ML20062C269
| ML20062C269 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/23/1978 |
| From: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| HOWE-218-78, NUDOCS 7811070336 | |
| Download: ML20062C269 (3) | |
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Stephen H. Howell Senior Vwe 1+esident General offices: 1945 West Pernell Road, Jackson, Mimigen 49201 o (517) 788-0453
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Hove-218-78 Mr J G Keppler, Regional Director Office of Inspection and Enforcement US Huclear Regulatory Comission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 4
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MIDLAND NUCLEAR PLANT - NRC ITDIS OF NONCOMPLIANCE INSPECTION REPORP NO 50-329/78-09ANDNO50-330/78-09 This letter, with its enclosure, is in response to your letter of September 21, 1978 which transmitted the results of your inspection of the Midisnd construc-tion site on August 29-31, 1978 and which requested our written response to the item of noncompliance.
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Enclosure:
Consumers Power Company Response to the Item of Noncompliance Described in NRC Inspection Report No50-329/78-09andNo50-330/78-09
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4 OCT 2 71978 7811070336 h
a CONSUMERS POrrR COXPANY RESPONSE TO THE ITiM OF N0;!COMPLIAT;CE DESCRIBEL IN NEC INSPECTION REPORT NO. 50-329/76-09 AND NO. 50-330/70-09 NONCONERMANCE TO WELDING PROCEDURE (50-330/78-09-02)
Description of Noncompliance Appendix A of Report No. 50-329/78-09and50-330/78-09 provides the following:
l "10 CFR 50, Appendix B, Criterion V, states, in part,- that ' Activities affecting quality shall be prescribed by documented instructions, procedures,.... and shall be accomplished in accordance with l
these instructions, procedures.
Consumers Power Company Quality Assurance Program Policy No. 5, Rev. 5, Paragraph 2.0.k j
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referenced ANSI N45 2, Criterion 6.
Criterion 6, states, in part, that, ' Activities affecting quality shall be prescribed by documented 4
instructions, procedures,
. and shall be acccmplished in accor-dance with these instructions, procedures.
J Bechtel Power Corporation Welding Procedure No. P8-AT-As, Rev 1,
requires that backing gas flow rate be 10-15 CFH for velding first
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and second passes.
Contrary to the above, on August 31, 1978, the inspector determined
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the backing gas flow rate usel by the velder when velding the root i
pass of veld No. 38 on dravirs No. M611, Sheet 5, was 45 CFH."
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Response
l It is our evaluation that the observed use of a 45 CFH backing gas flow l
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rate, or any other incidence where the specified flow rate may have been j
exceedec, would not have resulted in any nandetectable adverse quality condition. This matter will be formally documented and dispositioned by Bechtel NCR 1518 and Consumers Power Co NCR M-01-4-8-071.
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i The following corrective actions have been taken to eliminate the j
noncompliance:
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Recognizing that the previous specification of 10-15 CFH for backing ges flow rates was overly restrictive and did not allow i
the flexibility needed for good velding practice, the Bechtel velding procedure specifications (WPS) have been revised.to allow purge rates of 1-40 CFH. This was implemented by specification change notice (SCN) G27-8014. General purging specificction GPS-1 1
has been revised to place additional requirements on the minimum flow rates and to permit flow rates in excess of those specified in the WPS. This change was implemented by SCN G27-8015 i
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The Field Weld Engineers have been apprised of the infraction and the subsequent velding specification changes.
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Bechtel Project Quality Control Instruction (PQCI) No. 7220/W-1.00 has been revised (issued as Rev. 6) to require the Welding Quality Control Engineers to identify on the individual veld records the specific items checked on surveillance inspection for activities 2.1.c, " Edge Preparation, Fit-up, Purge and Preheating," and for 2.1.d, " Technique Requirements." This vill allow specific indication of those characteristics that are being surveillance inspected, including verification of purge flow.
To assure proper implementetion of the new PQCI requirements, a training session was given to all WQCE's on 10/6/78 and documented by Bechtel memorandum Qcm-5338.
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