials, Parts and Components) Revision 8, states that " Consumers Power and their onsite Suppliers exercise a system of controls to assure that only correct and accepted materials, parts, and components (items) are used and installed.
These items are identified by marking the items, or by records traceable to the items."
The Zack Company Q.; Manual, Section 9, Revision 0, states that "as the traveler progresses, all detail parts required are given a visual check to insure that each sub-component of the item has been properly identified
Appendix A (Continued).
with the traveler number placed on all sub-component parts, the traveler shall be identified with the control r. umbers to insure the traceability of the material, and to prevent interringling of incorrect material.
All identification (control number and/or traveler number) shall remain on the travelers and component parts throughcut the fabrication process to insure that the components are incorporated in the completed item."
The Zack Company Quality Assurance Manual, Section 9, Revision 0, states that " Quality Control inspector shall insure that the proper color coding has been placed on the material, and that the material has been properly identified with its control number..."
Contrary to the above, measures did not assure the identification of safety related HVAC components througnout fabrication, erection and installation as evidenced by the following:
Duct No. V26-SH2B-46.1-P1515, prior to March 21, 1980, (a) did not have either the traveler number or the control number identified on all of the sub-components; (b) was fabricated with angle irons marked with contro:s No. 929 and No. 727-2, but only angle iron control No. 929 was recorded on the traveler; and (c) the coil contro:
umber was recorded on the traveler as 383, but the control nu-ber was not on the item.
Duct No. V26-SH2B-47.1-1516, prior t: March 21, 1980, did not have either the traveler number c -he control number identi-fied on all of the sub-components.
Hangers No. V26-SH1B-11F10807 anc N:. V26-SH1B-12-F10802, as of
.1 arch 28, 1980, (a) did not have.hs angle iron control number recorded on the traveler; (b) dic nct have either the traveler number or the control number identi'ied on all the sub-components; and (c) had angle irc rarked V26-SH18-11-F10807 installed on hanger number V26-SE'_E-12-F10802 and vice versa.
Hanger No. V19-0(3/C898) F940, as o' March 28, 1980, did not have either the traveler number er the control number identi-fied on all of the sub-components.
Hanger No. V19-11(6/C898) F942, as cf March 28, 1980, (a) did not have either the traveler number or the control number identified on all of the sub-comp:nents; and (b) was fabricated with two pieces of angle iron mar <ec with control number 887, when the control numbers recorded or, the traveler did not include the number 887.
Hanger No. V19-13 (7/C898) F944, as of March 31, 1980, (a) did not have either the traveler number or the control number identified on all the sub-co poner.ts; and (b) was fabri-cated with one piece of angle iron narked with control number 887, when the control numbers recorced on the traveler did not include number 887.
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Appendix A (Continued) -
Hanger No. V19-SH1-7, as of March 31, 1980, (a) did not have either the traveler number or the control number identified on all of the sub-components; and (b) was fabricated with an an 'e iron marked with hanger number V1-3 (9/C886) F916.
During the week of March 17, 1980, an NRC inspector found numerous sections of angle iron stored in the Poseyville laydown area were without identification.
Hanger No. V1-3 (7/C886) F916, as of March 31, 1980, did not have either the traveler number or the control number identified on all sub-components.
During the period March 17-20, 1930, an NRC inspector found a large number of turning vanes in ten foot lengths, without either color coding or control number, stored in a rack in the field fabrication shop, and used in fabricating the following items:
(1) Duct No. V03-SH2-2-F9437 (replacement piece)
(2) Duct No. V10-42B-F10171 (3) Duct No. V10-428-1-F10172 (4) Duct No. V3-SH2-2D-F12685 This is an infraction (Civil Penalty - S4,000).
5.
10 CFR 50, Appendix B, Criterien IX (Control of Special Process), states,
" Measures shall be established to assure that special processes, including welding, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Consumers Power Company Quality Assurance Program Policy Number 9 (Control of Special Process), Revision 8, states that "For such special processes as welding, where the required level of quality cannot be measured by inspection only of the item, Consumers Power, its Suppliers, and their lower tier Suppliers, accomplish these processes under controlled condi-tions in accordance with applicable codes, standards, and specifications using qualified procedures, equipment and personnel."
A.
The Zack Company QA Manual, Section 10, Revision 0, states that "It shall be the responsibility of the Quality Control Inspector to insure that all welding shall be performed by only those welders who have been qualified for this work, and that each qualified welder uses the established welding procedures for the work."
Contrary to the above, prior to March 31, 1980, measures did not assure that welding was accomplished using qualified procedures, as evidenced by the fact that:
Appendix A (Continued).
A shielded metal arc welding process was shown on the travelers, but a gas metal arc welding process was used in the fabrication of the following items:
(a) Duct No. V26-SH28-46.1-P1515 (b) Duct No. V10-42B-F10171 (c) Duct No. V10-428.1-F10172 (d) Duct No. V26-SH2B-47.1-P1516 (e) Duct No. V3-SH2-2D-F12685 Travelers for ducts No. V34-SH1-F9395, No. V34-SH1-5-F9396, No. V34-SH1-4-F1306 nd No. V34-SH1-3-1306 stated the welding procedure to be user was Number QCP-1-P5CS.
This procedure requires the use of carbon dioxide as the shielded gas.
Dur-ing the week of Mar..h 25, 1980 individuals advised the inspector that carbon dioxide was not available at the Midland site, and therefore this procedure was not followed in performing these welds.
This is an infraction (Civil Penal.y - $3,500).
B.
The Zack Company Quality Control Procedure MB-QCP-6, Rev. 3, requires in Section 5.12 that " issuance and return of weld filler metal is controlled through the use of a Filler Metal Withdrawal Authorization form which is maintained with issued material from the time it is issued and until it is returned." Section 5.13 requires that " low-hydrogen electrode is issued in portable rod warmer caddies.
Each caddy is energized (i.e. plugged in) at all times, except when in transit to and from the location at which welding is performed." Section 5.14 requires that " holding ovens and portable rod warmer caddies are to be maintained at the temp-eratures specified in AWS D1.1-79, Section 4, paragraph 4.5...
their temperature is checked by a QC Inspector once every two (2) months and documented on the Rod Oven Temperature Check form..."
Contrary to the above, procedures to control weld filler metal at the Midland construction site were not followed as evidenced by the fact that:
On March 12, 1980, a rod warmer caddy in the welding booth area of The Zack Co. fabrication shop was not energized.
The caddy contained at least twelve E-7018 weld rods (low-hydrogen electrode). No Filler Metal With-drawal Authorization form was maintained with the material.
On March 13, 1980, a review of the temperature records for the portable rod warmer caddies disclosed temperature records did not exist for two caddies. The temperature records for two other caddies indicated the te.aperature for those two caddies was last checked prior to November, 1979.
Appendix A (Continued) This is an infraction (Civil Penalty - 53,500).
C.
Consumers Power Company Quality Assurance Program Policy No. 9, (Control of Special Processes), Revision 9, dated March 18, 1980, Section 3.1, Process Qualification and Control, states that "when performed by a supplier, the requirement to perform special processes in accordance with applicable specifications, codes, and standards, is made a provision of the Procurement Documents placed with Consumers Power Principal Suppliers. These Principal Suppliers are also required to establish provisions for the control of special processes in their lower-tier Procurement Documents."
Bechtel Corporation Specification No. 7220-M-1515A(Q), Revision 7, paragraph 14.9.3, states that "The Succontractor shall submit written welding procedures for review and acceptance by the Buyer prior to use. If the procedure is not prequalified by AWS D1.1, the procedure qualification test records shall be submitted along with procedure."
The Zack Company QA Manual, Section 10, Revision 0, states that
" Welding shall be performed by using Zack Company qualified and approved welding procedures." Tne Zack Company Welding Procedure Number MB-QCP-1 (P-SCS), Revision 2, requires that (1) base metal conform to the specifications for SA414, Grade A, and that (2) welding be of material in tne tnickness range of 1/16 (0.0625) inch to 3/16 (0.1875) inch.
The crocedure was actually qualified to weld in the thickness range of 0.0672. inch to 0.269 inch.
Contrary to the above, welding was not performed in accordance with qualified procedures as evicenced by the fact that:
Duct No. V2-SH1-1-2A-F8403, which was fabricated using Welding Procedure Number MB-QCP-1 (P-5CS), is ASTM A527 material with a thickness of 18 gauge (0.0475").
Welding Procedure Number MS-QCP-1 (P-5CS) was used to fabricate ducts No. V34-SH1-1-F9395, No. V34-5H1-5-F9396, No. V34-SH1-2-P1306, No. V34-SH1-3-P1-306, and No. V34-SH1-4-P1306.
The sheet metal of the ducts is ASTM A527 and the angle iron is ASTM A36.
Certain angle irons used to fabricate Duct No. V26-SH28-46.1 P1515 are identified with control number 727-2.
Material certification for angle iron control number 727-2 indicated material is ASTM A575.
Based on review of welding procedures,
-an NRC inspector determined that the Zack Company does not have a qualified welding procedure to weld on ASTM _A575 material in accordance with AWS D1.1, 1977 code.
Under a Certificate of Cor.formance, dated November 5,1979, the Air Monitor Corporation welded air m:nitors without prior buyer review and acceptance of welding procedures. The air monitors were subsequently received onsite.
l.
Appendix A (Continued).
This is an infraction (Civil Penalty - $4,000).
D.
Section 6.9 of the Zack Company Quality Control Procedure MB-QCP-3, Revision 2, requires that when safety related welding has been completed, the welder who performed the work shall mark each weld he has made with his welding symbol number.
Section 6.5 of the Zack Company Quality Control Procedure MB-QCP-7, Revision 2, requires that upon completion of a welding activity, each welder shall place his weld identification number on his work.
Contrary to the above, during the period from December 10, 1979 to March 20, 1980, all welding activity was not identified by a welder's identification number. This was evidenced by the fact that not every weld performed on duct hangers, designated V26SH1, Nos. 33, 34, 36, 37, 38, and 21a, was marked with a welder identification number.
This is an infraction (Civil Penalty - 53,000).
E.
Paragraph 4.1.7 of the Zack Company Quality Control Procedure MB-QCP-3, Revision 2, requires that when a welder has been tested and qualified to weld _on this project, he will be assigned a unique welder I.D. -stamp and this stamp will not be reassigned to any other individual.
Contrary to the above, during the period February 28 - March 20, 1980, two qualified welders were assigned the same weld stamp, No. CU7.
This is an infraction (Civil Penalty - 53,000).
6.
10 CFR 50, Appendix B, Criterion X (Inspection) states that "A program for inspection of activities affecting quality shall be established and executed by or for the crganization performing the activity to verify conformance with the documented instructions, pro-cedures, and drawings for accomplishing the activity..."
Consumers Power Company Quality Assurance Program Policy Number 10 (Inspection) Revision 8, states that " Inspection and surveillance are performed to assure that activities affecting quality comply with documented instructions, design documents and applicable codes and standards."
A.
The Zack Ccmpany QA Manual, Section 6, Revision 0, states that
.. Procedures have been established for... inspection..."
Contrary to the above, review of instructions and proc 2dures by an NRC inspector during the week of March 17, 1980 indicated that instructions and procedures for inspection were not prescribed for activities affecting quality as evidenced by the fact that no procedure existed for final inspection of field fabricated items at the Midland site.
l Appendix A (Continued) This is an infraction (Civil Penalty - $3,000).
B.
Bechtel Specification No. 72220-M-151A(Q), Revision 7, Paragraph 14.8.3.b states that " undercut shall not exceed 1/32 inch..."
The Zack Company Procedure No. QCP-20, Revision 2, requires that external surfaces of completed welds be examined for undercutting.
Contrary to the above, the program for inspection was not adequate to assure compliance with applicable specifications as evidenced by the fact that certain flange-to-duct welds on Duct No. V26SH2b-47.1-P1516 have undercuts exceeding 1/32".
This item was inspected and accepted by Zack QC on February 15, 1980.
This is a deficiency (Civil Penalty - $0).
7.
10 CFR 50, Appendix B, Criterion XV (Nonconforming Materials, Parts, or Components) states that " Measures shall be established to control materials, parts, or components which dc not conform to requirements in order to prevent their inadvertent use or installation..."
Censumers Power Company Quality Assurance Program Policy Number 15 (Nonconforming Items), Revision 8, states that, "... Nonconforming items (structures, systems, components, parts, materials) are identified by marking, tagging, segregating, or by documentation..."
A.
The Zack Company Quality Assurance Manual, Section 16, Revision 0, states that "...when it is determined that a nonconformity exists, it shall be tagged with a nonconforiance tag by the Quality Control Inspector who then shall initiate a nonconformance report.
Contrary to the above, measures which would prevent the inadvertent use or installation of nonconforming materials had not been estab-lished as evidenced by the fact tha.:
Duct No. V03-5112-2-F9437 was fabricated to Seismic Class 2 requirements instead of the prescribed Seismic Class 1 require-ments.
As of March 21, 1980 a nonconformance report was not initiated for the duct fabricated to the requirements of Seismic Class 2.
On March 12, 1980, nonconforming weld filler material (no material certification) was observed being used in welding a piece of duct identified on traveler No. F-9396..The material was not identified as being nonconforming.
This is an infraction (Civil Penalty - $3,500).
B.
Paragraph 6.3 of the Zack Company Quality Control Procedure MB-QCP-8, Revision 2, states
Appendix A (Continued) "In conjunction with initiating the NCR form, the QC inspector initiates a yellow nonconformance tag (s).
The hard copy is attached to the nonconforming item (s) and the soft copy is attached to the NCR form.
Each tag identifies the item by name, piece mark and item number.
The yellow nonconformance tag, by it's application, flags the item as nonconforming and prevents further work on or with the item."
Contrary to the above, during March and April, 1980, non-conformance tags had been applied to Ruskin NIBD23 fire dampers without explicitly identifying the item by name, piece mark, and item number. On April 18, 1980, and April 23, 1980, white nonconformance tags were observed being used on Ruskin NIBD23 fire dampers stored at the Zack fabrica-tion shop and on hangers installed in the Service Water Building respectively.
This is an infraction (Civil Penalty - $3,000).
8.
10 CFR 50, Appendix B, Criterion XVI (Corrective Action), states " Measures shall be established to assure that conditions adverse to quality, such as nonconformances are promptly identified and corrected."
Section 3.0 of Consumers Power Company Quality Assurance Program Policy Number 16, (Corrective Action), Revision 8, states that " Corrective action is initiated to correct conditions adverse to quality of items and activities." Section 3.4 states that " suppliers... who perform services for the nuclear plant, implement and follow a system for corrective action according to the Supplier's approved procedures."
A.
Contrary to the above, during the period May 23 - October 2, 1979, none of the seven non-conformance reports generated by the Consumers Power Company had been promptly corrected as evidenced by the fact that as of March 19, 1980 they had not been closed out.
This is an infraction (Civil Penalty - $4,000).
B.
The Zack Company Quality Assurance Manual, Section 16, Revision 0, dated February 28, 1979, states "The site or plant Quality Control Inspector shall be responsible for inspecting the material or equip-ment as it is received... Items placed on " HOLD" will be for deficiencies found in receipt inspection, e.g.:
1.
No material certification.
Contrary to the above, measures were not adequate to assure that conditions adverse to quality were promptly identified, as evidenced by the fact that:
Review of the Zack Company (at the Midland site) noncompliance listings disclosed that 250 pounds (5 boxes) of 3/32" diameter, Hobart E-6011 weld rod, serial number 90155A, that were received at the Midland site on May 17 and June 6, 1979, lacked a material Y
^
Apper. dix A (Continued) certification and were not placed on HOLD until March 11, 1980.
The remainder of this weld rod, 450 pounds in 9 boxes, was..ot placed on HOLD and its use is unknown.
250 pounds (5 boxes) of 3/32" diameter, low hydrogen 7018, welding rod, received at the Midland Job Site on December 15, 1979, were not marked as nonconforming for being " improperly boxed" until March 11, 1980.
This is an infraction (Civil Penalty - $3,500).
9.
10 CFR 50, Appendix B, Criterion XVII, states that, " Sufficient records shall be maintained to furnish evidence of activities affecting quality.
The records shall include at least the following:
Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and material analyses... Records shall be identifiable and retrievable."
Consumers Power Company Quality Assurance Program Policy Number 17, (Quality Assurance Records), Revision 9, Section 1, states that " Consumers Power and its Suppliers compile recorcs as specified in applicable procedures..."
The Zack Company Quality Control Proce:ere MB-QCP-21, Rev. 3, site procedure for inspecting installation of equipment, requires that the construction site quality control inspector is responsible for in process inspection and documentation of all items being installed and for final inspection of equipment installed.
It further states "that these functions will be documented on the following form:
Quality Control Survey Report Form No. 4."
Contrary to the above, sufficient reco-ds to furnish evidence of activities affecting quality were not maintained as evidenced by the fact that l
equipment installation inspection records did not exist for the safety l
related fire dampers installed during the period November, 1979 - January, 1980.
l This is an infraction (Civil Penalty - 53,000).
i 10.
10 CFR 50, Appendix A, Criteria XVIII, states that "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.
The audits shall be performed... by appropriately trained personnel not having direct responsibilities in the area being audited."
Consumers Power Company Quality Assurance Program Policy Number 18, i
l (Audits), Revision 9, Section 1, states that "..._ Audits to verify compliance to the requirements of the nuclear plant Quality Assurance l
Program are conducted by qualified personnel who have no responsibilities in the areas audited..."
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Appendix A (Continued) The Zack Company Quality Assurance Manual, Section 19, Rev. O, states that "All audit team members shall only audit areas for which they have no direct responsibility."
Contrary to the above, audits to verify aspects of the quality assurance programs were carried out by personnel with direct responsibilities in the area being audited.
Mr. Ed Thompson, Zack Company QA Manager and Mr. H. Geyer, Zack Company Project QA Manager, performed an audit on March 6-7, 1980 of the Zack Company Quality Assurance program at the Midland Site.
Mr. E. Thompson had been the Zack Company Project Manager at the Midland site in December 1979, a period included in the audit.
This is an infraction (Civil Penalty - 53,000).
Although the total civil penalties, pursuant to Section 234 of the Atomic Energy Act of 1954, amount to Fifty-four Thousand Five Hundred Dollars (554,500),
at the time of these items of noncompliance, the total civil penalties for any thirty (30) day period could not' exceed Twenty-five Thousand (525,000).
Consequently, cumulative civil penalties in the amount of Thirty-eight Thousand Dollars ($38,000) are proposed.
This Notice of Violation is sent to the Consumers Power Company pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. In determining the amount of civil penalty for each item of noncompliance, a penalty of $3,000 was proposed for infractions involving one example.
An additional 5500 was proposed for those infractions involving two examples.
For infractions involving three or more examples, the maximum civil penalty for infractions, 54,000. was proposed.
In one instance, the maximum civil penalty for an infraction was proposed because of the more serious nature of the item of nomcompliance.
The Consumers Power Cocpany is hereby required to submit to this office, within twenty-five (25) days of the date of this notice, a writter statement or explanation in reply, including for each item of noncompliance:
(1) admission or denial of l
the alleged item of noncompliance; (2) the reasons for the item of noncom-I pliance if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further i
noncompliance; and (5) the date_when full compliance will ne achieved.
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