ML20002D557
| ML20002D557 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/14/1976 |
| From: | Youngdahl R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20002D555 | List: |
| References | |
| NUDOCS 8101210343 | |
| Download: ML20002D557 (3) | |
Text
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- Aree Code S17 7881860 L
. June lh, 1976 Mr James G. Kappler US Nuclear Regulatory Commission 799 Roosevelt Road; Glen Ellyn, IL 60137 DOCKET 50-155, LICENSE DPR-t' - BIG BOCK POINT PLANT By letter dated May 19, 1976, you transmitted Inspection Report 050-155/76-09 and requested that we respond to two infractions identified therein and,'in - addition, requested that we respond to three items in the cover letter. On May 26, 1976, Mr R. B. Sevoll responded by letter to the item regarding third-party inspection. The purpo'.e of this letter is to respond to the recaining items identified. In fracti on "A. Contrary to Technical Specification h.1.2(b), the primary _ core g spray system did not meet operability requirements during power i' operations frem June 1975 to February 1976 due to unacceptability of weld No. S with code (B31.1.0) following a mod'irication of the core spray system in May 1975."
Response
The plant was not operated intentionally with a code unacceptable veld. g Further, even though the veld was not code acceptable, the system struc-tural integrity was adequate such that the veld would not rupture under l operating conditions. As stated in the event report dated April _5,1976, l plant Management did not recognize that-a code unacceptable veld existed until February 1976. At that time, corrective action was initiated. - In addition, ve believe that the systematic corrective action taken since i the occurrence in June 1975, as described briefly in our April 5,1976 event report and amplified later in this letter, vill preclude recurrence. In fraction Contrary to Appendix B to 10 CFR Part 50, Criteria IX, X and XVI, "B.. veld No. S. of the primary core spray system was not accomplished in accordance with applicable codes (B31.1.0). The progrcm fc-i inspection of the veld activity failed to verify conformance with I -- {-. the veld procedure, and measures to assure nonconfomance is I. 7/o/a/o W 3 , 1e. g
a 2 a promptly ~ dentified and corrected were not taken; although ac-cording to the licensee's records, the veld was rejected by Radiography on May 16, 1975, and subsequently found to be un-acceptable by technical review by a level III examiner in June 1975."
Response
The corrective action taken to preclude recurrence is described later in this letter. It should be noted that the statement in the infraction regarding the veld being rejected by radiography on May 16, 1975 is mis-leading. This statement is true; however, the veld was reworked and finally accepted (in error) by radiography on May 18, 1975 Concern Erpressed Related to Laxity of Quality Assurance Controlr 7he error in accepting the veld by radiography occurred on May 18, 1975 On May 29, 1975 the "S" veld was examined by an approved ultrasonic preservice tech-rique and found to be code acceptabic. In June 1975 the veld gas classified as code unacceptable by radiography; however, this reclassificatica was not docu-At the time of the occurrence, the current QA Program Procedures for mented. Indoctrination of CP Co Operations were in the process of being issued for use. supervisory and Management personnel, including NDT supervisory and Mar'.gement personnel, in basic quality assurance philosophy and requirements was completed This indoctrination session included indoctrination in the 18 in June 1975 criteria of Appendix B to 10 CFR 50, but did not address specific requirecrats t for implementing the QA Program for Operations. QA Program Procedures 15-51 and 16-51 covering deviation re. porting and correc-tive action were implemented by the QA Department in October 1975 The System Protection and Laboratory Services (SP&LS) Department Procedures were issued for use in February 1976. SP&LS Department Procedure SPLS-26 is entitled "Non-conformance and Corrective Action," and implements the requirements of QA Pro-gram Procedures 15-51 and 16-51 for the System Protection and Laboratory Services Department. Training of all NDT personnel, including supervisors and technicians, in SP&LS Procedure SPLS-26, "Nonconformance and Corrective Action," was completed on May h, 1976. Training of NDT supervisory personnel by the QA Department in QA Program Procedures 15-51 and 16-51 is ongoing at the present time and vill be 11, 1976. The NDT Section Supervisor attended the June 3-b, completed on June 1976 session. The emphasis of these sessions is each individual's responsibility for reporting and dispositioning conditions adverse to quality. Most of the SP&LS Department's activities at a nuclear plant are in the area of In the case of NDT, inspection of equipment against a set of acceptance criteria. For each veld inspected, the NDT the acceptance criteria is determined by code. technician prepares a report which documents whether or not the veld meets the If the acceptance criteria is not met, the NDT technician acceptance criteria. -also prepares a deviation report, has it reviewed by his supervisor (ie, telecon) ( and submits the deviation report to the plant for disposition and appropriate corrective action and submits a copy of the deviation report to the plant QA { representative.
'l 3 A maintenance work order package 'is assembled for each job. These packages are' audited by a' qualif,ied CP Co HDT. Level'III inspector _ following completion 'of the - -{? If a weld that had been previously accepted was' deemed rejectable by the job. Level III1 inspector, the Level'III. inspector would prepare a deviation' report 1 and submit it to the plant'for disposition and appropriate corrective. action. The deviation reporting' system has now been' fully. implemented by; NDP Section personnel. - This specific event has been reviewed with the Level III. Supervisor finvolved, the Manager of the SP&LS Department, the Manager of. Production Nuclear,~ the -Nuclear Licensing Administrator and the!Vice President of Production and Transmission 1 ~ (Company officer). We conclude.thatLthis reviav, along with the implementation q of :QA Program Procedures 15-51 and 16-51, 'SP&LS Department Procedure 'SPLS-26 and the training of SP&LS NDT personnel, provides adequate corrective action to-pre-vent recurrence. Y - Upgradin~g the Quality of Code Acceptable Welds-Your letter requested that Consumers Power describe the measures ve plan to take to upgrade the quality of weld, above the code acceptable level, performed by the. plant maintenance staff on safety-related piping. Several years ago, Consumers Power Company -intensified its efforts in velder training. As a. minimum,: it is - our intent to meet the.requirenents' of the. code.. In addition, we are continually. offering and upgrading training programs to enhance -the skills of welders and ' from time to time offer classes to appropriate supervision.in proper velding standards. ) j [r g / } /]Jw. f. R. C. Youngdahl Executive Vice President Y O f W r-4 7 s-t- -, -,-+,-,'- mrw+-w g g
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