ML20038B477

Responds to NRC 810916 Ltr Re Violations Noted in IE Insp Repts 50-329/81-12 & 50-330/81-12.Corrective Actions:Joint Training & Certification Program Instituted for QA Auditors in Early 1981

ML20038B477
Person / Time
Site:	Midland
Issue date:	10/30/1981
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20038B468	List: ML20038B477
References
14601, NUDOCS 8112080322
Download: ML20038B477 (5)

Text

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dE /W Power O Consumers CRIy8ny General Offices: 1945 West Parnell Road, Jackson, MI 49201 * (517) 788 0453 James W Cook vica era,isa., - eroicca , e.zinac i z and Construction October 30, 1981 Mr J G Keppler, R?gional Director Office of Inspection & Enforcement US Iluelear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND PROJECT -

INSFECTION REPORT NO 50-329/81-12 AND 50-330/81-12 FILE: 0.h.2 SERIAL: lh601

References:

1. NRC letter, J G Keppler to J W Cook, dated July 10, 1981

2. CPCo letter, Serial 13525, J W Cook to J G Keppler, dated August 7,1981 3 NRC letter, C E Norelius to J W Cook, dated September 16, 1981 This letter, including all attachments, provides Consumers Fover Company's response to Reference 3, which rejected portions of our response (Reference 2) to three items of noncompliance decerited in Appendix A of Reference 1.

This letter is a new complete response for items h , 5 and 8.

Consumers Power Compe.ny By -

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James W ' Cook Sworn and subscribed to before me on thi< 30th day of October,1981.

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&c. i /n . s a x[J u <a , a . . .b.

f Notary Public, Jackson County, Michigan My commission expires September 8, 1984

.WRE/lr CC: RJ Cook, USCC Rt.aident Inspector Midland Nuclear Plant (1) 8112080322 811203 g DR ADOCK 05000329 2 GBi l

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A CONSUMERS POWER COMPANY'S RESPONSE TO NOTICE OF VIOLATIONS DESCRIBED IN NRC INSPECTION REPORT DOCKET NO 50-329/81-12 AND 50-330/81-12 Item h from Appendix A (Item of Noncompliance 50-329/81-12 and 330/81-12-12 provides the following:

"10CFR50, Appendix B, Criterion V states, in part, ' Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings. . . and shall be accomplished in .with these instructions, pro-cedures, or drawings.'

The Consumers Power Company Quality Assur1nce Program Policy No. 5, Re-vision 9 states, in part, ' Instructions for controlling and performing activities affecting quality of equipment or operations. during the design, construction . . . phases of nuclear power plants, such as . . . construc-tion, installation . . . are documented in instructions . . . and other forns of documents, and the responsible CP departments shall 'also verify through audits that the required instructions . . . are implemented.'

Contrary to the above, seven large bore pipe restraints, supports, and anchors were not installed in accordance with design drawing and specifi-cation requirements. (329/81-12-11; 330/81-12-12)

This is a Severity Level V violation (Supplement II)."

CONSUMERS POWER COMPANY'S RESPONSE Violation Item h The pipe supports identified in the NRC report of the May 18-22, 1981 inspection which were used as supporting details for Item h in the Notice of Violation were all turned over to QC for inspection in 1980 (inspec-tions completed between 5/80 and 12/80).

An evaluation was conducted by MPQAD of the quality indicators related to hangers for the time period of June 1980 to.May 1981. This study found that half of the indicators were issued between 9/17/80 and 11/19/80 which coin-cides with the QC inspection dates for the hangers identified by Mr Yin.

This study concluded that construction did not assure that hangers and related ite=s were complete and in accordance with the most recent drawing revision prior to turnover to QC.

As a result of actions taken primarily in the Quality Control area, the number of quality indicators dropped from a peak of 13h in August / September 1980 to an average of 19 25 per month frcm March .1081 thru June 1981, and that general level has been maintained. Overinspections conducted by MPQAD have confirmed that the Eechtel QC inspection of hangers has improved and is providing increased assurance that pipe hangers which have been QC inspected and accepted do meet drawing and specification requirements.

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2 Actions taken as a preventive measure include the following. In June 1981, field enginaers were issued a hanger checklist which was prepared for their use to assist in the checking of hangers prior to turnover to QC. This checklist includes a review to confirm use of the most recent drawing re-vision, and by checking all items noted on the checklist, the field engineer can help assure that the hangers are complete and in accordance with the drawing and specification requirements prior to turnover to QC for their inspection. In addition, the reading list for Meenanical Field Engineers has been expanded to enhance their skills.

Based on this evaluation and the resulting recc=mendations and action taken by Bechtel Field Engineering, and the information in oar response to Item 5 of the Notice of Violation, we are scheduling an overinspection by MPQAD of a sample of those pipe hangers and supports installed prior to January 1981 to assess the acceptability of the installations and adequacy of the original inspection performed by Bechtel QC. This overinspection program vill be completed by December 31, 1981. Subsequent evaluation of the overinspection results will be used to determine if there is any need for additional ccrrective action.

In addition to the above, in response to your concern about rework subsequent to QC inspection (Ite= f), this concern is similar to Item 6 in your Notice of Violation resulting from the May 18-22, 1981 inspection. We request that you review our respense to Item 6, as our response to the concern stated in your letter dated September 16, 1981. In that letter, you stated that you will examine this matter during a subsequent inspection, therefore apparently accepting the actions we have taken. Therefore, we feel that no additional action is necessary on this item. An audit is planned to be conducted in November 1981 to address the effectiveness of the rework centrols which includes the additional procedures generated since the May inspection.

All of the specific hanger deficiencies are being addressed. Item a through d and f have been resolved. Project Engineering has been requested to evaluate the ccnditions represented by ite=s e, g and h. Disposition and corrective action results from the disposition is anticipated to be completed by January 5, 1981. Pending the result of the overinspection to be accomplished by MPQAD of the hangers installed prior to January 1981, the plant will be in ec=pliance in regards to this =atter at that time.

Item 5 from Appendix A (Item of Nonec=pliance 329/61-12-12 and 330/81-12-13) provides the following:

"10CFR50, Appendix 3, 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 docu-mented instructions, procedures, and drawings for acecmplishing the activity. '

The Consumers Power Cc=pany Quality Assurance Program Policy No 10, Revision 8 states, in part , ' Inspections and surveillance are performed to assure that activities affecting quality comply with . . . design documents.'

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3 Centrary to the above, licensee construction quality control inspectors inspected and accepted six of seven large bore pipe restraints, supports, and anchors that, in fact, had not been installed in accordance with design drawings ard specifications as determined by the NRC inspector. (329/81-12-12; 330/81-12-1?).

This is a Severity Level V violatica (Supplement II)."

CONSUMERS POWER COMPANY'S RESPONSE Violation Item 5 The pipe supports identified by the NRC in the report of their site inspection of May 18-22, 1981, which were used as supporting details for Item 5 in the Notice of Violation vere all inspected in the time period of May 1980 to Dece=ber 1980.

An evaluation conducted by MPQAD of quality indicators related to hangers for the time period June 1980 to May 1981 found that half of the indicators vere issued between 9/17/80 and 11/19/80, which coincides with the QC inspection dates for the hangers identified by Mr Yin.

The evaluation also found that during that time period, the number of : rafts personnel significantly increased. Construction had not assured that hangers were complete and met the requirements of the most recent drawing revision prior to turnover to QC. The result was that QC received a large number of hangers to inspect and these hangers had a relatively large number of deficiencies.

In Octobel and November of 1980, planned personnel changes included a new Lead Mechanical QCE, and pipe support group supervisor. These changes brought additional experience to the QC organization. Additionally, increased effort was directed to the inspection of pipe supports.

Subsequent to these actions, the number of quality indicators dropped frem a peak of 13h in Augu t/Septe=ber 1980 to an average of 19.25 per =cnth from March 1981 through June 1981, and that general level has been maintained.

Overinspections conducted by MFQAD have confirmed that the Bechtel QC inspection of hangers has improved and is providing increased assurance that pipe hangers which have been QC inspected and accepted do meet drawing and specification requirement-A question regarding the intent of Specification M-326 with regards to the location for the measurement for clearance determination (is a clearance that varies from 1/16" to 3/8" acceptable if the drawing requires a 1/16" clearance) has been referred to Bechtel Project Engineering.

All of the specific hanger deficiencies are being addressed. Item a through d and f heve been resolved. Proj ect Engineering has been requested to evaluate the conditions represented by items e, g and h. Disposition and corrective action results from the disposition is anticipated to be completed by January 5, 1981. Pending the result of the overinspection to be accomplished by MFQAD of the hangers installed prior to January 1981, the plant will be in ccmpliance in regards to this matter at that time. It is felt that our present inspection program is in ecmpliance with applicable requirements in regards to hanger inspections, j

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h j 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 Pcver Cc=pany Quality Assurance Program Policy No 5, Revisihn 9 states in part, 'The various Consumers Power Departments and Suppliers who perf orm a safety-related activity prepare required instructions, procedures and other instructicnal-type documents prior to initiation of safety-related activities. Reviews of Consumers Power Cc=pany departmental proce-cures for adequacy are ccnducted during the design and cons'truction phase . . .

by the Quality Assurance Audit and Administration Section within Environmental Services, Quality Assurance and Testing. They also verify through audits that the required instructions and procedures are prepared and implemented. '

Contrary to the above, licensee and contractor 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 proble=s was not being performed. (329/81-12-16; 330/81-12-17).

This is a Severity Level V violation (Supplement II)."

CONSUMERS POWER COMPANY'S RESPONSE Violation Item 8 Additional review indicates the failure of the cited Bechtel and CPCo audits to identify the fact that CPOC's were not being provided prior to system fsbrication and installation rwulted from a weakness in the planning for those specific audits. Althousn the CPDC's are an essential element of the design system, this attribute was not selected as one to be audited; rather, all three of the cited audits concentrated on ec=pleted calculations.

The cited audits were conducted in late 1980. In early 1981, recognizing such potential weaknesses in audit p_snning and other aspects of auditing, Bechtel and CPCo instituted a joint training and certification program for QA auditors. This program places greater emphasis on preparation for audits, (ie, audit plan, audit scope and preparation of checklists to implement the audit plan and scope).

We currently have 39 persons listed as auditors or auditors-in-training of which 29 have completed the new joint QA Auditor training. A refresher course for previously certified auditcrs is planned for 1982.

The training outlined above should provide additional assurance that MPQAD audit checklists include all of the essential elements of tF proc edure being audited, therefore impraving the quality of the audits and providf rg more assurance that pctential problem areas vill be identified.

It is our opinien that the audit program is in compliance with applicable requirement s. ,

WRE/lr

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