ML20010G600
| ML20010G600 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/07/1981 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20010G597 | List: |
| References | |
| 13525, NUDOCS 8109220283 | |
| Download: ML20010G600 (12) | |
Text
- - -
D e
COOSum8iS Power James W Cook OhfOf Vice Pr asident - Projects, Engineering and Co estruction General offices: 1945 West Pernell Road, Jackson, MI 49201 = (517) 78&O453 August 7, 1981 Mr J G Keppler, Regional Director Office of Inspection & Enforcement US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137-MIDLAND PROJECT -
INSPECTION REPORT NO 50-329/81-12 AND 50-330/81-12 FILE: 0.4.2 SERIAL: 13525
Reference:
- 1. NRC Letter, J G Keppler to J W Cook, dated v aly 10, 1981 This letter, including all atto.hments, provides Consumers Pove- Company's response to Reference 1 which transmitted the subject Inspection Report and which requested our written statement regarding eigh items of noncompliance described in Appendix A of Reference 1.
h Consumers Fover Company
,- /Gs .- j
,s b -
l B . h / DC b b i y'L/Zamesl}
W Cook ,
Sworn and subscribed to before me on this 7th day of August,1981.
o%
NotaryPublic,JacksonCounty,jchigan My commission expires Septembu 8,1984 WRB/lr CC: BJCook, USNRC Resident Inspector Midland Nuclear Plant P
m 10 1981
- - - - a
Attachment to
. Serial 13525 Page 1 CONSUMERS POWER COMPANY'S RESPONSE TO NOTICE OF VIOLATION DESCRIBED IN NRC INSPECTION REPORT NO. 50-329/81-12 AND 50-330/81-12 Item 1 from Appendix A (Item of Noncompliance 50-329/81-12-04 and 330/81-12-04) provides the following:
"10CFR50, Appendix B, Criterion XVI, states in part that, ' Measures shall
- be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective materials and equipment, and nonconformances are promptly identified and corrected . . .
the identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.'
Consumers Power Company Program Policy No 16, Revision 9, Paragraph 1.0, states in part: ' Corrective action is that action taken to correct and preclude recurrence of significant conditions adverse to the quality of items.'
Consumers Power Company Quality Assurance Procedure M-2, dated March 2, 1981, requires the Midland Project Quality Assurance trend analysis be implemented. Specifically, for each performance area identify trends requiring corrective action, detcrmine the sources of these trends, and obtain appropriate corrective actica commitments. Corrective action commitments are the responsibility of the " Appropriate Individual.."
Contrary to the above, a review of Monthly Trend Analysis Reports and related documentation covering the period July 17, 1980 through March 31, 1981, revealed that appropriate site managers have not routinely established comprehensive corrective actions in responsa to the identification of adverse gar.lity trends. Moreover, evaluations of adverse trends have not routinely identified the root causes of nonconformances. For example, 22 instances of construction personnel bypassing QC hold points were .ncluded in monthly trend analysis, but an adequate analysis to identify the root cause of these occurrences was not perfo rmed. (329/81-12-04; 330/81-12-04).
This is a Severity Level IV violation (Supplement II)."
Response to Item 1 A. During the period July 17 to October 15, 1980, the QA engineers who were analyzing trends employed the Monthly Trend Report as the means for notifying the appropriate manager that corrective action was required.
This did not provide an effective follcw-up mechanism to assure that action was taken. Management reviews of the Trend Reports noted this deficiency and caused the use of Quality Action Requests (QAR) to serve as miO881-0001a-12
) .
Attachment to a
' Serial 13525 Page 2 4
formal notification and as a tracking mechanism for any actions identified in the Trend Report.
l The NRC inspection during May 18-22, 1981, as*provided by examples in the body of the Inspection Report, determined that both the analysis of trends for root cause and the investigations which led to the conclusion that'a trend was not indicative of a deterioration of quality, have not been adequately documented. The use of a QAR now provides the mechanism to assure that there is complete documentation of analysis as identifed and any corrective action considered necessary. Each Trend Report-is signed by.the Quality Assurance Site Superintendent who has the responsibility _to
- review trends for a stop work consideration and is responded to by letter by the Manager of the Midland Project Assurance Department. This response t provides concurrence with the actions required by the Trend Report or asks i that further action be taken. _The review and specific response documents a stop-work was not considered an appropriate action for the trends identified during the reporting periods covered in the inspection.
I All six of the examples cited in the body of the inspection report
/ pertained to trend charts C-2 or B-3. Data on these two charts have been consolidated for the period June 1980 through April 1981 and a QA Engineer -
has been assigned to evaluate the nature of the nonconformances involved in the two areas and to the extent possible will determine the root cause j of each trend. He will also make a determination whether any additional i corrective action is indicated at this time. Contrary to the inference in
' the body of the inspection report, it is felt that the level. cf the.
4 inspection function is an important element in the analysis of trends as for any given absolute level of quality the number of noncompliances will be directly proportional to the inspection level. It is also noted that 4 the "real underlying causes" of trends may not be determinable or in fact
- assignable to a specific cause or causes which would warrant specific process corrective action. Whether a t rend is identified or not, individual nonconformances documented on an Audit Finding Report.or a donconformsace Report are reviewed for'the necessity to provide process corrective action. As an example, the 22 instances of-construction personnel bypassing QC hold points wbich led to the eventual stop work on a specific work activity had been Lader review by the Quality Assurance
- Department. The initial assessment was that the nonconformance reports being written by Bechtel Quality Control were appropriately being written i to document an indeterminate condition. This resulted from not knowing when expansion anchors were specifically installed in relationship to the
- design change which required the hold point.
The inspection report references documentation which " identified further weaknesses" in the trend' analysis program. In fact the Site QA' -
! Superintendent had 'een a leader in causing a review of the effectiveness and efficiency of the present trend analysis program which had evolved to its present form partially in response to NRC suggestions made after the
- project midterm QA review. An alternative trend analysis program is
. presently being utilized concurrently with the foregoing program which is
' miO681-0001a-12 I'
i
~, .... .,+,.n,..- .n....nn..,_,- ,_,,_,,,,w,...,n._._w
l l
Attachment to i
. Serial 13525 Page 3 required by our procedural commitments. It is expected'that this al*< rnative trend analysis program will prove to be an improvement over ou < resent program. This program provides for different criteria on the trend categories and provides for more specific instructions on what to look for, on what to record and on what actions to take when analyzing trend charts. When it is determined that a sufficient data base exists to judge the effectiveness and efficiency of the new program and to assure continuity of the trending analysis, a determination will be made as to formally switching to the new program. We would welcome the opportunity to review this program with the Region III staff prior to its implementation. Compliance with reguletory requirements and CP Co program requirements will be obtained upon comptetion of the actions associated with the two review teams reviewing the C-2 and B-3 trend data.
Item 2 from Appendix A (Item of Noncompliance 330/81-12-07) provides the following:
"10CFR50, Appendix B, Criterion X, states in part: 'A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures and drawings fer accomplishing the activity.'
Consumers Power Company Quality Assurance Program Policy No 10, Revision 8, Paragraph 1.0, states in part: ' Inspection and surveillance are performed to assure that activities affecting quality comply with documented instructions, design documents and applicable codes and standards.'
Contrary to the above, the electrical contractor's Quality Control (QC) inspections of cable termination activities on May 12, 1981, failed to verify conformance to Paragraph 3.11 of Project Quality Control Instruction E-5.0 which states in part: ' Verify that the . . . minimum installed cable bend radius is not violated.' As a result, a violation of the minimum bend criteria for Cable No 2AB2322B, that was observed by the NRC inspector has not been identified by the QC inspections.
(330/81-12-07)
This is a Severity Level VI violation (Supplement II)."
Response to Item 2 >
The condition which is the subject of this item of noncompliance was discovered by a Consumers Power Company employee who was accompanying the NRC Inspector. Consumers Power Company NCR M-01 9-1-061 was written to document the violation of the minimum bend radius criteria on Feeder Cable No 2AB2322B terminated in MCC 2B23. Construction completed the rework of this feeder cable to meet FPE-7.000, Revision 8 requirements (cable terminations) The Project Quality Control Instruction, E-5.0 Inroection Record Number 2AB2322B-1, which covers this particular cable installation, was held open because the miO881-0001a-12
Attachment'to
, Serial 13525-4 Page 4 meggering inspection step had not been performed. The inspection record presently reflects unacceptable status for Step 3.11 (minimum level radius).
Reinspection of subject cable will be performed in accordance with acceptance criteria of FPE-7.000, Revision 8 at which time it is anticipated that NCR M-01-9-1-061 can be closed out and the cable will be demonstrated to be in full compliance with its requirements. FPE-7.000, " Cable Terminations," Revision 8, was revised and was implemented on May 21, 1981, to include the requirement that " bend radius for training cable / conductor shall be per vendor's requirements." Further corrective action to prevent recurrence was to retrain-personnel. Bechtel inter-office memorandum 0-3889 was issued on May 18, 1981, to instruct personnel on the minimum bend radius requirements. The Quality Control Engineer who had erroneously accepted the nonconforming condition was given an eight-hour training program on all phases of termination by a Level II Quality Control Engineer. The above corrective actions will establish measures to assure that the minimum bend radius criteria will not be exceeded.
Item 3 from Appendix A (Item of noncompliance 50-329/81-12-09 and 330/81 4 10) provides the following:
"10CFR50, Appendix B, Criterion XVI, states in part: ' Measures shall be established to assure that conditions adverse to quality . . . are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude r3 petition.'
Consumers Power Company Quality Assurance Program Policy No 16, Revision '
9, Paragraph 1.0, states in part: ' Corrective action is that action taken to correct and preclude recurrence of significant conditions adverse to the quality of items or operations. '
Contrary to the above, as of May 22, 1981, corrective action had not been taken in response to Bechtel Quality Assurance Finding SA-97 dated April 3, 1980, and Consumers Power Company Audit Finding Report M-01-0?-106-i dated January 27, 1981, which identified the lack of approved procedures for the rework of items which had been accepted by Quality Control.
(329/81-12-09; 330/81-12-10)
This is a Severity Level V violation (Supplement II)."
Response to Item 3 Bechtr' Construction has developed Administrative Guidelines addressing rework. The Administrative Guidelines provide reference to particular field procedures and outline the me.*ns of administrative 1y processing rework information such that proper notifications and coordination are attained.
Bechtel Quality Control has also developed Adminiatrative Instructions to indicate the process followed for processing rework items.
miO881-0001a-12
I Artschment to
, Serial 13525 Page 5 i
Additionally, the field proced' ires were revised to more clearly address rework
- in some areas. Specifically, within the electrical area, Field Procedures
, FPE-3.000, " Installation of Electrical Tray and Conduit;" FIE-3.100, " Class IE Tray Support Installation;" and FIE-3.300, " Class IE Conduit Support," have
- been revised to address the rework of electrical raceway. These documents are in the approval cycle and are expected to be issued by August 12, 1981. In addition to these procedure revisions, an Administrativc Guide E-1.00,
" Processing Rework of Scheduled Raceway," was issued for use by Bechtel Construction.
. Bechtel Quality Control has developed and issued QC Administrative Instruct. ion No 617, " Instructions for Processing Rework Electrical l tems." This i- inr.truction details how rework is processed by Quality contral.
4 The lack of prompt ccrrec action described in the Item of Noncompliance relative to the Bechtel at Consumers Power Company audit findings was due to considerable discussion between parties on the need, extent and detail necessary to adequately cover the rework activity procedurally. There was a lack of any ider.tified nonconformances relative to items being reworked and as
- such, there were not and are not now, indications that the rework processes were out of control.
It is noted that the above-referenced administrative guideline = and instructions have been developed for Civil, Instrumenta ton, Mechanical and Electrical disciplines, and these actions in the.Hechanical area are
!- considered responsive to Unresolved Item 329/81-12-15 and 330/81-12 !
concerning procedural provisions to control design revisions on small bore piping and piping suspension systems. In the Mechanical area, the guidelines have been issued and revisions to the. appropriate Mechanical procedures have been made and are expected to be issued for use by August 12, 1981.
l Full compliance will be achieved upon issuance or the procedures.
Item 4 from Appendix A (Ites of Noncompliance 50-329/81-12-11 and 330/81-12-12) provides the following:
"10CFR50, Appendix B, Criterion V stat es, in part, ' Activities affecting
- - quality shall be prescribed by documented instructions, procedures, or i drawings . . . and shall be accomplirued in with these instructions, procedures, or drawings.'
The Consumers Power Company Quality Assurance Program Policy No. 5, l Revision 9 states, in part, ' Instructions 3r controlling and performing
( acti?ities affecting quality of equipment ,perations during-the design,
- construction . . . phases of nuclear power nts, such as . . .
- anstruction, installation . . . are docume. ,ed in instructions . . . and other forms of documents,' and the .
- esponsible CP departments shall 'also
. verify through audits that the required instructions . . . are
! implemented.' Contrary to the above, seven large bore pipe restraints, miO881-0001a-12
{
- ___-._-._...-m _ . _ . , _ , . ~ _ , _ _ . _ . , _ . . - . , _ _ _ _ , . . _ . _ . _ , _ . , . . _ . _ - . . ,
Attachment to Serial.13525 Page 6 supports, and anchors were not' installed in accordance with design drawing.
and specification requirements. (329/81-12-11; 330/81-12-12)
This is a Severity Level V violation (Supplement II)."
Item 5 from Appendix A'(Item of honcompliance ~329/81-12-12 and 330/81-12-13) provides the following:
"10CFR50, Appendix B, Criterion X states, in part: 'A program for
, inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify 1 conformance with the docueented instructions, procedures, and drawings for.
accomplishing the activi.y.'
The Consumers Power Company' Quality Assurance Program Policy No. 10, Revision 8 states, in part: ' Inspections and surveillance are performed to assure that cu'-4, ties affecting quality comply with . . . design docu-ments.'
l Contrary to the above, licensee construction quality ontrol inspectors inspected and accepted six of seven large bore pipe .traints, supports, and anchors. that, in fact, had nct been installed in a .cordance with design drawings and specificationa as determined by the NRC inspector.
(329/81-12-12; 330/81-12-13) i i This is a Severity Level V violation (Freplement II)."
! Response to Item 4 and 5 t
These two items of noncompliance are appropriately addressed together. The item identification used in this response is . identical to the identification ,
of the seven specific examples of noncompliar.ce found'in Section V 2 of the body of the inspection report. Further anaiysis of the seven-items i substantiated approximately only half of the findings. Specifically the following was determined.
r 1. Items e and d were found upon reinspection to be in nonconformance with their requirements and erroneously accepted by Bechtel Quality Control.
l Nonconformance reports have been issued for these discrepancies.
4 Compliance will be achieved upon ilosure of the nonconformance reports.
- 2. Item e (rigid frame restraint 18-1HCB-2-H13) is not in fact nonconforming to its design requirements nor was there an inspection error.
QC reinspection of this restrain utilizing standard inspection methods (level and angle finder) indicated that this item is within tolerance.
L The NRC calculations had indicated a 2.2,1 out of parallel condition j
between the upper shim plate and stanchion plate versus 2* allowable.
i miO881-0001a-12
(
y -,~ ,~,,-.-,.,.-,.,,n a v v,- , , , -, v m ,---e n , w n ,, e ,.w-- ..-n e m ..e,,-, ,-,,.m.,.,,ne-- .7...,+~,-.en,, m,-e+-r.,-~.-- - - > ~
. _ _ _ . . _ . . = _. . .
^
i .
Attachment to
. Serial 13525 Page 4 i
i i- 3. Item f (sliding stanchion assembly 2HBC-124-H7) at the' time of the NRC j inspection was nonconforming. Further QC_ inspection revealed that the l paint Jine between the base plate and the wall was broken. Because of this, .t is believed that the hanger movement occurred after the QC inspection that accepted the installation. An SCN (No. 26) to M-326 dated June 16, 1981 has been issued rendering the previously inconsistent cor.dition acceptable. No ft-ther action on this item is required.
- 4. Item g (Rigid Frame Assembly 12-2HBC-124-H5R) is in compliance.
4 Consumers notes that the NRC Inspector referenced the wrong specification.
Specification 7220 C-305(Q) relates to drilled-in anchor bolts The applicable specification for this condition is Specification ).20-C-306(Q) for grouted-in anchor bolts. This Specification (C-306) references no requirements for proximity of abandoned holes (due'to the different .
anchoring mechanism none is required). Therefore, no inconsistency existed nor was there en inspection error. No further action is required.
- 5. Item h (Anchor 2 1/2" - ICCB-2-H7) in a cimilar manner to (g) above is in
- compliance. The applicable Spec. (M-306) contains no requArements for the proximity of abandoned bolts. (Note
- further QC inspection revealed that i the 1/4" diameter bolts were, in fact, abandoned). Therefore, no I
inconsistency existed nor was there an inspection error. No further action is required.
- 6. Item i (Swav Strut FSK-M 1MBC-137-3-H3(Q)) had not, as yet, been released for QC inspection, it is considered "under construction" and as such, no
, inconsistency is noted.- No further action is required at this time o+.her
- than assuring at the time of inspection the item is in conformance.
i Item 6 of Appendix A (Item of Noncompliance No. 50-329/81-12-13 and 330/81 - 14) provides the f<llowing:
"10CFR50, Appendix B,-Criterion III states, in part: 'The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews .~. . Design control measures shall be applied to items such as . . . stress analysis . .. '
The Consumers Power Company Quality Assurance Program Policy No. 3, Revision 9' states, in part, 'The design organization identifies the applicable regulatory requirements, design bases, codes and standards; defelop the design and specify the design interfaces; perfora design j ve rification and prepare design documents. '
l Contrary to the above, several of the small bore pipe and piping suspension system designs performed at the site had not been prepared, reviewed and approved in accordance with established design control
, procedures. (329/81-12-13; 330/81-12-14) i
- j. This is a Severity Level IV violation (Supplement II)."
miO881-0001a-12
Attachment to Serial 13525 Page 8 i
Section V 3 of the body of the report further provides:
'"In iiscussion with the Small Pipe and Hanger Group Supervisor,-the inspector was told that the stress calculations will be performed after the stress walkdown approximately ninety days prior to the system turnover for startup testing. The inspector stated that failure to document stress.
calculations prior to issuance of drawings for construction is in nonconformance with Bechtel EDP-4.37; Revision 2, Paragraphs 7.5 and 8.3, which stated that, Calculations shall be checked and approved, in accordance with these procedures, prior to issuing drawings for construction, .. . Exceptions to this requirement shall be approved by i the Projec' Engineer, and to ensure follow-up and finalization of incompl.sto vork, preliminary calculations tentatively committed to final design work are filed, after review, in a separate binder entitled, Committed Preliminary Design Calculations (CPDC). This is an item of noncompliance, contrary to 10CFR50, Appendix B, crc.erion III."
Response to Item 6 Immediately upon identification of the problem br the NRC and consistent with the immediate action letter (IAL) of-May 22, 1981; a hold was placed on the further issuance of isometrics to construction without a completed, approved Committed Preliminary Design Calculation in place.
A program was initiated to review and upgrade all small bore piping cal-culation packages to CPDC status. This program is now complete.
Audits of this activity were conducted by MPQAD on June 16-19, 1981 and June 30 - July 2, 1981. A final audit was initiated the week of August 3, 1981, consistent with Item 7 of the NRC Immediate Action Item Letter (Ref Docket 50-329 and Docket 50-330.) These audits focused on both tha programmatic
- acceptability of the packages (consistency with EDP 4.37 requirements) and technical adequacy. Consumers Engineering provided a technical specialist for the audits). There were no findings resultant from completed audits.
It is noted that the docket number placed on the immediate action letter is in error in that "50-462" should be "50-330."
L -
l The specific isometrics identified by the NRC Inspector as not having acceptable piping stress calculations in the design package have been reviewed and these design packages have been upgraded to CPDC status as part of the i overall program identified. The completion of the actions specified in the
- IAL will achieve full compliance.
Item,7 of Appendix A (Item of Noncompliance 50-329/81-12-14 and 330/81-12-15)-
provides the following:
1 "10CFR50, Appendix B, Criterion VI states, in part, ' Measures shall be 4 established to control the issuance of documents . . . including the changes thereto, which prescribe all activities affecting quality. These miO881-0001a-12
7 j
Attachment to Serial 13525 Page 9 measures shall assure that documents, including changes, are reviewed . . . and approved . .. . by authorized personnel and are distributed to and used at the location where the prescribed activity is performed.'
The Consumers Power Company Quality Assurance Program Policy No. 6, Revision 8 states, in part, ' Measures are included to assure tbst doc-uments, including changes, are reviewed for adequacy and approved for release by the supervisory personnel of the organization preparing the i document, and are distributed according to controlled distribution to the user functions.'
i Contrary to the above, an outdated specification was maintained at the small bore piping design group work location and revised calculations were not marked " Superseded" in accordance with the procedural. requirements.
(329/81-12-14; 330/81-12-15)
This is a Severity Level V violation (Supplement II)."
Response to Item 7 p In accordance with the Immediate Action Letter (Ref. Docket No 50-329 and No 50-330, the following steps were taken in response to the NRC finding.
i 1. MED 4.37-0 was revised (Revision 16, dated 5/21) to include requirements
{ that the specific revision number of the specification or procedure, of f- which the calculation was based on, is identified in the calculation package. Subsequent audits by MPQAD have confirmed that this requirment has been acceptably implemented.
- 2. A document control. review was conducted by Bechtel Quality Engineering to ensure that all the applicable up-to-date specifications and procedures are in place :On the work locations. Cases where superseded and/or uncontrolled references were found were docamented. The subsequent audit
- conducted May 23-29,'1981, by MPQAD found no additional superseded or uncontrclled references. This area is considered to be in compliance.
- 3. Training in QA Procedures in general, MED-4.37.1 and Specification M-343, was conducted on May'22, 1981. MPQAD assisted in and witnessed this training.
The instance identified by the NRC Inspector of a superseded calculation not identified as such (calculation 412-2-11) was examined. It was -
determined that since the Calculation Package Upgrading Program had not
'tacovered 'any additional cases, that this item is an isolated case and hac been corrected. However, MPQAD has included an, additional check of the Superseded Calculation File as part of the final program audit scheduled of the CPDC' review program.
4 miO881-0001a-12
i
-Attechnent to
[,< Serial 13525 Page 10 Item 8 from Appendix A (Item of Noncompliance 50-329/81-12-16 and 50-330/81-12-17) provides the following:
, "10CFR50, Appendix B, Criterion XVIII states, in part, 'A comprehensive system of planned and periodic audits shall be carried out to verify-.
compliance with all. aspects of the quality assurance program.'
The Consumers Power Company Quality Assurance Program Policy No. 5, Revision 9 states, in part, 'The various Consumers Power Departments-and
~
Suppliers who perform a safety-related activity prepare required 4~ instructicns, procedures and other instructional-type documents prior to
} initiation of safety-related activities. Reviews of Consumers Power Company departmental procedures for adequacy are conducted during the design and construction phase, . . . by the Quality Assurance Audit and
, Administration Section within Enviromental Services, Quality Assurance and
- Testing. They also verify through audits that the required instructions
- and procedures are prepared and implemented.' -
i -
Contrary to the above, licensee and contrsctor audits of small bore piping design activities at the site did not include detailed review of system ~
stress analysis'and follow-up on previously' identified hanger' calculation problems was not being performed. (329/81-12-16; 330/81-12-17)
J This is a Severity Level V violation (Supplement II)."
Response to Item 8 i Contrary to NRC statement that audits "did not include detailed review of i system stress analysis", three of the audits specifically covered small bore l pipe and hanger. analysis. These audits were Bechtel Audits No 24-5-1 and
. AA-MA-2: conducted June through July and September 1980 respectively and CP Co Audit M-01-24-0 conducted in September 1980. The first Bechtel audit team f- included one Technical Specialist, and the second Bechtel audit team included
! three Technical Specialists. These specialists provided a specific technical review in. conjunction with the overall programmatic review provided by the
{= audits.
l-The Consumers Power Company Audit utilized the results of the NRC Inspection (Report Docket 50-373 and'50-374, dated' August-27, 1980) of LaSalle County Station conducted during August 1980. The NRC Inspection identified problems
.at 'LaSalle in the design of small bore pipe including lack ~of approved procedures, formal indoctrination and training of design personnel, use of inappropriate design criteria and inadequate audit by the LaSalle County' j- Licensee.
, Based on this NRC report, the CP Co audit checklists specifically included training and indoctrination of design personnel, presence of procedures ant detailed review'of selected calculations. The CP.CO audit did not result'in any findings in the areas of indoctrination, training or procedures. However, it did find six out of. nine findings in the area of preparation and checking miO881-0001a-12
~. _ .~. _
Attachment to
, Serial 13525 Page 11 of. design calculations. The conclusion drawn from the audit was that the
- overall design process system was satisfactory.but that the checking function required added attention. Accordingly, additional indoctrination to the checkers was accomplished as a process corrective action. Follow up on the audit findings was accomplished. .All the findfags were verified for completion of corrective action by.MPQAD before closure.
~
The above supports the fact that site audit (s) did include review of stress calculations. The statement (in Paragraph 4)-that there was no autit follow-up in the first two quarters of 1981 is not valid. The NRC inspection report.
itself noted that MPQAD Audit M-0-17-1 was performed in April 1981. In addition, Audit M-0-24-0 was conducted in September 1980, and the last finding was closed in January 1981 implying that' generic follow-up of the audit was also extended into 1981. It is noted that programmatic commitments do not require quarterly audits of any specific activity.
4 The audits by CP Co and Bechcel did not find the condition of an absence of CPDCs for the piping system designs in accordance with the design control procedu us. The auditora, to the extent this area was investigated,
. interpret'c the design control procedures the same as for Resident
! Engineering; that being the piping system CPDCs did not have to be in place until later in the design process. The CPDCs for hangers were audited and were found to be in order.
, Audits were committed to_ be accomplished in conjunction with the immediate action letter of May 22, 1981. These audits have confirmed the overall adequacy of the design process as has the results of the review program of the
- piping design packages. These additional audits have. included a technical
=
specialist from Consumers Power Engineering Department.
- It is felt that the above demonstrates that. compliance has been achieved with-regard to the subject of this item of noncompliance.
l l
i
\
l.
t l
miO881-0001a-12 l
l
._,...-_-_-_,__,,--_._-____._-a.,.-__-._.,.._,-,.,_,.._,-2,