ML20091F135
| ML20091F135 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/07/1983 |
| From: | Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-06, CON-BOX-6, FOIA-84-96 NUDOCS 8406020010 | |
| Download: ML20091F135 (1) | |
Text
{{#Wiki_filter:. 1 i NOV 7 1983-1 r 4 i ~ ,,e j l MEMORANDLSI FOR: U. Potapevs. Chief. Vender Program Branch RIV i i l THRU: J. F. Streeter. Chief Engissering Bronch 1. lHvision of Engineering. RIII 1 i FROM: D. R. Hunter. Chief. Management Oograms'Section. l Division of Engineering. RIII 1
SUBJECT:
2ACK CopFANY. CHICAGO. ILLIl10!$ [ i j Inspections by Region !!!.' Division of testenering. Management Programs personnel 1 at Zack Company, 4600 W.12th Street. Chtsage.111tnols, pertaining to the j { Midland plant. indicate potential generic meeknesses as specified below: i
- 1. Material received not in accordance with pmeuremer.t'decuments; 1
1 l 2. Acceptance of material deviating from specificatten requitwentst' l 3. Time required to close-out audit findings, encessives and l i 1 Lack of trending of audit findings as' required by Zack Trond Procedum. 4. { consumers Power Compary. Midland Plant, was issued a violation for Item No. 4 ~ in Region III Inspection Reports 50-323/83-08 and 50-330/83-08. A preset j inspection by Region IV regarding these four areas would be appreciated, l please advise us if we can provide any further assistance. l i D. R. Hunter. Chief i { Managesent Progresetsection ~ re,h i> , s, a glo840517 r,, R CE -96 POR I- ~ l JJ .e.Mll... Afd...... MH....{. r ..RJ.!.! /...!.l.l.l. f.!W8.5.....B.I. ..hkl@...... St.9.!n t Dan . kT.nne .it 4 11./. 4../. 8. 3...u...... 1.1../.u..[.83.... l.1.7....1.........11. f./. 8. 3... > <,.u.11./..>. i./.I. 3.uu. .u.1.uu,u.uu .u 1 page g n...u..uuu.a.g i ). TRiciAt. nrcoO c.opy g g a e . t r
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t e ,/ Do het No. 99900785/82-02 The Zack Company ATTN: Mrs. Christin Zack DeZutel ( l %.,' ' President l 4600 W. 12th Place Chicago, Illinois 60650 Gentlemen: This refers to the special inspection conducted by Mr. L. E. E11ershaw of this office on July 22, 23, 27 30, August 4-6, 30-31, and September 2-3, 7-10, l 1982, of your facility at Chicago, Illinois, associated with the fabrication of heating.., ventilation, and air conditioning (HVAC) systems and to. the, discussions of our findings with you'and members of your staff'at the l conclusion of the inspection. This inspection was conducted as a result of the receipt by the Nuclear Regulatory Commission (NRC) of.illegations pertaining to implementation and i enforcement of the Zack Company quality assurance program and was performed in j conjunction with an investigation by the Region !!! Field Office of the NRC Of fice of Investigation (01). Investigative findings pertaining to alleged improper QA records alterations, alleged harassment and intimidation, and alleged improper complicity by NRC licensed utilities, are contained in NRC O! Report No. 3 82 025 and 3 82 057 while inspection findings are contained in NRC Report No. 99900705/82 01. Areas examined and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the j inspector. l l In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of l this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you l believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary j that you (a) notify this office by telephone within 10 days from the date of this letter of your intention to file a request for withholding; and (b) submit within 25 days from the date of this letter a written application to this office to withhold such information. If your receipt of this letter has l been delayed such that less than seven days are avellable for your review, l please notify this office promptly so that a new dae date may be established. 1 RIV R4 i SCtR& CPS 80 VP9 3:V6fPd (0;Rt LE r /lk 18arnes UPotapoJs RL9en~gart TFlies terman 7/1 ) J/1r/81 - JMN83 ~ U11/83 p$/)g3 kt).h ! U lM [ I D'~, g 'J1g'): f' 4 y t
~. y -i i The Zack Company Consistent with Section 2.790(b)(1), any such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of i the reasons on the basis which it is claimed that the information should be withheld from public disclosure. This section further requires the statement I to address with specificity the con;Iderations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible i } into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods tieted above, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, Orici:21 CiM D Uldis Potapova Uldis Potapovs, Chief Vendor Program Branch
Enclosure:
Appendix A - Inspection Report No. 99900785/82-02 bec: JTCollins, RIV s RLBangart, RIV-JEGagliardo, RIV ~ EHJohnson, RIV MIS Section (J. Perry) VPB Brinch Chief 1' VPB Section Chiefs -VPB Inspector DMB-IE:09 ASME NBB&PVI t. e N' 6 \\' \\_ N ^ i j g s g p +- N \\ -\\\\ 3 j
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v -I ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS l REPORT INSPECTION 7/22,23,27-30, INSPECTION HO.: 99900785/82-02 DATE(S) 8/4-6, 30-31, 9/2-3, ON-SITE HOURS: 148 & 7-10/82 i l CORRESPONDENCE ADDRESS: The Zack Company j ATTN: Mrs. Christine Zack DeZutel President 4600 W. 12th Place Chicago, Illinois 60650 ORGANIZATIONAL CONTACT: Mrs. Christine Zack DeZutel TELEPHONE NUMBER: (312) 242-3434 I i PRINCIPAL PRODUCT: Heating, Ventilation, and Air Conditioning Systems (HVAC). NUCLEAR INDUSTRY ACTIVITY: Current activity consists of HVAC systems being furnished to the Commonwealth Edison Company's LaSalle County Station, Units 1 and 2; Illinois Power Company's Clinton Power Station, Unit 1; and Consumers l Power Company's Midland Plant, Units 1 and 2. ASSIGNED INSPECTOR: (.M b 27hR Ellershaw, Re tip'3 Component Program Ohte' S ction (R& CPS) OTHER INSPECTOR (S): D. D. Chamberlair., Reactor Systems Section H. Wescott, Project Inspector, RIII R. M. Burton, Investigator, Office of Investigations, RIII, Field Office R. D. Lanksbury M E e, Reactor Inspector, RIII tha /P3 APPROVED BY: I. Barnes, Chief, R& CPS Date INSPECTION BASES AND SCOPE: A. BASES: Appendix B to 10 CFR Part 50. B. SCOPE: This inspection was conducted as a result of the receipt by the Nuclear Regulatory Commission (NRC) of allegations pertaining to implement-ation and enforcement of The Zack Company quality assurance program, and was performed in conjunction with an investigation by the Chicago Field Office of the NRC Office of Investigation. Inspection findings are contained in (cont. on next page) PLANT SITE APPLICABILITY: 50-373; 50-374; 50-329; 50-330; 50-461 k M() '/) d i s- ?! J' ,,A* 5
v ORGANfZATION: THE ZACK COMPANY CHICAGO, ILLINOIS t REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 2 of 36 i .I SCOPE: (Cont.) NRC Report No. 99900785/82-01, while investigative findings are contained in NRC OI Report Nos. 3-82-025 and 3-82-057. The main e l purpose of this inspection was to assist the investigative staff in the evaluation of the identified allegations. 1 A. VIOLATIONS: None B. NONCONFORMANCES: 3 None C. UNRESOLVED ITEMS: None D. OTHER FINDINGS OR COMMENTS: 1. Review of Allegation Backaround This inspection was conducted at the request of the NRC Region III Office and in conjunction with an investigation into allegations received from former Zack Company employees, pertaining to falsified / altered quality assurance documentation; namely, material j certifications. The alleger first contacted NRC Region III, in person, on May 3,1982, and subsequently by telephone on May 10, 1982, and again, in person, on May 19, 1982. The allegations, briefly, dealt with possible forged signatures, use of white-out to effect changes in reported results,. and the adding of information to material certifications which had been received from material suppliers / manufacturers. The Zack Company had identified these conditions in letters to their customers on the following dates: (1) Bechtel Power Corporation-Midland Plant, Units 1 and 2, August 28, 1981; (2) Baldwin Associates-Clinton Power Station, Unit 1, September 25, 1981; and (3) Commonwealth Edison Company-LaSalle County Station, Units 1 and 2, September 25, 1981. The Zack Company was performing a review of all purchase order files, including certifications, and was taking action ta rectify all dis-covered discrepancies. One of the actions taken was to establish a formal documentation control system. In order to implement the system, additional personnel were required. l l ?; __ ~. ?:q Q. .e
9 ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS i { REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 3 of 36 On September 2,1981, the services of a Senior Quality Assurance Engineer from Project Assistance Corporation (consultants) were retained by Consumers Power Company for assignment at The Zack Company, for the purposes of establishing a formal document control system and performing an indepth review of the conditions described l by The Zack Company in the letters to their customers. Subsequently, i six document control personnel were employed by The Zack Company to I assist in the review and implement the document control system. One of the new employees was promoted to the position of Document Control Supervisor, effective November 16, 1981. In February / April, 1982, a number of quality control documentation personnel, including the supervisor, were terminated. j On July 26, 1982, the Government Accountability Project (GAP) forwarded to the NRC a letter which detailed alleged deficiencies relative to the implementation of 1he Zack Company QA Program. Attached to the correspondence were three affidavits, each accompanied by a memorandum which summarized the GAP interview of the three individuals, and three additional memoranda, each of which contained additional concerns relative to The Zack Company. The body of the letter contained 22 specific allegations which were compiled by GAP and represented their interpretation of the concerns which we're specified by the 3 affidavits and 6 memoranda. i NRC Region III conducted a detailed comparison between the 22 GAP alle-gations which were included in the July 26, 1982, correspondence and the attached affidavits / memoranda from which the 22 purportedly came. The comparative review also included all subsequent affidavits and memoranda which dealt with The Zack Company policies and practices. ( This detailed comparative review identified minor differences between GAP's summary of the allegations and those which we identified during our review of the affidavits and memoranda. Each of the discrepancies was individually assessed to determine its technical significance. The review concluded that the 22 GAP allegations encompassed the significant concerns raised in the affidavits and memoranda. This report addresses the 22 GAP alleg'ations as they pertain to I \\ activities of The Zack Company at their corporate offices in Cicero, Illinois. Those concerns contained in the 22 allegations which are site specific in nature can be found in the respective NRC Inspection Reports which address activities by The Zack Company at LaSalle s (50-373/82-51 and 50-374/82-18 issued December 22, 1982), Midland (inspection underway), and Clinton (inspection pending). l l -~ _y e p -.w y
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= ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS i REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 4 of 36 1 1 i j 2. Inspection of Allegations: )i For clarification purposes, the following information is provided. The i Zack Company has established three Quality Assurance Manuals (QAM); one i for each project; LaSalle, Midland, and Clinton. The LaSalle QAM (L-QAM) became effective on October 21, 1976, as Revision C. It is j currently Revision 6, dated March 24, 1982. The Midland QAM (M-QAM) i became effective on July 11, 1980, as Revision 0. It is currently Revision 1, dated May 11, 1981. The Clinton QAM (C-QAM) became i effective on July 11, 1980, as Revision 0. It is currently l Revision 1, dated September 30, 1980. In audition, Quality Control l Procedures (QCP) manuals are established by proj(:t. i a. Allegation No. 1: Absence of any formal Quality Assurance t Documentation Program - Until personnel were hired in the fall of 1981 to honor corrective action commitments there was no QA j formal program for documents. As a result, they were in an uncontrolled state, i.e., a mess. Documents were piled on the floor. Review: (i) The L-QAM, Revision C, contained the following sections: Section 3-Design Centrol; Section 4-Procurement Control; Section 5-Occument Control; and Section 18-Quality Assurance Records. During the various revisions, the format has changed somewhat so that the current Revision 6 contains the following: Section 4-Design Control; -Section 5-Procurement Documents; Section 6-Drawings and Procedures; Section 7-Document Control; and Section 18-Quality Assurance Records. All of these sections address the control of documents as they relate to the specific titles of each section. (ii) The M-QAM and the C-QAM since their dates of effectivity, have contained the following sections: Section 4-Design Control; Section 5-Procurement Document Control; Section 6-Instructions, Procedures, and Drawings; Section 7-Oocument' Control, and Section 18-Quality Assurance Records. The L-QAM is considerably more comprehensive than either the M-QAM or C-QAM; however, the M and C-QAMs refer to imple-menting QCPs. A review of the implementing QCPs and Quality Assurance Instructions (QAI), identified in the indices of the applicable project QCP manuals, revealed the following: i E .._ 4
v ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS t REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 5 of 36 I i (1) PQCP-7, " Plant Document Control," Revision 0, dated July 28, 1980, through Revision 8, dated September 1981 addresses the control of: QA Manuals; shop tickets (travelers); and vendor / customer drawings, specifications, and procedures j l utilized by The Zack Company. l (ii) QAI No. 4, became effective on October 26, 1981, as Revision 0, entitled, " Control, Content and Maintenance j j of QA Purchase Order / Certified Material Test Report Files." Revision 1, dated February 1, 1082, and Revision 2, dated j May 7,1982, are entitled, " Control, Storage and Maintenance of Quality Assurance Purchase Order / Certified Material Test i Report Files." Revision 0 was prepared by the consultant while Revision 1 was prepared by the Document Control Supervisor. l (iii) QAI No. 3, Revision 0, dated December 7, 1981, was entitled, " Record Management." Revision 1, dated May 7, 1982, is i i entitled "QA Record Management / Instruction." (iv) QAI No. 7, Revision C, dated May 10, 1982, is entitled, "QA Record Storage." A review of the above QCP and QAIs revealed that they meet the intent of 10 CFR Part 50, Appendix 8 requirements.
== Conclusion:== The Zack Company had written a formal. document control program with the issuance of L-QAM on October 21, 1976. It is apparent that supplementary implementing procedures / instructions were not available until July 28, 1980. The NRC Region IV Vendor Program. Branch had no inspection history regarding the Zack Company prior to this special inspection. However, nonconformances were identified with regard to their current document control program and are contained in NRC Inspection Report No. 99900785/82-01. l s I l 1 a h i ] Ib ~ . ~. t =+ .yp-3
ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 6 of 36 5 b. Allegation No. 2: Inadequate qualifications of personnel performina i significant roles - Individuals without any previous nuclear experience were assigned to make decisions requiring engineering judgment, as well as detailed knowledge of professional codes and legal requirements for QA documentation. They received these assignments despite protesting that they were not qualified to make such significant decisions. The qualification deficiencies extended to the Zack auditors. Review: The Zack Company has a detailed written program contained in the QAMs and supporting QCPs, related to indoctrination and training, and on going (monthly) training. A review of the allegers' indoctrination and training records was made to determine the extent of training received and if it was consistent with their job responsibilities. The file documentation control clerk was employed on October 5, 1981. The document control clerk who subsequently became supervisor on November 16, 1981, was employed on October 19, 1981. The first documented training for both individuals occurred on November 18, 1981, and was presented by the consultant. The description of the training is as follows: " Technical and clerical requirements relative to implementation of Zack Procedure QA-4. Indoctrination and Instruction relative to the applicability of ANSI 45.2.9 to the Zack Quality Assurance Program. Familiarization with basic alpha-numeric filing systems and practices. Familiarization with ASTM Standard Specifications." The clerk signed two reading lists on February 25, 1982, indi-cating that an extensive review had been performed during October 7, 1981 through February 24, 1982, regarding the QAM, QAIs and QCPs related to document control, 10 CFR Part 50, Appendix B, 10 CFR Part 21, ANSI standards related to procurement and QA audits, and the documentation requirements contained in i the technical specifications of The Zack Company's three customers. The supervisor received training on April 27, 1982, presented by the Lead QA Engineer, pertaining to the proper flow of quality i I assurance documents. t i I l ff _.. ~. _, a \\ g ~ w-e ~
v 1 i ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 7 of 36 l Both individuals received training on April 28 and 29, 1982, pre-sented by the QA Manager, regarding the proper methods for making corrections to QA documentation and records, and the use j of The Zack Company QA stamp ~on QA documents and records. The clerk signed a reading sheet on April 29, 1982, indicating that a review of five ANSI standards had been performed. j Further, the supervisor gave a training session to an individual identified as a Quality Assurance Engineer-Documentation, on February 17, 1982. This training consisted of instruction and review of the QAM and the two QAIs relating to document control. The supervisor also wrote a letter dated Deceniber 1,1981, which gave authority to the clerk to perform a QA record review and to j use the QA Review Stamp with signature / initials. l The training records of purchasing, engineering / drafting, and internal auditors were reviewed during this inspection. I Instances were identified where indoctrination, training, and qualification sessions had not been documented. Certain qualifications and certifications of auditors had not oeen kept current, prior to 1981. Since that time, individuals performing internal audits have been qualified through successful completion of the Auditor Training Program and the Audit Team Leader Training Program presented by Bechtel and Consumers Power Company. Numerous Quality Assurance training sessions have been provided to the engineering / drafting personnel.
== Conclusion:== The Zack Company did not meet their commitments regarding monthly training sessions until May 1982; however, the training provided, appeared to be commensurate with the background and educational experience of the individuals involved. A nonconformance was idantified and is contained in NRC Inspection Report No. 99900785/82-01. I s 9 1
ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 8 of 36 s j. i c. Allegation No. 3: Missina documentation and discrepancies in I welder qualifications records - To illustrate, an October 23 Interim Report found 25 discrepancies in a partial review of { welding qualifications records for the LaSalle site. i Review: j This item refers to the welders at the LaSalle site, the records of which are not maintained at The Zack Company fabricating facility. This area is addressed in special safety inspection reports 50-373/82-51, 50-374/82-18. The Zack. Company has committed to qualify their welders in accordance with the requirements of the American Welding Society code, AWS 01-1 and AWS D1-3. A review of the qualification records of the four shop welders was performed, and a comparison made against the AWS requirements.
== Conclusion:== During this review, one shop welder was identified as having been improperly certified as being qualified. This item has been identified as a nonconformance and is contained in NRC Inspection Report No. 99300785/82-01. d. Allegation No. 4: Inadequate training for QA personnel - Despite' repeated requests for comprehensive training, Zack only offered informal guidance and self-study materials. To illustrate the quality of the training, Zack Preside ~nt Christine DeZutel and her husband were trained "in accordance with The Zack Company Quality Assurance Training Program" on the basis of one hour's instruction from a Zack executive in NRC regulations and pro-fessional QA standards. The company finally proposed a formal training program shortly before it dismissed the entire QA documentation staff. Review: Criterion II of Appendix 8 to 10 CFR Part 50 requires that a QA Program provide for indoctrination and training of personnel performing activities affecting quality and to assure that suitable proficiency is achieved and maintained. The Zack Company's QA program, as stated in item D.2.b above, does provide for indoctrination and training. 4: Si l s ~ y
ORGANIZATION: THE ZACK COMP'ANY CHICAGO, ILLIN0IS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 9 of 36 Prior to April 30, 1982, the documentation control group reported to the QA Manager, thus QA personnel consisted of: QA Manager, two QA engineers, a QC inspector, and the document control group. The training records of two of the document control group are addressed in item 0.2.b. above. An individual was employed on i August 18, 1980, as QC inspector with a subsequent job promotion f to QA engineer on July 9,1981. A review of his training records shows that he attended 43 formal training sessions between October 28, 1980 and October 6, 1981. Further, there were copies ) of written examinations showing his successful completion of training as a Lesel I and II QC inspector. He also successfully completed the Auditor Training Program provided by Bechtel-l Consumers Power Company as evidenced by a Consumers Power i Company letter dated April 14, 1981. Reading lists dating from August 26, 1980 through April 17, 1981, show extensive coverage of all aspects of the QA program. Another individual was employed as e QC inspector on September 28, 1981, with subsequent promotion to QA engineer on January 19, 1982. His training records show reading lists dated October 20, 1981, and February 12,'1982, covering all aspects of the QA program. Further, he attended nine formal training sessions and successfully completed the Consumers Power Company's Audit Team Leader Training Program. The current QA Manager was employed as a Lead QA engineer on September 8, 1981. The records show that he was previously employed as a QA engineer performing' nuclear vendor audits and l that he was certified as a level II examiner in accordance with 'l SNT-TC-1A, for magnetic particle, liquid penetrant, visual inspection, and radiography.
== Conclusion:== The Zack Company's QA Program provides for indoctrination and training of personnel performing activities affecting quality. I With regard to the training given to the Zack President and Vice j President (her husband), the NRC found no requirements where these individuals have to be trained in QA. The formal training provided Zack employees, including the president and vice president, since July, 1980, as evidenced by the records, appears to be adequate and consistent with the job responsibilities, j l \\~ ~ 1 i M~
ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS l 3 REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 10 of 36 i l e. Allegatian No. 5: Missina records due to inadequate document control - Both unauthorized management personnel, and even the owner's dog, had access to Zack QA records and Purchase Orders. As a result, records were lost or chewed up. i Review: .i During a Zack Company quality assurance review of certifications, inconsistencies were identified. These were categorized into four groups: (i) Material certifications with incomplete information (11) Material certifications with technical inaccuracies (iii) Material certifications with possible unauthorized and improper modifications 1 (iv) Possible person / persons improperly modifying material certifi-cations This information was transmitted to their customers in letters dated August 28, 1981 (Bechtel Power Corporation-Midland Pawer Station), and September 25, 1981 (Baldwin Associates-Clinton Power Station, and Commonwealth Edison Company-LaSalle County Nuclear Station). Subsequently, letters dated October 23, 1981, with an attached document, entitled " Potential 10 CPR Part 50.55(e) Reportable Defect Evaluation for Material Certi-fication Deficiencies," were sent to.their customers. The document states in part, "There has been a breakdown of the quality assurance program as related to. Document Control and... Control of purchased material, equipment, and services This breakdown resulted in an incomplete review and acceptance of procurement documentary evidence (material certi-fications) and access to those documents by unauthorized personnel resulting in improper modifications being made The deficiencies were categorized. Two of the categories were listed as "No certification or C of C" and " Certifications missing." + I 5 5 is i 4 s - r 7 g
w\\ ~ ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 11 of 36 e Section 6 of this document, " Corrective Action," states in part, "... A document and records management program will be developed l. and implemented. A documentation task force consisting i of six persons has been assembled. The group experience rep-resents over 25 years in the documentation field and over 40 years in quality assurance or related areas. Three of the six persons have at least a Sachelor degree and two l have a Master degree. This group has just completed a review of all known or available purchase orders and documentation for the three projects. A centralized filing system has been established and detailed quality assurance instructions have been developed I for records and receipt inspection." i The allegers were part of the documentation task force.
== Conclusion:== This allegation was substantiated as it had already been identified in The Zack Company's notification to its customers. This notification occurred in August-September, 1981, prior to the allegers employment at the Zack Company. There were no additional instances of missing documentation identi-fied, relating to material certifications. However, a noncon-6 formance regarding missing QA documentation was identified and is contained in NRC Inspection Report No. 99900785/82-01. f. Allegation No. 6: Absence of required quality verification on documents that could be retrieved - This ranged from missing signatures to missing required test data, specifications, and certifications to professional codes. Review: The Zack Company identified this item in their notification letters and documents referenced in D.2.e. above. The deficiencies were categorized as follows: I E 1 t J lt Y " ~ W cd
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gP ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS i REPORT INSPECTION i NO.: 99900785/82-02 RESULTS: PAGE 12 of 36 TYPE DEFINITION Clerical errors: Those certifications that had acceptable chemical and physical test data but lacked reference to the prefix " ASTM" (i.e., A36 instead of ASTM-A-36), the revision or date of standard, the standard (i.e., ASTM, ASME or other standard) or the G-90 coating designation on sheet steel. Signature Missing: Those certifications that are acceptable in all aspects except, they had not been i signed by an authorized representative for the company. i Signature Error: Those certifications that are acceptable j in all aspects except, the signature typed and the signature signed do not agree (i.e., J. Jones, QA Manager typed-actually signed by Tom Smith). Wrong Standard Those purchase order packages that contain referenced: a material certification or certificate of compliance that references a standard not included in the technical speci.'i-cation. Ct.smical/ Mechanical Those purchase order certifications which test data: have chemical analysis and/cr mechanical test data missing or is not in accordance with ASTM Standards or technical speci-fication requirements.
== Conclusion:== This allegation was substantiated, as it had already been identi-fied in The Zack Company's notification to its customers. Addi-tional examples are identified in a nonconformance contained in NRC Insnection Report No. 99900785/82-01. l S ~ 3. l e ./_
v ORGARIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 13 of 36 i 1 k g. Allegation No. 7: Lack of proper identification through compliance l with material traceability requirements - This led to problems such as lack of required traceability for some 114,000 hexheads, bolts, nuts and similar items. Similarly, certain steel beams could not i be traced with certainty, although indications are that they come from Argentina. Review: 3 I j The NRC inspectors reviewed the Zack file packages for purchase orders (P0s) C-4286, C-4473, and C-4484. P0 C-4286 was placed with the Delta Screw Company (Delta) on February 4, 1981, for 20,000 bolts and-20,000 nuts. This material was designated for stock and could thus be used at any of the three sites. On February 13, 1981, Zack received the ordered material with a letter certifying that the bolts conformed to ASTM A307 and the nuts to ASTM A563. P0 C-4473 was placed with Delta on August 26, 1981, for 20,000 each, bolts, nuts and washers. This material was designated for use at Midland. Subsequently, on September 4, 1981, Zack received the ordered material with a letter certifying that the bolts conformed to ASTM A307, the nuts conformed to ASTM A563, and the washers conformed to ANS1 827.2 and were made of AISI 1010 steel. The chemical and physical properties were also provided for the bolts and nuts as was the hardness of the washers. P0 C-4484 was placed with Delta on September 14, 1981. Zack received the ordered material with a letter certifying that the bolts conformed to ASTM A307, the nuts conformed to ASTM A563, and the washers conformed to ANSI B27.2 and were made of AISI 1010 steel. The chemical and physical properties were also provided for the bolts and nuts as was the hardness of the washers. On September 22, 1981, Zack wrote conconformance reports (NCR) M-110, NCR Q-112, and Supplier Deviation Disposition Request (SDDR) 2187 (Zack No. 092291-1s). NCR M-110 was written against J PO C-4484 and stated that the bolts were not marked as required by ASTM A307, and NCR Q-112 was written against PO-4286 for the same rease.i. SDDR 2187 was not written against any specific P0 and requested acceptance of any ASTM A307 bolt not marked by the manufacturer as required. In addition, on September 28, 1981, Zack wrote hold report Q-184 against P0 C-4473, and two other P0s not related to this allegation, stating that the certifications for the material had not yet been reviewed. Y e a 5-3
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e w ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 14 of 36 i SDDR 2187 was dispositioned by Bechtel Power Corporation (Bechtel) on October 23, 1981, to accept any bolts not marked in accordance with ASTM A307 providing they conformed with all other requirements of Technical Specification 7220-M-151A (Bechtel's j specification for HVAC systems at Midland). On October 28, 1981, Pittsburgh Testing Laboratory (PTL) provided Zack with the results of chemical analyses and physical tests performed on various material samples, including samples from P0 C-4286 and P0 C-4484. The results of these tests were within the specification requirements. Subsequently, Zack wrote SDDR 2219 (Zack No. 102981-25) on October 29, 1981, to request disposition of nuts and wasners purchased to ASTM A307 that do not have a manufacturers identf**'e+4cr ::rk. They &lav noted that the nuts should be purchased to ASTM A563 and the washers to ASTM F436 and requested a specification change to reflect this. In addition, Zack stated that they were in the process of acquiring certificates of conformance from all suppliers of nuts and washers for Midland. On November 18, 1981, Zack wrote NCR M-175 stating that the nuts and washers from P0 C-4484 did net have a manufacturer's identification mark as required per ASTM A307. SDDR 2219 was dispositioned by Bechtel on November 20, 1981, stating that ASTM A307 recommends nuts per ASTM A563 and that ASTM A563 nuts are not required to be marked. Therefore, there is no deviation from specification requirements. It further stated that washers without manufacturers identification were acceptable provided they conformed with all other requirements of ASTM F436. Based on the answers to SDDRs 2187 and 2219, accepting the material "as is", and having received, reviewed and accepted the material certifications for P0 C-4473, hold report Q-184 was closed for this PO on December 16, 1981. On December 22, 1981, Zack wrote change 1 to P0s C-4286, C-4473, and C-4484 stating that per agreement with Delta, the bolts and nuts of P0 C-4484 were to be returned for full credit. Subsequently, on December 30, 1981, NCRs M-110 and M-175 were dispositioned to accept ASTM A307 bolts, ASTM A563 nuts, and F436 washers without any manufacturers identification marks as approved by Bechtel on SDDRs 2187 and 2219. On January 5, 1982, change 1 to P0 C-4484 was canceled. E i s 9
v ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 15 of 36 l l On January 13, 1982, Delta wrote a second material certification for the washers provided under P0 C-4473, apparently to correct an error on the September 4,1981, e certification. This certification stated that the washers conformed with ANSI B27.2 and were made from AISI 1010 steel, l as did the previous certification, but stated that the washers were zinc plated in accordance with ASTM B633 instead of ASTM A164 as previously stated. NCR Q-112 was dispositioned on February 17, 1982, to not use the material for nuclear work, but use for nonnuclear work only. Subsequently, on February 18, 1982, Zack wrote NCR L-237 to accept the material as-is. 500R 2577 (Zack No. 062382-1C), dated June 23, 1982, was written by Zack stating that the washers purchased on P0s C-4484 and C-4473 have a certificate of conformance indicating that they are made of AISI 1010 steel and meet the requirements of ANSI B27.2. 500R 2577 was dispositioned by i Bechtel on July 13, 1982, to accept the use of washers made of AISI 1010 steel and zinc plated to ASTM B633/ ASTM A164. They also stated that Technical Specification 7220-M-151A would be revised to add AISI 1010 steel for washers. The NRC inspector also reviewed Zack Company P0 C-904 dated August 22,1979, for 300' of 8"x15"x20' ASTM A36 steel. These P0s were placed with Edgecomb Metals who delivered the material to Reliable Galvanizing. Reliable Galvanizing then delivered the material to Zack, who subsequently delivered it to the Clinton site. Discussion with Zack personnel indicated that a thorough investigation had been made and it was determined that the Argentinian Steel was mixed at the galvanizing shop with another order. A review of available documentation revealed that Zack NCR ZC CB-519, dated June 25, 1981, was written upon discovering a section of Auxiliary Steel that was identified "Somisa Ind, Argentina." Further corrective action taken was to initiate Zack NCR ZC C8-519 Revision 1, dated February 19, 1982, to perform a thorough investigation into this matter. In addition, Baldwin Associates wrote NCR 6528 dated March 4, 1982, in order to track this item. t si ~ _ +,
ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS a REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 16 of 36 ? Investigation established that 27 hangers had been installed containing Argentinian steel members. Samples of the Argentinian steel were sent to PTL for chemical and physical analysis. The analysis performed by PTL was found to correspond to the original certified material test reports supplied by Edgecomb Metals. However, all hanger assemblies containing Argentinian steel were removed and replaced with i the exception of those that were inaccessible.
== Conclusion:== t This allegation was not substantiated. With regard to the portion of the allegation dealing with the three Delta Screw ~ '~ ~ ~ ~ ~ Company purchases, contrary to the allegation an NCR or SDDR l was written to disposition each purchase order discrepancy. It was noted that Zack appears to have been confused on what i the requirements for the material were and in some cases were slow to write an NCR/SDDR. However, the NCRs and SDDRs were written and the material problems were dispositioned. Zack's change 1 to each of the three P0s, to return some or all of the material for credit, appears to have been an error since Bechtel had already dispositioned the material as acceptable for use at Midland. ? I With regard to the portion of the allegation dealing with the Argentinian steel, it is noted that this issue only applies to the Clinton site and that both Zack and Baldwin Associates wrote NCRs to track this item. Material samples were taken for ana ysis and they met the appropriate requirements. In addition, all accessible hanger members identified as having 3 been made with the Argentinian steel were removed and replaced with hangers made from domestic steel. Further technical evaluation on this matter will be made in a special safety inspection report on Clinton HVAC systems. 1 i
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e, ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 17 of 36 Il e h. Allegation No. 8: Improper alteration of QA records through i stickers containing signatures of questionable authenticity - This item is addressed on 0I Investigation Report for Case No. 3-83-025. i Review: In the Spring of 1981, the 7.ack QA Manager was notified by a Consumers Power employee stationed at the Midland Nuclear Project that some questionable Certified Material Test Reports (CMTRs) had been detected. The QA Manager conducted a preliminary investigation and identified some problems in +"e rc:-;f C"TR dvuumentation. As a result of this, Zack QA j personnel undertook an in-depth investigation into the l documentation problems. Zack notified their customers of the inconsistencies identified on the following dates: Midland Station on August 28, 1981; Clinton and LaSalle Stations on September 25, 1981. Among the inconsistencies identified were examples of what appeared to be alterations to CMTRs. These alterations consisted of the use of stickers containing information on them such as ASTM material designations ar.d descriptive characteristics of the material and additions / modifications on the CMTR itself as evidenced by the use of more than one type face, the use of " white-out", a 4 or handwritten modifications. The stickers also had a signature, of questionable authenticity, that gave the impression that the stickers had been signed by the same individual who had signed the CMTR. As part of this inspection, an examination was made of CMTRs that had stickers attached to them. A comparison was made of the information contained on the sticker to that on the CMTR to which it was affixed and to revised CMTRs that had been acquired from the vendor. In many cases, the information provided on the sticker differed from that on the CMTR to which it was affixed because of the addition of the revision year for a particular ASTM standard. There were cases noted where the revision year provided on the sticker did not agree with the revision year provided on the revised CMTR acquired from the vendor. The lack of the ASTM standard year on a-CMTR is not considered to be a problem from a technical viewpoint as steel manufacturers supply material to the most current standard regardless of the ASTM revision year listed ) on a purchase order. The exception to this, of course, is that after a new revision to an ASTM standard is published, I 1 i ( Y
w ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 18 of 36
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material already in stock will be exhausted prior to shipping material manufactured to the new revision. In addition, it is noted that the revisions to the ASTM standards are normally minor in nature and consist of correcting typographical errors and restructuring the format and other similar changes that do not affect the structural strength of the applicable material. It should also be noted, that as shown in j Inspection Reports 50-373/82-51 and 50-374/82-18, there is a large design margin to failure for the materials utilized in the HVAC systems and thus sufficient room exists to allow for any minor perturbations in material changes due to revisions to the ASTM standards without affecting the soundness of the installed systems. There were a number of cases noted where the CMTR listed information on the material type in a form that did not specifically call out an ASTM standard. The attached sticker ~ put the information on the material type in a form that specified a particular ASTM standard. An example of this would be a CMTR listing "USS GALV. LFQ G90" with the attached sticker specifying " ASTM-A527-71/G90 COATING LFQ CHEM TREAT l NO OIL". Though the example given above for the CMTR listing is not the desirable way of listing the material type, it is s considered to be technically acceptable. This is based on i the fact that ASTM A527, Steel Sheet, Zinc-Coated (Galvanized) by the Hot-Dip Process, Lock-Forming Quality, is the only commercially available sheet steel that meets the requirements of being galvanized and of lock-forming quality (LFQ). With regard to the reference bn the sticker to " CHEM TREAT NO OIL," this is not considered to be a matter of. technical significance to the end use of the material and is not truly a part of the " material certification". Chemical treatment or oiling of the galvanized sheet steel is a buyer option allowed by the ASTM standard and only serves the purpose of preventing the formation of white oxide during shipment and storage. The discrepancies between the original CMTR, the sticker, and the revised CMTR, such as the listing of a general requirement ASTM standard (like A525) along with the specific ASTM standard (in this case A526 or A527), are not considered to be a material certification problem. a b \\ 'g i 9 / e
r v ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS i REPORT INSPECTION i NO.: 99900785/82-02 RESULTS: PAGE 19 of 36
== Conclusion:== This allegation was substantiated in that stickers of questionable authenticity had been added to a limited number of CMTRs and alterations / modifications had been made by Zack personnel to some CMTRs. However, during the review of CMTRs containing stickers and altcrations/ modifications and other applicable documentation, no items relating to this l allegation were noted that made the structural integrity of the installed HVAC systems questionable. 1. Allegation No. 9: Improper alteration of QA records through whiting-out previous information in order to create the appearance of compliance with legal requirements - A technical evaluation of this allegation was made in combination with allegation number 8. The details of the circumstances surrounding the alleged record falsifications and suspected forgeries are provided in OI Investigation Report for Case No. 3-82-025. j. Allegation No. 10: Improper requests by Zack management for vendors to supply unavailable information or to inaccurately j upgrade quality documentation - Some vendors, such as U. S. Steel, refused to participate in the improprieties. Other vendors cooperated to the letter of the request, even retyping the spelling errors in model certification letters supplied by Zack. Another vendor returned a blank form for Zack to fill in as needed. Review: It was alleged that two situations existed in which Zack vendors participated in improprieties. Situation 1: By letter dated January 22, 1982, The Zack Company wrote to RMC (Zack's refrigerator piping supplier) requesting a letter of e conformance for materials supplied to The Zack Company pursuant to purchase order C-9509. The Zack Company attached a sample letter of conformance showing the information requested. i 1 l f,; 3
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4 ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINDIS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 20 of 36 l t In response to this request, RMC provided a letter of conformance I dated January 22, 1982, identical to the sample letter of I conformance sent by The Zack Company to RMC. (The RMC supplied letter of conformance contained the same misspelling of the word l "auxilliary" [ sic] in three places, as did The Zack Company supplied sample letter.) The following information was obtained from a NRC review of RMC files and an interview of RMC employees. I During April 1976, RMC entered into a contract with The Zack l Company to provide materials and install 11 air conditioning systems at Commonwealth Edison Company's LaSalle County Nuclear Station. The contract specified RMC would provide the piping, fittings and valves, refrigerant specialties, refrigerant, labor, 4 testing, and start-up on 11 systems, which were: Service Building (systems: SB-1, 58-2, and S8-3) Off-Gas Building (systems: OG-1 and OG-2) t Auxiliary Building Laboratory (system: ABL-1) Auxiliary Building Offices (system: ABO-1) Control Room Building (systems: CR-1 and CR-2) I Auxiliary Equipment Electric Room (systems: AEE-1 and AEE-2) Of the 11 systems, 4 (AEE-1, AEE-2, CR-1, and CR-2) were nuclear safety-related. From the review of the RMC files by NRC personnel, it was learned RMC had a quality assurance program in effect and by letter dated April 15, 1977, The Zack Company had approved RMC's Job t I Procedures. This file review also disclosed that on February 14, 1978, The Zack Company wrote RMC and requested " certifications on the material that you furnish and install. This includes... copper tubing." RMC obtained the certification from its supplier, LeRan Copper and Brass Company, and transmitted it to The Zack Company on June 21, 1978. 1 n ~ ~~
w ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS i I REPORT INSPECTION i NO.: 99900785/82-02 RESULTS: PAGE 21 of 36 6 i 1
== Conclusion:== The Zack Company's request for a letter of conformance from RMC was not improper. There was no improprieties involved in RMC supplying Zack with the exact information they requested (in the Zack sample letter) since RMC had the same, appropriate conformance information properly documented and in their files. Situation 2: By letter dated March 31, 1982, The Zack Company wrote to the i Weldstar Company (a Zack welding electrode supplier) and advised i Weldstar that because of " site conditions," Zack had misplaced the certification for certain welding electrodes. In the letter, The Zack Company listed electrode heat numbers and requested Weld-I star to " resurrect" their copies of the certifications for the electrodes pertaining to those heat numbers. The electrodes i involved were type E6011, 1/8" and 3/32" diameter, and were issued in 1978 and 1979. In response to The Zack Company's letter, Weldstar replied by letter dated April 6, 1982. The letter stated in part, "In answer to your letter dated March 31, 1982, we do not have any recall on any certification papers dating as far back as 1978. Lincoln Electric Company has a form, which we are enclosing for your evaluation and files. This form will enable you to type any information that you are missing.* Due to this material in question being typical material, there should be no problem with your company filling out this information." A review of the Lincoln Electric Company " Certificate of Con-formance to Requirements for Welding Electrode" revealed that the certificate was properly notarized. (Lincoln Electric is the manufacturer of the welding electrode in question and a supplier to Weldstar of that electrode). On the Certificate of Conformance to Requirements for Welding Electrode the only information not present on the certification which could have been typed in by t The Zack Company was Zack's name, address, order number and date. This information is normally typed on the certification by the l supplier of the material circa the time the original order is supplied to the purchaser. l e T'6 2 f' ~ 96 s f' b g
- v ORGARIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS i REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 22 of 36 i The typical certification lists test data obtained during an annual h test of material of a particular classification. It certifies that the material supplied (in this case E6011 electrode) is of the same classification, manufacturing process and material requirements as the electrode sample used in that annual test. The American Welding Society Standard AWS AS.1-78, Specification for Carbon Steel Covered Arc Welding Electrodes, paragraph 2.9, i " Certification," states, in part, "For all material furnished under this specification, the manufacturer certifies that the material, or representative material, has passed the tests required for classification by this specification. When I required by the purchaser. the manufacturer chall ruraft5 a' copy of the results of those tests." It should be noted that 1/8" and 3/32" diameter E6011 electrodes have no test requirements under AWS A5.1-78. Electrode sizes having no test requirements can be classified provided at least j two other sizes of that classification (e.g., 5/32" and 3/16" diameter E6011 electrodes) have passed the tests required I for them. This is the case with the 1/8" and 3/32" diameter E6011 electrodes supplied by Lincoln Electric to Weldstar, and subsequently to The Zack Co,npany. The following information was obtained through discussions with the President and Quality Assurance Mananger of Weldstar, during a visit to Weldstar. The only material (other than certain welding equipment and accessories) that Weldstar provides to Zack for nuclear related applications is welding electrodes. The E6011 welding electrodes supplied to Zack are manufactured by the Lincoln Electric Company, purchased from Lincoln by Weldstar, and subsequently distributed by Weldstar to its customers. All welding electrodes supplied to The Zack Company are accompanied by the appropriate certifi-cation documents. In addition, the containers in which the Lincoln Electric Company packages its E6011 welding electrodes specifically state that the material " conforms to AWS A5.1". While at Weldstar, NRC personnel randomly reviewed four of the seven Weldstar invoices which pertained to the heat numbers referenced in The Zack Company's March 31, 1982 letter. Each of the Weldstar invoices reviewed indicated that typical material certifications had been provided with the material shipments. t Nii J ..i- .~ O l e e j I S 5 +-
l .i ORG.ANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 23 of 36 i 1
== Conclusion:== t l The Zack Company's request for copies of misplaced welding i electrode certifications was not improper, k t Although the certificate of conformance did not contain The Zack Company's name, address, order number or the date, there was no impropriety involved in Weldstar providing The Zack Company with the certificate for the E6011 electrodes which they supplied. l k. Allegation No.11: Failure to distinguish between commercial and nuclear purchases on Purchase Orders - Since items purchased for nuclear use have much stricter quality verification requirements than those purchased for commercial use, this omission led to the improper upgrading program described above. f Review: l l The NRC inspector reviewed the project specifications for the i work being performed by The Zack Company for the LaSalle, Midland, l and Clinton sites: Sargent & Lundy Engineers Technical Specification No. J-2590, Revision 1, dated April 10, 1975 through i Amendment No. 1, dated November 11, 1981 - LaSalle County Station, Units 1 and 2; Bechtel Power Corporation Technical Specification No. 7220-M-151A(Q), Revision 0, dated November 17, 1976 through Revision 11, dated March 4, 1982 - Midland Power Station, and Sargent & Lundy Engineers Technical Specification No. K-2910, dated January 18, 1978 through Amendment No. 4, dated January 21, 1982 - Clinton Power Station. Certain portions of the work for all three sites have been classified as " Safety Related." In addition, the associated purchase orders from the customers to The Zack Company were reviewed, and in only one case could the imposition of 10 CFR Part 21 be identified; that being in Bechtel's purchase order number 7220-M-151, Amendment Number 21, dated March 12, 1980. .The customers procurement documents specify the materials to be used in the construction of the HVAC systems, and in the case of equipment used in the HVAC systems; e.g., balancing, fire, and gravity dampers, motors, fans, etc., even the specific suppliers The Zack Company must use. A total of 201 Zack Company procurement files were reviewed. These files consisted of Zack Company purchase orders and supplements, shipping documentation, material test reports, certificates of conformance, applicable correspondence, receiving inspection reports, and copies of nonconformance reports (if required). These files covered a time frame from September 1975 to present and represent purchases destined for all three sites. ,m n.v. - . v oo,,e m ~+r -w.v-me.+ +m_** 9[ -8 1 7 t 2y J
e ~1 ORGARIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 24 of 36 f
== Conclusions:== i l The Zack Company did not distinguish between commercial and I nuclear purchases of material on their purchase orders nor were l they required to. They procured materials in accordance with the designated materials in the technical specifications. When purchasing equipment which is designated by the customer as safety-related, The Zack Company includes words to the effect, " Furnish and deliver all (equipment) in accordance with the i l attached plans, specifications, standards, technical criteria as required by specification (number). QA program, QC procedures, and seismic qualifications to be delivered." The Zack Company infrequently used the term nuclear safety-i related in their purchase orders until June 1981. At that time it l was decided to try and make their purchase orders consistent with the end use of the materials they were procuring, if known. j Upgrading of materials / equipment is not considered improper. A company may procure commercial grade material / equipment and take the responsibility for upgrading to meet the requirements of their customers procurement documents. i l 1. Allegation No. 12: Unqualified vendors on the AVL - This occurred i due to the absence of necessary surveillance of vendor QA programs. Review: The NRC inspector reviewed Zack's Quality Assurance Program Manual, Revision C, dated October 21 1976 This was approved by Sargent and Lundy by letter dated October 16, 1975. - Section 4 of Zack's QA Manual, titled " Procurement Control", states, in part, "the quality of all purchased equipment shall be controlled as follows: All vendors supplying equipment for this project shall be required to submit for approval, shop drawings and other data, in sufficient detail to establish that the quality of the product they are to furnish meets or exceeds the requirements of the contract. Purchasing shall maintain a card file on suppliers, and only those suppliers who qualify shall be used. To qualify, a supplier must have properly filled orders placed by the Zack Company in the past, and must have an established record of consistently delivering the correct type, grade, quality and quantity of material...." l l s- '$g xu.d 4
e ORgARIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS l REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 25 of 36 Zack's Quality Assurance Manual, Section 5, " Procurement Documents",' Revision 5, dated March 1, 1977, approved by Commonwealth Edison Company by letter dated April 22, 1977, states, in part, "All' suppliers who qualify are placed on an approved bidder's list by Zack by meeting the following conditions: 1. Submit a quality control manual or certification as required by Zack or the contract. 2. Have the submitted date approved by Zack, if required. i 3. Establish a " Quality" record with Zack for at least 3 years. i l 4. Furnish certificates of compliance for their product"if required. All suppliers shall be maintained on active approved status providing they maintain their quality control standing with Zack, and Zack shall not require, or be required to conduct additional audits unless required by contract." i In addition, Baldwin Associates approved the Zack QA Manual, Section 8, Revision 0, dated February 28, 1979, titled " Control of Purchased Material, Equipment and Services", by letter dated June 22, 1979, for the Illinois Power Company, Clinton Project. Also, Bechtel Power Corporation approved the Zack QA Manual, Edition IV Revision 0, dated July 11, 1980, by giving a status Level I approval. The NRC inspector also reviewed one of Zack's initial approved vendors list. The methods of evaluation and approval of vendors was to perform an audit at the vendor's facility, place a vendor on the approved list based on an ASME Quality Systems Certificate (Materials) or an N Stamp, source evaluation, the supplier's performance for at least one year with a low rejection rate, and a review of receiving inspection reports with a low record of NCR, or hold reports. F 4 1 ?, t
w ORGANIZATION: THE ZACK COMPANY. ~ CHICAGO, ILLINOIS l REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 26 of 36 '^ h Of scussion with Zack Company pe'rsonnel ' indicated that audit reports of several of those vendors that had been audited j could not be fcund and that they had bewn misplaced or lost. l A new approved vendors < list,' approved on July 7,1982, was j made that included only those vendors scpplying nuclear safety-related and nonsafety-related-seismic items. This apprcved vendors list contained 51 suppliers of safety-related material equipment. Forty-five have been audited between Septemoer 1981 and June 1982 and found to be acceptable. The remainin~g six suppliers are-h61ders of N Stamp or Quality System Certificates (Materials) and thus, are not required to be audited / surveyed. I
== Conclusion:== This allegation has not been substantiated. Procedures governing control of vendors for the LaSalle project did not l require an approved vendors list. The use of vendors was based on past satisfactory experience. Based on a discussion j with Zack personnel on February 7,1983, an approved fendors . j list was required for.the Clinton and Midland projects which ^ was also used.for the LaSalle project. The same vendors supplied material for all three proje' cts and were considered { qualified. The Zack QA Manuals for the three projects (LaSalle, Midland, and Clinton) have essentially the same requirements for vendor surveillance and is considered adequate for the safety significance of the HVAC systems, and is considered-to meet the requirements of the ASME B&PV Code for a non pressure retaining vessel. 4 F r. M + 1 e Y 4 s a 1 1 ,i f.?, < p. 2 ,ey. s, a V
~ ORGAN'IZATION: THE ZACK COMPANY 1 CHICAGO, ILLIN0IS REPORT INSPECTION NO.: 99900785/82-02' RESULTS: PAGE 27 of 36 i I m. Allegation No'. 13: Failure to remove unqualified vendors from the AVL - Even if Zack determined a vendor was unqualified, that did not guarantee the vendor's removal from the AVL. For example, l' Zack received approximately 38 Purchase Orders from the Delta Screw Company during the period it was " removed" from the AVL. Review: 1 During the investigation of this allegation, the NRC inspector established the following: l 1. There was no 1981 fall audit of Delta Screw. However, H^ there was an audit (C/L No. ZC-VS-82-69) performed by Zack of Delta Screw dated February 10, 1982, which found the vendor to be satisfactory. 2. There was a Zack memo, dated October 20, 1981, removing Delta Screw Company from the approved vendor list (AVL). This was the apparent result of a telecon on or before October 20, 1981, between Zack and a NRC Region III inspector discussing traceability of bolting material. l l 3. There was a Zack memo, dated December 17, 1981, to all } ~ Project Managers, Document Supervisor QA, Quality Engineers, QA File Approved Vendors List, and Purchasing Department, approving their commercial fastener s suppliers for safety and nonsafety-related fasteners. 4. A review of the Master Purchase Order Log indicated that 12 purchase orders containing a total of 40 entries, had 'T been placed with Delta Screw, between December 22, 1981 T and February 17, 1982. There were no purchase orders placed with Delta Screw during the period of October 20, '~ 1981, through December 17, 1981, and there was no receipt of material for the LaSalle, Midland, and C1tnton projects during that period. S. Zack officially placed Delta Screw Company on the AVL on February 10, 1982. 4 V ~ I
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r 3 s A e. -g y v y y ,~ ORGANIZATION: THE ZACK COMPANV-i CHICAGO,.ILLINQIS l INSPECTI0is [ REPORT RESULTS: PAGE 28 of 36 i NO.: 99900785/32-02 ' .I Concluiion: i i ~ 'This hilegation has been substantiated in that Zack did make purchases.from Delta Screw Company prior to officially placing Them on the AVL on February 10, 1982. However, based en Zack's memo dated December 17, 1981,,it is obvious that the intent was to place the Delta Screw: Company back on the i AVL effective that date and that purchases from them had been approved from diat date on. Since no instances were found where purchasas were placed wit'h Delta' Screw Company between October 20, 1981; and December 17, 1981', it'is considered that.Zack compliid with the intent of their~ QA Manual but made a clericdl error in not actually placing Delta Screw. Company on the AVL until Fsbruary 10, 1982. n. Allegation No. 14: Management awareness of QA breakdown - Zack management was painfully aware of the proslem. As the company conceded, "There has been a breakdown of the quality assurance 3 program as-reta'ted to criterions [ sic] VI - Document Control, i and VII - Control of purchased material, equipment and services } .The company promised reform and training to the QA J staff. But'the commitments were not honored. Instead, Zack ,ma'agement scapegoated the staff for problems created by its own n 1 negl ec.t. j' i Review: The NRC inspxtor reviewed The Zack Company's potential 10, CFR. Part 50.55(e) report, the reorganization effort towards establish - ing a formal. document controlisystem, including the use or a-o \\ \\ consultant t~o' initiate document contrdl? procedures, and the subsequent hiring of six individuals *to Jm'plement the system. In addition, ti@ indoctrinatio'n 'and trainino rUcrds of certain 2 -,e of these ihdividuals were rOvikwed. \\g 3 s 4 Conclusion (( w .a m y.; The Zack Company management was aware'of the, breakdown in quality 7' assurance as stated in their document "The Zack Company-Potential: 10 CFR Part 50.55(e), Reportable Defect Evaluation for Material Certification Deficiencies" which wts?'sEomitted to their customers under cover letters dated Octesber 23, 1981. k I" i -* g u _4 .l 4 g ci w[ y i n
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l ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS L. REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 29 of 36 The Zack Company kept its commitment to reform, by: (i) employing a consultant to establish a formal document control system; and (ii) employing six individuals to implement the established system. The Zack Company provided indoctrination and training as identified in D 2.b. above. o. Allegation No. 15: Harrassment, attempted intimidation and retaliation against QA staff - All current and former Zack { _ employees who were contacted confirmed this allegation. The tactics included dismissal threats, severe personal abuse, accusations of petty misconduct, and eventually dismissal of the entire QA documentation staff through a pretextual (sic) reorganization. } This item is being addressed in OI Investigation Report for Case No. 3-82-057. p. Allegation No. 16: Bad faith progress reports to the utilities - Zack disguised its misconduct through false reassurances to its utility customers. To illustrate, the company reported to Midland on a partial review of some 2,900 purchase orders. Although the review was less than half complete, the Zack President charac-terized it as a " total document audit." Review: A review of The Zack Company progress reports was made. The iden-tification of the progress reports appears to be confusing in that there are external and internal progress reports. However, the following lists the reports by chronological order, with a brief description of each. (i.a) August 28, 1981 - initial letter to Bechtel Power Corporation (Midland) from The Zack Company, addressing the identification of a possible 10 CFR Part 50.55(e) reportable defect. (i.b) September 25, 1981 - initial letters to Baldwin-Asso-ciates (Clinton) and CECO (LaSalle) from The Zack Company addressing the identification of a possible 10 CFR Part 50.55(e) reportable defect. ..? [ '. t: %~ x b ' K WYW l$N ?A : ' N
[ I ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS i t REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 30 of 36 i 2 1 (ii) October 23, 1981 - letters to all three customers with attached copies of The Zack Company potential 10 CFR i Part 50.55(e) Reportable Defect Evaluation for Material l Certification Deficiencies. Section 3.0 of this report j states that a total of 1330 purchase order (PO) packages have been reviewed as follows: Midland-550; Clinton-375; and Lasalle-405. i (iii) October 23, 1981, internal memorandum, subject: " Third Interim Report-0ccumentation Review Results as of October 23, 1981." This memo states in part, "It is felt 4 that the current-State: cf the review prece55 should bw categorized as preliminary. Essentially the review has i not been an indepth analysis of all documentation. Appreciable progress has bada sede toward assessment but final status has not been firmiy defined." The memo also states that approximately 1,750 packages I have been reviewed. (iv) January 15, 1982 - Addendum to LaSalle Power Station showing corrected P0/CMTR packages from first to second report. j (v) Jar.ua ry 22, 1982 - letter to Baldwin Associates (Clinton) i from The Zack Company, regarding an attached, updated report on the status of tt.e material certifications identified in (ii) above.. (vi) February 10, 1982 - two lettees to the LaSalle County Station QA Superintend =.it, from The Zack Company regarding an attached, updated status report of purchase orders. (vii) February 12, 1982 - letter to Bechtel Power Corporation (Midland) from The Zack Company regarding an attached, i updated status report dated January 15, 1982. This 1etter states in part, "... As indicated by the i report, a significant increase in the number of l corrected purchase order packages has been accomplished and a number of the remaining purchase orders indicated as still discrepant have only one or two items tc be corrected. i .l 5 '..* Ne 9 g g
l l ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS l l REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 31 of 36 i. i (viii) February 12, 1982 - letter to Commonwealth Edison Company (LaSalle) from The Zack Company regarding an attached, updated status report dated January 15, 1982. This letter states in part, "... As indicated by the report, a significant increase in the number of corrected purchase order packages has been accomplished and a number of the remaining purchase orders indicated as still discrepant have only one or two items to be l corrected. (fx) April 29, 1982 - letter to Baldwin Associates (Clinton) from The Zack Company regarding an update of the report sent January 22, 1982, in (v) above. l (x) May 3, 1982 - letter to Baldwin Associates (Clinton) from The Zack Company regarding corrective actions taken as of May 3,1982. I I (xi) June 29, 1982 - internal memorandum regarding status of the Clinton Station material discrepancy reports in j (v) above. It should be noted that one letter in item (vi), and the item l (vii) and (viii) letters were prepared and signed by the Document Control Supervisor, who is one of the allegers. Further, item (iv) was prepared by the Document Control Supervisor, although not signed by him. The NRC inspector did not find reference to "a partial review of some 2,900 purchase orders." A letter dated November 12, 1981, from the president of The Zack Company to Mr. J. W. Cook, Vice President - PE&C, Midland site, Consumers Power Company, states in part, ". . The Zack Company would like to express our sincere gratitude to Consumers Power Company for the loan of your employee, Mr. Howard McGrane, for ,the total document control audit of our corporation...."
== Conclusion:== The document control supervisor (alleger) and his staff was responsible for the purchase order document file review and either preparing or providing input to the status reports supplied to the customers through April 29, 1982. J Ti ~ A ? -S.
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v ORGAMIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 32 of 36 i A nonconformance was identified and is contained in NRC Inspection Report No. 99900785/82-01. g Apparently the quote used in allegation number 16 has been changed from the actual words used in The Zack Company president's letter, such that the meaning is somewhat different. This allegation has not been substantiated. i q. Allegation No. 17: Failure to adequately discipline those responsible for records falsification - The company promised l its utility clients to identify and take appropriate action against the guilty parties. Although the responsible executive was identified,-the " appropriate disciplinary action" consisted of a paperwork demotion and additional training. Review: A review was conducted of The Zack Company report identifying { certain potential 10 CFR Part 50.55(e) related deficiencies. The report revealed that among the deficiencies identified during The Zack Company review of purchase orders and corresponding certifi-cations were " stickers" and " alterations." Stickers pertained to l situations in which gummed labels had been applied to purchase order certifications and cover sheets. The Zack report states: "These labels were typed and signed by the individual originally certifying the data to indicate ASTM designation in full. t Authenticity of the signature is questionable." Regarding i alterations, the Zack report states alterations involve "those certifications that have apparently been altered by typed or handwritten changes." An excerpt from The Zack Company report describes in part, the 'f corrective action taken regarding these situations. "Those person (s) involved in the modification to material certi-fications have been identified and reprimanded by The Zack Company Ownership. This reprima:d consisted of demotions in position and documented letters to the personnel files. An intensive and individualized training was then given with respect to the requirements and necessity for accurate and controlled documen-tation. E ?? R l. g , _i _ __1
OR,GANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 33 of 36 Y "As stated previously, The Zack Company management and ownership assumed part of the responsibility for those unauthorized actions because it allowed an enviroment [ sic] conducive to this type of action to exist. The Zack Company also has taken into consideration that the individual (s) involved are loyal employees and while their actions are not condoned, it is understood that it was done with the thought that it was helping the company. j Therefore, The Zack Company perceived that the most beneficial action for both the company and the respective projects was not in the loss of these individual (s) but rather in the redirection and controlling of their efforts. "However, because of the implications of this action by these individual (s) the responsible party (ies) have been advised that any further action of this type would result in immediate dis-3 missal."
== Conclusion:== The determination of whether or not adequate disciplinary action has been taken with regard to actions committed by the employees of a licensee's vendor, is not a matter within the purview of NRC regulations. i The matter of records falsification is addressed in OI Investiga-tion Report for Case No. 3-82-025. r. Allegation No. 18: Surrender to unrealistic utility deadlines - Zack was under intense pressure from its utility clients, in particular Com Ed, to rush the quality verification of its purchases. Rather than defend the integrity of its QA reform program, Zack succumbed and attempted to produce a " rush job". That is why the company pressured employees to work over-time and perform tasks for which they were not qualified. There was not time to do the job properly. (When the QA staff refused to sign off on unacceptable records, management personnel did it themselves.) f E. 9_ 'e [ T- [j'". ,-p / ' 1
,I ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS 4 i REPORT INSPECTION l NO.: 99900785/82-02 RESULTS: PAGE 34 of 36 i Review: A review of correspondence of The Zack Company provided the x following information. The Zack Company informed Commonwealth Edison Company (CECO), by letter dated September 25, 1981, of a i potential 10 CFR Part 50.55(e) reportable defect and a review / l evaluation was being conducted. An attachment to the letter, corrective action report number 014-a, committed to completion of this review by October 30, 1981. The Zack Company issued reports on October 9, 1981, and October 23, 1981, in which identified deficient items were categorized. The October 23, i 1981, report committed to obtaining all missing and/or corrected certifications by December 31, 1981. j A letter from CECO to The Zack Company, dated November 2, 1981, . requested submittal of all Zack Company nonconformance reports (NCR) requiring engineering disposition by CEC 0/Sargent & Lundy ' Engineers (S&L). All other NCRs were not to be submitted. On November 13, 1981, The Zack Company submitted 15 NCRs. CEC 0/S&L completed their disposition on December 31, 1981. In January 1982, additional Zack Company NCRs were reported open. The Zack Company was requested to submit all NCRs still open as of March 1, 1982. Discussions with The Zack Company personnel indicated that there were frequent, verbal discussions with CECO personnel prior to March 1, 1982. On March 1, 1982, The Zack Company sub-mitted 69 NCRs which were still open. It was determined by CEC 0/S&L that these NCRs did not require their engineering disposition; thus, were returned to The Zack Company for their resolution. On April 1, 1982, The Zack Company submitted 21 open NCRs, which, in their view required CECO /S&L engineering disposition. The last of these NCRs were closed out on April 9, 1982. Additional information is contained in special safety inspection report 50-373/82-51, 50-374/82-18.
== Conclusion:== There was no documented evidence of unrealistic utility deadlines being imposed upon The Zack Company. An issue such as working overtime is not a matter within the purview of NRC regulations. chl 2# ,[ a e#*'[s A ,f', j 3
~ w OR p lZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS i i REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 35 of 36 b l It has already been eet?.blished that The Zack Company reported conditions which included the use of labels with signatures whose authenticity is questicnable, and certifications that have i apparently been altered by typed or handwritten changes.
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this was identified prior to the hiring of the QA documentation staff. It could not be determined that these practices continued after The Zack Company had identified and notified these condi-tions to their customers. There was no evidence of managernent, other than those qualified, signing off on QA records. s. Allegation No. 19: Utility knowledae of the QA breakdown - There can be no question that the utilities have been aware of the Zack breakdown. The company was the subjeco of previous requests to l stop shipping nonconforming material, as well as previous severe enforcement action at Midland, whose owner Consumers Power even loaned a contract employee to help straighten out Zack's QA records deficiencies. At LaSalle, Zack informed Commonwealth Edison that it could not supply adequate information to properly correct 69 of 99 QA nonconformances. This allegation, as it pertains to LaSalle, is addressed in special safety inspection report 373/82-51; 374/82-18. The special safety inspection reports for Midland and Clinton will address this allegation as it pertains to them." t. Allegation No. 20: Utility complicity with the ongoina breakdown - When formally notified of Zack's miseries, the QA management for the utilities and their contractors failed to face up to their responsibilities. Instead, Com Ed pressured for a rush job in the corrective action program. At Midland, the contractor Bechtel was satisfied if it were " highly probable" that Zack ordered the correct material. The Midland QA program responded to Zack's QA effort with an effort to rewrite the QA rules. Even before the effort was completed, the Midland QA management decided that "in virtually all cases, material is acceptable or will be deemed acceptable." i This allegation, as it pertains to LaSalle, is addressed in special safety inspection report 50-373/82-51, 50-374/82-18. The special safety inspection reports for Midland and Clinton will address this allegation as it pertains to them. f 1 l t c L
ORG6GZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS REPORT INSPECTION NO.: 99900785/82-02 RESULTS: PAGE 36 of 36 u. Allegation No. 21: Utility complicity with retaliation - In desperation, Mr. Howard and another Zack QA employee, Mr. Ronald Perry, disclosed the QA deficiencies to officials at LaSalle and Midland. In each case, the discussions were supposed to be confidential. In each case, the Zack employees were soon subjected to recrimination and harrassment, suggesting that the confidences were not honored. In Mr. Howard's case, the entire QA staff was dismissed within two weeks of his disclosu;e to the Midland QA Manager. This item is being addressed in OI Investigation Report for Case No. 3-82-057. i v. Allegation'No. 22: Inaccurate public denials by utilities of the Zack deficiencies - To illustrate, a Commonwealth Edison I spokesman stated in a Chicago television interview that the Zack records were reviewed thoroughly by its Architect / Engineer Sargent & Lundy. In fact, an internal January 1982 Surveillance i Report at LaSalle revealed Sargent & Lundy had... celeted the requirements for submitting on-site contractor documentation (such as Zack's) to S&L for review. This review is now the responsibi-lity of the Zack Company. Based on this change, S&L's letter accepting Zack's documentation is no longer required. This allegation, as it pertains to LaSalle, is addressed in special safety inspection report 50-373/82-51 and 50-374/82-18. I The special safety inspection reports for Midland and Clinton will j address this allegation as it pertains to them. i l I s_
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UNIltO $1 Af t5 8 [.. ,b NUCLEAR REGULATORY COMMISSION HE GION IV " (#* 511 RYAN PL AZA DRIVE. suite 1000 I \\,* AnLING10N, T[XAS 7(,011 DCT 121992 Docket No. 99900785/82-01 i The Zack Compan.y ATTN: Mrs.ChristeneZNckDeZutel l President i 4600 W. 12th Place Chicago, Illinois 60650 ? l Gentlemen: This refers to the inspection conducted by Mr. L. E. Ellershaw of this office on August 3-6, and September 10, 1982, of your facility at Cicero, Illinois, associated with the manufacture of heating, ventilation and air conditioning -(HVAC)systemsandtothediscussionsofourfindingswithyouandmembersof your staff at the conclusion of the inspection. This inspection was conducted as a' result of the receipt by the Nuclear Regulatory Commission (NRC) of allegations pertaining to implementation and. enforcement of The Zack Comparyy quality assurance program, and was performed in conjunction with an investigation by the Chicago Field Office of the NRC Office of Investigation. Specific findin s pertaining to the allegations are contained in NRC Report No. 99900785/82-0. The main purposes of this inspection were-to assist the investigative sta f in the evaluation of identified concerns and to establish whether HVAC system manufacture was consistent with applicable codes, contractual and regulatory reguirementd. QA, programmatic areas relating to the allegations,were selected for inspection and included welding process i control, nonconformances and corrective action, audits, indoctrination and training, document control, QA records, procurement document control, welder j qualification, and implementation of 10 CFR Part 21. Areas examined and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an examination of procedures and representative records, interviews with personnel, and ob.servations by the inspector. During the inspection it was found that the implementation of your QA program failed to meet certain NRC requirements. The specific findings and references to the pertinent requirements are identified in the enclosures to this letter. / ' N 2
9 i The Zack Company Please provide us within 30 days from the date of this letter a written state-ment containing: (1) a description of steps that have been or will be taken to correct these items; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the date your corrective actions and preventive measures were or will be completed. Consideration may be given to extending your response time for a good cause shown. The response requested by this letter is not subject to the clearance pro-i cedures of the Office of Management and Budget as required by the Paperwork l Reduction Act of 1980, PL 96-511. In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains an l exempt from disclosure under 10 CFR 9.5(a)y information that you believe to be (4) it is necessary that you (a) notify this office by telephone within 10, days from the date of this letter of your intention to file a request for withholding; and (b). submit within 25 days from the date of this letter a written application to this office to withhold such information. If your receipt of this letter has been delayed such that less than 7 days are available for your review 11 ease notifythisofficepromptlysothatanewduedatemaybeestablisted. Consistent with Section 2.790(b)(1), any such application must be accompanied by an affidavit executed by the owner of the information which identifies the s document or part sought to be withheld, and which contains a full statement of the reasons on the basis which it is claf aed that the information should be. withheld from aublic disclosure. This section further requires the statement to address wit 1 specificity the considerations listed in 10 CFR 2.790(b The information sought to be withheld shall be incorporated as far as po)s(4). sible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, the report will be placed in the Public DocumentsRoom. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, n / *-/ t.).;/:t.i UU.% John T. Collins Regional Administrator i
Enclosure:
l 1. Appendix A - Notice of Nonconformance i 2. Appendix B - Inspection Report No. 99900785/82-01 1 3. AppendixC-InspectionDataSheets(6pages) u ]
9-APPENDIX A The Zack Company Decket No. 99900785/82-01 NOTICE OF NONCONFORMANCE I Based on the results of an NRC inspection conducted on August 3-6 and September 10, 1982, it appears that ce~rtain of your activities wer,e not con-ducted in accordance with NRC requirements as indicated below: Criterion V of Appendix B to 10 CFR Part 50 states: "A ti ities affecting c v quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be~ accomplished in accordance with these instructionsrprocedures or drawings. Instructions, i procedures, or drawings shall include appropria,te quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." Nonconformances with these requirements are as follows: '~ A. Section 10 of the QA Manual, duct work, a, Revision 3 states in part, "All welding for Class 1 strict accordance w kind shall not be permitted...." Welding Procedure Specification WPS-1, a Gas Metal Arc Welding procedure, paragraph 13.0 states in part, "This withAWSD1.1-79,Section5,PartB.procedureisqualifiedinaccordance j AWS 01.1-79, Section 5, Part B states, in part, "In areparing the procedure specification, the manufac,turer or contractor siall report the~ specific values for the essential variables that are specified.... The changes set forth in 5.5.2.1 through 5.5.2.5 shall be considered essential changes in a welding procedure and shall require establishing a new procedure by qualifica-tion...." Part 5.5.2.3 essential var,iables:" Gas Metal Arc Welding" (GMAW), identifies the follcwing A change in electrode diameter; a change of more than 10% above or below the specified mean amperage for each diameter electrode used, and an increase of 25% or more a decrease of 10% or more in the rate of flow of shielding gas or mixture. WPS-1 the welding of ASTM A-36 material, was qualified with a, when used for 0.045 inch diameter electrode at 195 amps with a gas flow rate of 20 cubic feet perhour(CFH). g h 5 ~ p
, (.,'.*;..- q l ' 1 Contrary to the above the NRC inspector observed deviations being permitted and changes,to essential variables being made without the a )tocedure being requalified during GMAW of duct rings for the Midland )lant, in which the welder was using 0.035 inch diameter weld wire 125 amps and a gas flow rate of 30 CFH. This was the only in proc,ess 3 2 j welding o,bserve.d by the NRC inspector during this inspection. B. Procedure QCP-29, " Plant Procedure for Welding Electrode Control," Revision 0 dated September 5 1979 Section 5, states in I The Foreman, will record daily,on the Weld Material Contro art, "... Sheet: The i welder's name and symbol; date; weld procedure to be used; type, size, and amount of rod issued; rod heat number... and amount returned Section 7 states in~part, hall be protected so that its characte its original package, it s or welding properties are not-affected.... TraceabiHty ui electrodes is accomplished by checking dates in (the) specific Zack Company traveler and weld material control sheet." Contrary to the above, the following conditions were identified: 1. Electrodes (bare wire on spools) ~were not being protected in that three spools of stainless steel electrodes each of a different i type, were observed under a work bench in a,n uncovered condition. Further, two spoolt had been issued on December 17, 1981, and the other on April 16, 1982. 2. Traceability of these electrodes would be precluded when used at a time later than the issue date, in that the date of issue as shown on the weld material control sheet would not coincide with the date of actual welding on.a specific Zack Company traveler. ~ C. g' A Manual Section 6, Revision 3, dated September 26,ic 1977 states in part, Fabricationinstruction(s)areprovidedtothefabr Engineering in the form of Shop Travelers that specifically set forth all necessary data. Inis will include: . any special processes to be used such as machine rolled, welded construction, etc...." AWS D1.1,information, Part A, paragraph 2.1, states in Section 2 welds shall be clearly shown on the drawings., siz complete regarding location, type and extent of all ... Detail drawings shall clearly indicate by welding symbols or sketches the details of groove welded joints and the preparation o,f material required to make them...." l 4 h i O. i
1 J t. Contrary to the above, full and complete information regarding location, type, size and extent of welds weldjoints and material preparation j was not sho,wn on shop travelersIdetail drawin,gs provided to shop person,n The only information provided was the welding procedure spe,cification + number, which does not delineate the above information. 0 D. QAManualSectidn10 part, "All welding.,.page 2 Revision 3, dance with our, established - 1 .shallbeinaccor { welding procedures andsubjecttothere l tion set forth in the welding pracedures.2quirements, tests, and inspec-Contrary to the above, litativii acceptance criteria for weldsins include appropriate qua Therefore without acceptance criteria being. stipulated s ments were not set forth in welding procedure,s.pecific inspection requ j E. . part, hop to insure that the activities emp 4 page 4 Revision I dated March 1 "The controlle int $efabrica-j j tion s 1 l being satisfactorily accomplished. l. " Shop supervis(4 shall be responsible for checking all shop fabrication j tickets to insure that they are complete in all respects.... 1 "They shall be checked for method of fabrication welded seams or machine - t rolled, or any other special process that is requ, ired and the extent of j supervision or inspection required during production." i Contrary to the above, shop fabrication tickets were not complete in { all respects in that they did not address certain fabrication methoas/ operations an,d their sequencing; e.g., rolling or forming' and galvanizin t j F. QA Manual Section 8 page 1, Revision 2,' dated September 16,1977, states i in part ...allpurchasesthataremadewillbemadebyusingawritten 1 purchase, order. Any verbal orders shall be confirmed in writing as soon as possible." Page 2 Revision 1 i ... For Nuclear Plant and/or s,eismic applicaliondated March 1 1 states in part p material certifications will be supplied by vendor.,All purchase orders will contain specific statements requiring certification and physical and chemical properties of materials as required...." Section9,page1,QualityCon{rolInspectors,hallInspectth Revision 1 dated March 1 1977 states in part ... The plant i material to insure that it meets the recuirements of the purchase order l and that it is acceptable for its intenced use...." i 1 4i l ',) "F. L ~
Contrary to the above, the following conditions were identified: 1. The Zack Company placed purchase order (PO) Number C-4199 with ~ 1 Central-West Machinery Company in November 1980 for 152 gallons of 1 j Hardcast FTA-20. This material was received and accepted. Q Subsequently, a verbal order for an additional 24 gallons was placed i and received in November 1980, and as of the date of this inspection, l no written confirmation has been made. 2. The Zack Company placed P0 Number C-874 with Griffiths-McKillen Steel Company on July 5, 1979, for 3000 lbs. of 14 gage ASTM A-240 Type 304-2B stainless steel and 600 feet of 1\\ x 1 x 1/8 stainless angles, ASTM A-276 Type 304 with certifications required. I The received and'acce)ted certification 18, 1979, for the ASTM A-240 material s10ws the following:, dated Julytensile stre { phosphorus-0.38;~ sulfur-0.06 and nitrogen content is not addressed. The ASTM A-240 standard requires 70,000 psi tensile strength minimum, 0.045 maximum phosphorus, 0.03 maximum sulfur, and 0.10 maximum nitrogen. (NOTE: This material was ordered as nonsafety related it does indicate inadequacy of the receiving inspection ;' however function,.) i 3. The Zack Company placed P0 Number C-4458 dated Jul 30 Hobart North for 30 Jbs. stainlesssteelweldrod,y/32"T1981, with 3 The P0 stated " Actual or Typ'ical Chemistry, RT (radiographyhpe 308 ,mechani-cals, Charpy V notch tests. i The Certified Material Test Report (CMTR) was received and accepted 4 by Zack Company, but did not address RT or Charpy V notch tests. (NOTE: ThematerialspecificationdoesnotrequireRTorCharpy's.) 4. The Zack Compan dated August 4 Vincent Brass &y placed P0 Number C-9433 Aluminum Com of 22 gage stainless coils, Type 316, ASTM A-240, with mill certifi-cations required. The material was received with a certification, dated August 9, 1976. The 20 gage material was returned to Vincent due to damage. 1
- However, the 22 gage material was accepted, although the certification did not list a heat number and did not provide the actual chemistry.
The chemistry stated on the certification was simply a reiteration of the chemistry requirements stated in ASTM A-240. (NOTE: This material was ordered as nonsafety-related; however, this does not negate the statedrequirement). i l'y
. 5. The Zack Company placed PO Number C-739, dated September 29, 1978, with U. S. Steel Company for 20 tons of ASTM A-527, A-535 galvanized coils. Certifications were required. The material and certifica-tions were received and accepted showing the heat numbers as J 74531 and J 74278. i The certification did not provide physical test reports for heat J 74531. properties (NOTE: The ASTM material standard does not require physic to be re)orted however this material was purchased for i useattheClinton)ower.$tationslte,andtheClintonspecification did require physical properties to be reported.) G. Section7.1.2ofPQCP-7, Revision 8 " Plant Document Control" states in part, " Customer approved editions /r.e, visions to the ZQAM are controlled by. theQAM. Such control to include as a minimum the following: 7.1.2.4 Establishment byproject of a file of voided documents. 7.1.2.5 Documented distributio,n requiring, written acknowledgment *f-receipt." Section7.2.2ofPQCP-7, Revision 8 states in part, "New or revised... WPS's approved by the customer, are, controlled by the QAM. Such control to include as a minimum the provisions of paragraphs 7.2.1.2 through 7.1.2.5 above." Contrary to the above the file of voided documents did not contain Revi-sion0totheZQAM(ClintonProject nor Revisions 1 2, 3, and 5 of WeldingProcedureWPS-1.'Therewas)nodocumentation,toshowtha Manager at Clinton, who is on the Controlled Copy Distribution List received a copy of WPS-1, Revision 10 (June 1,1981) or the ZQAM, Revision 1 (September 30,1980). H. Section 19, " Audits" of the QA Manual (ZQAM-Revision 3) for LaSalle states in part theQualityControlDepartmentManager....""In plant audits shall be Section 19," Audits" of the QA Manual (ZQAM-Revision 1) for Clinton stai.es in part check IIsts... Audits will be performed as follows:" Audits are perfo twelve months for all sections of the manual (1) Zack Site-Every months for all sections of the manual....;"(2) Plant-Every twelve Section 7.0 of PQCP-17, Revision 1 " Training, certification, and Evaluation ofQualit Surveys" y Assurance Auditors - Performance of Audits and Vendor / Supplier states in part 7.3 Auditors / Lead Auditors prepare a written audit plan identifying the activity and organization to be audited 7.7 Audits shall be performed by use of check lists (ZQF-86)...." + 5 .c 9
6-e i Contrary to the above. a review of the internal audits conducted at the Zack plant and the LaSalle and Clinton sites from 1979 through 1981 (noauditswereperformedin1982 werenotauditedonanannualbas)is.showed that all sectiorsof the m There was also no evidence of 10 audit plans or 3 checklists for the 17 internal audits performed. .I. Section 2 " Quality Assurance Pro ram" of the QA Manual (ZQAM-Revision 1) I for Clinton states in part "The uality Assurance Program provides the i following: (1 Indoctrination an training of personnel performing acti-vitiesaffectin)gQuality.... l i Any activities affecting quality shall i be documented." i Section 2 "QualityAssuranceProgram,"oftheQAManual(20AM-Revision 3), forLaSallestatesinpart responsible for maintainin, .. The Quality Assurance Manager shall be Quality Control personnel.g a perma'nent file on all Quality Assurance and This shall include education, background, training, experience and the results of testing and examination." I 3 i Contrary to the above, a review of the QA record files for both the LaSalle and Clinton projects indicated that there were no documented indoctrination and training records maintained for one shop welder and two.home office. auditorsassociatedwithbothprojects. J. ProcedureQCP-11 Revision 6 " Training Procedures for Personnel Performing Quality Control }nspection',' r,equires that QC inspection personnel for 3 . i i the LaSalle project meet visual and color vision standards visual requirements be verified annually by reexamination., and the In addition certification forms which will be completed for each person who performs, inspections will be retained in the project files. Procedure PQCP-11 Revision 1 of Quality Control Inspectors'I " Training, certification, and Evaluation requiresthatQCinspectionpersonnelfor theClintonprojecthavear,a,nnualexaminationforvisualacuity,and the results of these' examinations be maintained in the files. The certification is also documented on a form which is maintained in the t files. In addition, the inspectors are evaluated 30 days after certifi-cation and annually thereafter, and the evaulations are documented on a form. l ProcedurePQCP-16 Revision 1 plant fabrication, personnel re,ceive monthly train,in"On going Training Quality Control Manager and the Production Manager,g.from both thea 1 session is documented and retained in the QA. files. l 4 h 4 t 4 .%T w e t ,.T .1 [. I .J.
_ = _ f ~ i. 7 Contrary)to the above, a review of the QA files for 13 QC inspectors (L j of documentation for the following items: 1. Annual Eye Exam - 15 (Clinton) and 6 (LcSalle) inspectors; k 2. Certificatio'nForm-13(Clinton)and1(LaSalle) inspectors; l 3. PerformanceEvaluation-16(Clinton) inspectors;and p 4. On going Training - 8 (Clinter) inspectors and 4 welders. K. Paragrap"h 4. of "The Zack Company Procedure for Compliance with 10 CFR Part 21 Revision 0, dated Decembe,r 9 l employee, of The Zack Company who has re,ason t'1978, states in part, "Any o believe a deviation exists, is required to supply this information both verbally and in ~ ~ _ writing _to his-immediate supervisor... The manager or supervisor to whom the deviation is reported shall review all details concerning the deviation to determine if a defect exists. If, in his opinion the deviation is a defect, or is potentially a defect, or if he is, uncertain t whether it is a defect the manager or supervisor shall forward the written report, ject manager."which shall include the results of his evalu appropriate pro ( Contrary to the above written 10 CFR Part 21 evaluation reports had not j been prepared or submItteif to supervision with respect to identified i deviations. L. Paragraph 9.1 of Sargent & Lundy Engineers, Chicago, Illinois Standard i Specification J-2590 for HVAC Duct work (Form 320) states in p, art, "The Contractor (Zack Company) shall be responsible for the leak tightness of 4 each duct system. To assure minimum leakage, the Contractor shall seal i a11'jointsandseamswhicharenotgasketedwithand(sic) approved l! material as specified in Article 3.5 for all nonnuclear applications, and shall be in accordance with Article 3.6 for all nuclear plant systems, i except HVAC systems in the service building, which can be the same as nonnuclear applications...." Contrary to the above unapproved materials-(Hardcast FTA-20 adhesive and duct tape) were us,ed in sealing HVAC systems at LaSalle. M. Paragraph 7.7 of QCP-8, "NCR," Revision 4 dated October 2 1980, requires-1 l' Nonconformance Report (form ZQFgineer in $1ank 15, of The lac thesignatureoftheProjectEn i 11)acknowledgingcorrectiveaction taken. 1 4 4 s 3 E
Contrary to the above, three NCR's (622 776 781,LaSalle)wereinitialled i for the Project Engineer by an unidentified s,econd party, and one NCR (475, LaSalle) was unsigned. N. QA Manual. Section 10, page 3, Revision 2, dated September 4 1977 states in part ... The welders performing the work shall only welders,who have successfully demonstrated through proper testing that they have the skills necessary to do quality. welding of the specified quality level required. When seismic class welding is required only those welders and welding procedures the reguirements of A.W.S shall be used." qualified in accordanc,e with y i WPS-7 "WeldingProcedure Specification for Qualification / Certification of, Welders page 2 Revision 8, paragraph 6.3 states in part, "The specifics,of welder, qualification,l(, am, gage / thickness of steel, size and classification i. e. 1 of filler meta positions of test),ps, volts, wire-feed-speed, mel,t rategas flow ... be revised to facilitate job needs.,and g may Such revisions shall be consistent with the requirements of AWS D1.1-79 Sections 3 and 5, AWS D1.3-78 Section 6 (and) the applicable Weldir-i Procedure Specification...." AWS DI.3-78 Section 6 paragra,,.. u.8.2.9, states in part "The welding procedure used in shall be a qualified welding procedure...."qualifica, tion of a welder AWS D1.1-79 and D1.3-78, Section 5.5 and 6 respectively address essential variables which, if change, require establishing a new p,roce qualification. Such esse 1al variables include: an increase of 25 or more or a decrease of or more in the shielding gas flow rate a reduction in melting rate, welding current or wire feed speed of ; and more than 5%. i Contrary to the above inspection of records identified that a welder had i been improperly certified to make groove and fillet welds using the GMAW as evidenced by the following ungualified essential variable process,being made to the applicable welding procedure sp changes for the performance of welder qualification testing: 1. Welder No. 34 made square groove welds in 10,12, and 14 gage sheet i metal test plates in accordance with the requirements of WPS-1 i which are as follows: Gage Amperage WireFeed(IPM) MeltRate(lbs/hr) Gas Flow (CFH) 1 10 145 204 3.3 25 12 120 190 3.1 20 14 100 182 2.9 23 On August 27, 1980, the test plates failed _the required bend tests. p s. 9 1 p --g,,
l ~ .g. 4 Subsequently, requalification test lates were made which were not 3 i in accordance with WPS-1 as shown j Gage Amperage WireFeed(IPM) Melt Rate (lbs/hr) GasFlow(CFH) l 10 100 160 2.3 30 1 12 95 150 2.1 30 14 70 108 ~1.62 30 These test plates passed the bend tests on October 23, 1980, and the welder was certified as being qualified for GMAW groove welds. 2. WelderNo.34made2T-joint fillet weld test plates in accordance with WPS-1 as follows: Gage Amperage WireFeed(IPM) MeltRate(1bs/hr) Cas Flow (CFH) 22 90 105 1.73 20 One test plate failed on August 29,1980. Subsequently, requalification test plates were made which were not i .j in accordance with WPS-1 as shown by: Gage Amperage WireFeed(IPM) MeltRate(lbs/hr) GasFlow(CFH) - t 22 50 80 1.2 30 These test plates passed the bend tests on September 19 1980, and the welder was certified as being qualified for GMAW fIlletwelds. 1 e l ( b / '4 6 I y \\
ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINOIS i
- trunt IN5Fttl10N INsPtLl10N NO.
99900785/82-01 DATE(S) 8/3-6/82 & 9/10/82 DN-SITE HOURS: 85 ' CORRESPONDENCE AnDRESS: The Zack Company i l ATTN: Mrs. Christene Zack DeZutel President 1 4600 W. 12th Place { Chicago, Illinois 60650 '.I DRGANIZATIONAL CONTACT: Mrs. Christene Zack DeZutel } TELEPHONE NUMBER: (312)242-3434 PRINCIPAL PRODUCT: Heating, Ventilation,andAirConditioning(HVAC). NUCLEAR INDUSTRY ACTIVITY: Current activity consists of HVAC systems being furnished to the Commonwealth Edison Co 4 any s LaSalle Count Station Units 1 and 2 Illinois Power Co any's Clinton Power; Company'sMidlandgant, Units 1and2.ower Station, Unit ; and Con,sumers P I /h. ASSIGNED INSPECTOR: M [I6b.e b, 9//9/fA !/ 4 4.. t. tilershaw$) Reactive & Component Program Fate / i Section(R&CP i OTHERINSPECTOR(S):J.T.Conway,R& CPS R& CPS L. B. Parker, j APPROVED BY: [ Owe TA.,/n_ I. Barnes, Chief, N&CP5 Date i INSPECTION BASES AND SCOPE: A. BASES: Appendix B to 10 CFR Part 50. 4 B. SCOPE: This inspection was conducted as a result of the receipt the Nu'dTear Regulatory Commission )ofallegationspertainingtoi lesen-tation and enforcement of The Compa quali assurance program and was i performedinconjunctionwithaninvesti tion b theChicaoFieldOffice' . of the NRC Office of Investigation. Spe ific fi din pert ining to the alle ations are contained in NRC Report No. 99900785 2-02. The main (con. on next page) PLANT SITE APPLICABILITY: 4 l ( 1-373; 50-374; 50-329; 50-330; 50-461.
- i i
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ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS l REPORT INSPU.110N NO.: 99900785/82-01 RESULTS: PAGE 2 of 10 SCOPE: Cont. purposes of this inspection were to assist the investigative staTf in the evaluation of identified concerns, and to establish whether HVAC system manufacture was consistent with applicable codes, contractual, and regulatory requirements. To make this determination, the primary areas i selected for inspection were welding process control nonconformances and I QA records, ion of 10 CFR Part 21.correctiveactio document control, i procurement document control, welder qual implementat A. VIOLATIONS: 1 None B. NONCONFORMANCES: 1. Contrary to Criterion V of Appendix B to 10 CFR Part 50, dev QAManual Section 10 and AWS D1.1-79 the NRC inspector observed being permitted and changes,to essential variables being made without the procedure being requalified during gas metal arc welding ofductringsfortheMidlandPlant,inwhichthewelderwasu(GMAW) sing 0.035 inch diameter weld wire 125 amps and a gas flow rate of 30 CFH. .t' The procedure requires the use, of 0.045, inch diameter weld wire, 195 amps and gas flow. rate of 20 CFH. This was the only in-walding o,bserved by the NRC inspector during this inspection. process 2. Contrar QCP-29,y to Criterion V of Appendix B to 10 CFR Part 50 and Procedure the following conditions were identified: Electrodes -that three s(bare wire on spools) were not being protected, in a. pools of stainless steel electrodes each of a different t condition. y)e, were observed under a work bench in an uncovered 'urther two spools had been issued on December 17, 1981, and the other,on April 16, 1982. b. Traceability of these electrodes would be precluded when used at a time later than the issue date,l sheet would not coincid in that the date of issue as shown on th' weld material contro the date of actual welding on a specific Zack Company traveler. 3. Contrary to Criterion V of Appendix B to 10 CFR Part 50, QA Manual Section 6, and AWS D1.1-79 full and complete information requiring preparation,pe, size, and e,xtent of welds, weld joints, and mater location ty was not shown on shop travelers / detail drawings provided to shop personnel. The only information provided is the welding procedurespecificationnum(er,whichdoesnotdelineatetheabove information. ) 4 ') d
ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS HLPORI IN5Ftt. 410N NO.: 99900785/82-01 RES'JLTS: PAGE 3 of 10 [ 4. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and QA Manual Section 10, instructions procedures, or drawings did not' include i. appropriate qualitative a,cceptance criteria for welds. Therefore without acceptance criteria being stipulated, specific inspection, requirements were not set forth in welding procedures. 5. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and QA Manual Section 7, shop fabrication tickets were not complete in all respects, in that they did not address certain fabrication methods / operations, and their sequencing; e.g., rolling or forming and galvanizing. 6. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and QA Manual Section 8, the following conditions were identified: 4 a. The Zack Company placed purchase order (PO Number C-4199 with Central-West Machinery Company in November)1980 for 152 of Hardcast FTA-20. This material was received and accepted. Subsequently a verbal order for an additional 24 gallons was placed and re,ceived in November'1980, and as of the date of this 3 inspection, no written confirmation has been made. The Zack Company July 5placed PO number C-874 with Gri b. Steel Com any on 1979 for 3000 lbs. of 14 Type 304-$B stainless sleel an,d 600 feet of 1 x 1\\ gage ASTM A x 1/8 stainless angles, ASTM A-276 Type 304, with certifications 4 required. The received and accepted certification for the ASMT A-240 material showed the following: dated July 18 tens strength-66,000 psi phosphorus-0.38;A-240 standard requires content was not addr,essed. The ASTM 70000psitensilestrength(minimum),0.045maximumphosphorus, 0.03 maximum sulfur, and 0.10 maximum nitrogen.(NOTE: This materialwasorderedasnonsafetyinspectio;nfunctio,n.) related however it does indi-cate inadequacy of the receiving The Zack Company placed PO number C-4458 dated Jul c. 1981 with Hobart North for 30 lbs. stainless s, teel weld rod 4 Type 308. The P0 stated " Actual or Typical Chemistry, graphy), mechanicals, Charpy V notch tests." / I, .)
o OR'GANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS i REPOR1 IN5PLCi10N NO.: 99900785/82-01 RESULTS: PAGE 4 of 10 i The Certified Material Test Report (CMTR) was received and acce)ted by Zack Company, but did not address RT or Charpy V j notc1 tests. (NOTE: The material specification does not require RT or Charpy's; however, it is still a P0 requirement.) d. The Zack Company placed P0 Number C-9433, dated August 4 1976 j with Vincent Brass & Aluminum Company for 4000 lbs. of 20 gage, and 2000 lbs. of 22 gage stainless coils, Type 316, ASTM A-240, with mill certification required. The material was received with a certification, dated August 9, 1976. The 20 gage material was returned to Vincent due to dama However, the 22 gage material was accepted, although the certi ge. fication did not list a heat number and did not provide the actual chemis The chemistry stated on the certification was f. i simply a reiteration of the chemistry requirements stated in ASTM A-240. (NOTE: This material was ordered as nonsafety-related;however,thisdoesnotnegatethestatedrequirements.) ) e. The Zack Company "placed P0 Number C-739 dated September 29 1978, i with US Steel Company for 20 tons of ASiM A-527, A-525 galva,nized coils. Certificgtions were required. The material and certifications were received and accepted showing the heat numbers as J 74531 and J 74278. r The certifications did not provide physical test reports for heat J 74531. (NOTE: The ASTM material standard does not require physi' cal properties to be reported; however this material was purchased for use at the Clinton Power Station site and the Clinton specification did require physical properties to be reported.) 7. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and paragraph 9.1 of Sargent & Lundy Engineers, Chicago cation J 2590 for HVAC duct work (Form 326) Illinois, Standard Specifi-unapproved materials (HardcastFTA-20adhesiveandDTtape)were,usedinsealingHVAC systems at LaSalle. 8. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and PQCP-7, " Plant Document Control " there was no documented evidence that a voided document file was, maintained u Clinton and welding procedure WPS-1. p-to-date for the QA Manual for i i h -~. -~ [ s
'. l, ',. I ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINDIS HLPURI IN5Ftll10N NO.: 99900785/82-01 RESULTS: PAGE 5 of 10 i i 9. Contrary"to Criterion V of Appendix B to 10 CFR Part 50, Section 19, " Audits, of the QA Manuals for LaSalle and Clinton, Assurance Audi-andPQCP-17, " Training, Certification,its and Vendor / Supplier Surveys," a re and Evaluation of Quality tors - Performance of Aud f internal audits conducted from 1979 through 1981 showed all sections of the QA manuals were not audited on an annual basis,l audits and 10 audit i plans and 3 checklists were missing for the 17 interna performed. 10. Contrary to Criterion V of A "QualityAssuranceProgram,"ppendixBto10CFRPart50andSection2, of the QA Manuals for LaSalle and Clinton, a review of the QA' records files for both the LaSalle and Clinton projectsindicatedthattherewerenodocumentedindoctrinationand training records maintained for one shop welder and two auditors. 11. Contrary to Criterion V of Appendix B to 10 CFR Part 50; QCP-11, "Trainin Procedures for Personnel performing Quality control Inspec-tion;" P CP-11, " Training, Certification, and Evaluatiorr of Quality Control nspectors QA files for 13 QC;" inspectors (LaSalle), 21 QC inspe,ctors (Cli ,( and 4 welders revealed a lack of documentation for the following items: Annu::1 rye exam - 14 (Clinton) and 6 (LaSalle) inspectors; a. b. CertificationForm-13(Clinton)and1(LaSalle) inspectors; PerformanceEvaluation-16(Clinton) inspectors;and c. d. On go'ing-Training - 8 (Clinton) inspectors and 4 welders. 12. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and paragra)h 4.1 of "The Zack Com)any Procedure for Complia,nce with 10 CFR ) art 21," written 10 CFt Part 21 evaluation reports had not been prepared or submitted to supervision with respect to identified deviations. 13. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and paragraph 7.7 of QCP-8, three NCR's (LaSalle) were initia11ed for the Project Engineer by an unidentified second party and one NCR (LaSalle) was unsigned. 14. Contrary to Criterion V of Appendix B to 10 CFR Part 50, QA Manual Section 10, American Welding Society (AWS) Standards D1.3-1978 D1.1-1979, andWeldingProc,edureSpecificationsWPS-7andWPS-1, l h .{. y
e, 1 e ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLINDIS l REPORT INSPEC110N NO.: 99900785/82-01 RESULTS: PAGE 6 of 10 i inspection of records identified that a welder had been improperly certified to make groove and fillet welds using the GMAW' process iy j-as evidenced by the following un ualified essential variable chan es l being made to the applicable wel ing procedure specification (WPS 1) i for performance of welder qualification testing: WelderNo.34madesquaregrooveweldsin10,irem,entsofhagesheet a. 12 and 14 metal test plates in accordance with the requ PS-1 f which are as follows: i Wire Feed Melt Rate Gas Flow Gage Amperage (IPM) (1bs/hr) (CFH) r 10 145 - 204 - --- - 3. 3 25 i 12 120 190 3.1 20 14 100 182 2.9 23 l On August 27, 1980, the test plates failed the required bend tests. Subsequently, requalification test plates were made which were not (. in accordance wi,h WPS-1 as shown by: Wire Feed Melt Rate Gas Flow Gage Amperage (IPM) (1bs/hr) (CFH) t 10 100 160 2.3 30 12 95 150 2.1 30 14
- 70 108 1.62
.30 These test plates passed the bend tests on October 23, 1980, and the welder was certified as being qualified for GMAW groove welds. Welder No. 34 made 2 T-with WPS-1 as follows:' joint fillet weld test plates in accordance Wire Feed Melt Rate Gas Flow Gage Amperage (IPM) (1b/hr) (CFH) 22 90 105 1.73 20 I One test plate failed on August 29 1980. Subsequently, requali-fication test plates were made which were not in accordance with WPS-1 as shown by: ( + J y
~ ORGANIZATION: THE ZACK COMPANY CHICAGO, ILLIN0IS HEPORl INSPiul0N NO.: 99900785/82-01 RESULTS: PAGE 7 of 10 i Wire Feed Melt Rate Gas Flow l Gage Amperage (IPM) (1bs/hr) (CFH) i 22 SO 105 1.73 20 The test plates passed the bend tests on September 19,ilie 1980,and the welder was certified as being qualified for GMAW f welds. C. UNRESOLVED ITEMS: ' None D. OTHER FINDINGS OR COMMENTS: 1. Areas Inspected. Welding process control - The NRC inspector reviewed the welding a. material control system including the issuance, documentation (weldmateAaltestreports retrieval and storage of welding materials. 'The applicable w)e,lding proce, dure specifications 1 procedure qualification records, and shop drawings / travelers were j reviewed. In process gas utal arc weiding was observed being performed on duct rings being supplied to the Midland Plant. As a result of this observation and review nonconformances B.1 B.2 B.3 and B.4 were identified. Addltionally, nonconforma,nce 8.5,wasIdentified of the inspection., although not a specific part of this area b. Procure n nt Document Control - A tdtal of 94 recurement document f1les w(re reviewed. lhese files consisted o Zack Company purchase orders and supplements,f conformance, applicable c shipping documentation material test reports, certificates o receiving inspection reports,f this review, nonconformanc and copies of nonconformance re) orts (ifrequired). As a result o t was identified. Further, review of Sargent & Lundy Engineers StandardSpecificationNo.J2590 ands &L'sapprovedmaterial(S&L) list resulted in nonconformance B.7 being identified, However on January 14, 1982,in nonconformance B.7 for use at LaSalle.T the uterials shown As of the date, of this inspection, S&L had not responded to The Zack Company request. The NPC inspector expressed concern over the apparent failure of the receising inspectign function to detect the discrepancies / anomalies between the purchase order requirements and the material certifications. P, ..? A
, l ' ORGANIZATION: THE ZACK COMPANY CHICAGO ILLINDIS REPORI IN5PEL110N i NO.: 99900785/82-01 RESULTS: PAGE 8 of 10 l c. Document Control - A review of the master file for the QA manuals and quality control and welding procedures as well as the file onvoldeddocumentsfortheClintonandLa$alleprojects,resulted i in the identification of nonconformance B.8. d. Audits - A review of re orts for 17 internal audits conducted at I the lack laSalle, and' linton sites from 1979 through 1981 and a review of 10 vendor / supplier audit reports conducted from October 1981 through May 1982 resulted in the identification of nonconformance B.9. QA Records - A review of the'QA record file for 13 QC inspectors e. at LaSalle, 21 QC inspectors at Clinton,formances $.and 5 auditors 4 welders resulted in the identification of noncon 10 and 8.11. A detailed evaluation of the QA program for both the LaSalle and Clinton projects, to determine if activities were bein t implemented consistent with quality commitments contained in both 'A manuals, and discussions with Zack personnel resulted n the following additional comments: lk. The QA manuals and applicable procedures for both the LaSalle andClintonprojectsappeartorequireupdatingtosatisfythe requirements of Appendix B to 10 CFR Part 50. Exampics of observed discrepancies are as follows: (1) The organization chart does not identify all the onsite and offaite grou QAprogram,pswhichfunctionunderthecognizanceofthe andtheQAresponsibilitiesofeachgroupare not described; (2) The organizational positions with stop work authority and ) the individual responsible for directing and managing the siteQAprogramarenotidentified; (3) Numerous instances where indoctrination, training, and qualification sesstoris have not been doct.iented; 1 (4) Qualifications and certifications of inspectors and auditors are not being kept current; (5) The basis for selection of suppliers is not being docuranted and filed; e y ~
8s~~ s x ,~ ORGANIZATION: THE ZACK COMPANY ' CHICAGO,ILLINDIS l( REPORT INbPttl10N PAGE<9 of 10 NO.: 99900785/82-01 RESULTS: -l (6) There was no documentation to indicate that supplier's certi- , ficates of conformance are periodically evaluated'by audits, ( l independent inspections, or tests to assure they are valid; s (7) There were no requirements for in process inspection of' work by individuals other than those who performed or ,-c. 7 directly supervised the activity; 1 4,, (8) Qualificationrecordsofprocedures,equipmentandpersonnel y associated with special processes:(e.g., welding) had not. < been fully established.. filed, and kept current; and j. ~ (9) 'There was no' requirement for management (above or outside. i the QA organization) to regularly assess the scope, status, ~ ~ and compliance of the QA program to 10 CFR Part 50, s . Appendix B. w a l 'f. Implementation of 10 CFR Part 21 - The NRC inspectorieviewed the s vendor's procedure "Ihe zack comp.any's Procedure for Co:npliance with 10 C R Part 21," Revision 0, dated December 19,ble to meet 1978, to ( verify that adequate documented measures were availa the reporting reouirements of 10 CFR Part 21. Two reports were examined for completeness and adherence to notification require-1 ments. These reports were: (1)a10CFRPart21reporttoNRC Region III on June 9,1982,.concerning fire dampers; and (2) a s , potential?10 CFR Part 21 report to NRC Region III on Aagust 2,1982, concerning weld records. These reports met the notification g ,
- C,.
reguire~ments of the vendor's procedure however, the required writteh evaluations had not been. pre ~ par;ed. (See Nonconformance 42 s 8.12.) Observations of the employee's bulletin board verified that the above vendor's procedure and Section 206 of the Energy Reorganiza-t tion Act of 1974 were properly posted. g. Nonconformances and Corrective Action - The NRC inspector reviewed j the following vendor's arccedure and two quality assurance manual sectionstodeterminet1eQA/QCrequirementsforthesubjectarea5 at the LaSalle site: Quality Control Procedure B, Revision 4, z, ~ 3 ^ y. 7 e k s. .g. ' c p c &.~ ~ e ', J y. m w g N L ,1 T q ra, s -..... x
- - a.
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o. ORGhNIZATION: THE ZACK COMPANY CHICAGO, ILLINDIS REPORl 1N5PEC110N NO.: 99900785/82-01 RESULTS: PAGE 10 of 10 i ) I dated October 2, 1980 "NCR"; Section 16 of the Manual (QAM), Revision, 2, dated April 1,1981, " Quality Assurance
- Nonconforming Material,2, dated September 1$, and Section 17 of the QAM1977,
. Parts or Components " Revision books of conpleted NCR's (300) were reviewed in the process of I. determining specific NCR's to be examined. Thirty-five specific j NCR's and 20 Corrective Action Reports were examined for complete-ness and compliance with the above requirements. Management review l 3 of NCR corrective action was lacking on four of the NCR's examined. (seeNonconformanceB.13). h. Welder Qualifications - The NRC inspector reviewed the qualification records of the four currently employed shop welders (nuclear) to verify that they had been qualified in accordance with the require-mentsofAmericanWeldingSociety(AWS) Standard, identified. D1.3-1978. As a result of this review, Nonconformance B.14 was l I l 9 ( i f l-4 .i-l I 1 1 f
,c-g n ue ![a UNITED STATES NUCLEAR REGULATORY COMMISSION k-flEGION 111 790 ROOSEVELT ROAO o,%' GLEN ELLYN,lLLlNOls to137 $4 4y FJAN 121981 l 4 x4: y.a,/.s;c - j Docket No. 50-329 Docket No. 50-330 O Op'I Consumers Power Company ATTN: hr. James W. Cook 6 gl Vice President Midland Project k 1945 West Parnall Road l Jackson, MI 49201 Gentlemen: This refers to the investigation conducted by Messrs. C. H. Weil, R. J. Cook, C. E. Jones, E. W. Lee, and H. H. Livermore of this office during the period March 6-July 31, 1980, regarding Consumers Power Company's Quality Assurance Program, as related to the heating, ventilation and air conditioning contrac-tor's activities at Midland Nuclear Power Plant, Units 1 and 2. The report setting forth the results of the investigation, is enclosed. In accordance with Section 2.790 of the NRC's " Rules'of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed investigation report will be placed in the NRC's Public Document Room, except as follows. If this report contains information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty-five days of the date of this letter, to withhold such information from public disclosure. The application must include a full statement of the reasons for which the information is considered proprietary, ar.4 should I be prepared so that proprietary information identified in the applic.* N is contained in an enclosure to the application. d A separate letter setting forth certain matters of concern and the items of noncompliance found during this investigation has been sent from the Office } of Inspection and Enforcement. Your response to those items should be made l directly to that office. j d;ig, h. 3 g ~ t o .3 g ~ 3 7 -. i .m g-- .-y er 49 -'Of
r. I t- /* I UAN 'f'2 'toAf l Consumers Power Company ! i We will gladly discuss any questions you have concerning this investigation. Sincerely, i )
- hm.)3lTh'ler ML 1
/ James G. Kepp Director l
Enclosure:
IE Investigation Repo~ts No. 50-329/80-10 r l and No. 50-330/80-11 i j cc w/ encl: Central Files i Reproduction Unit NRC 20b j PDR 4 Local PDR NSIC TIC Ronald Callen, Michigan Public Service Commission Myron M. Cherry W q.* 4 we 1 3 . D. i '? It! ~ ~ '
s m 3 r U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT i REGION III i Reports No. 50-329/80-10; 50-330/80-11 + { Docket Nos. 50-329; 50-330 Licenses No. CPPR-81; CPPR-82 Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant, Units I and 2 Investigation Conducted: March 6 - July 31, 1980 .l Investigation At: Midland Site. Midland. MI Investigator: / / C. H. Weil Date ~ Investigative Specialist Inspectors: (( eA I f / m R. J. Cook M Date i Resi, dent Inspector, Midland i O O-o w c.? / 47 -[(/ C. E. Jones Date Reactor Inspector IfG// A E. W. K. Lee Date / / ,/ Reactor Inspector $m I/ $l H. H. Livermore 1 {/ Datel Reactor Inspector Other Accompanying Personnel: 'D. W. Hayes (March 17-19, %d0h G. A. Phillip. (March 17-19, I';80) L Reviewed By: N. /[9/8/ 1 C. E. Norelius Date ?: Assistant to the Director .f / x 4eW' ..,..q
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\\ '~ s m i kC I Reviewed By: / m, R. C. Kno'p 4 Date Chief, Construction Projects i Section No. 1 I. 1 Investination Summary: i Investination on March 6 - July 31, 1980 (Report No. 50-329/80-10; i l 50-330/80-11) ] Areas Investigated: Special, unannounced investigation concerning allegations pertaining to the Zack Company (the heating, ventilating and air conditioning) (KVAC) subcontractor at the Midland Nuclear Power Plant construction site. Allegations concerned material traceability, falsifi-cation of records, procedures, and training of quality control inspectors. The investigation consisted of interviews, observations, and the review of records and other documents. This investigation involved 540 investigative j hours, both on and offsite, by seven NRC individuals. Results: Investigation was made into twenty-one allegations (dealing with l material traceability, violation of procedures, falsification of records, and the training of quality control inspectors) regarding the Zack Company work at the Midland construction site. Twelve of the twenty-one allegations were substantiated, and resulted in noncompliance with Title 10, Code of Federal Regulations, Part 50 (10 CFR 50), Appendix B, Criterie IV (Procurement Document Control), V (Construction, Procedures,-and Drawings), VII (Control of Purchased Material, Equipment, and Services), VIII (Iden-tification and Control of Materials, Parts, and Components), IX (Control of Special Processes), X (Inspection), XV (Nonconforming Materials, Parts, or Components), XVI (Corrective Action), XVII (Quality Assurance Records), and XVIII (Audits). The remaining nine allegations were not substantiated. i l l' i I a i p \\ $' -L\\- s a.; .c. [ \\ w +e er e w w 3 y 4.- w e e,w - e w-e e. w ed--r.
~__ l _y 1 m 9 t i i REASON FOR INVESTIGATION On March 6 and 10,1980, Individual 'A' provided seventeen allegations per-taining to the Zack Company (the MVAC subcontractor) at the Midland Nuclear Power Plant construction site, to Nuclear Regulatory Commission Region III t i (RIII) personnel. These allegations dealt with material traceability, g violations of procedures, falsification of documents, and the training of quality control inspectors. Subsequently, Individual 'A' provided two additional allegations. On March 10 and 12, 1980, Individual 'B' provided .l essentially the same information as Individual 'A', concerning the Zack j Company work at the Midland Nuclear Power Plant construction site. On April 14, 1980, Individual 'A' provided one additjonal allegation per-l taining to the Zack Company. On April 18, 1980, Individual 'C' advised RIII personnel of problems encountered with the traceability of materials i used by the Zack Company at the Midland site. On April 25, 1980, another i alleger, Individual 'D', made one additional allegation. Str2fARY OF FACTS As the result of allegations received concerning the activities of the Zack Company, HVAC subcontractor, at the Midland site, an investigation was initiated. During the initial phases of the investigation, Region III became aware that Consumers Power Company had issued a Management Corrective Action Request (MCAR), dated January 8, 1980, pertaining to the Zack Company. The MCAR showed Zack had failed to initiate corrective action on a large number of nonconformance reports and audit findings in a timely manner and had failed to address other requirements and commitments of the quality program. The MCAR, among cther things, indicated there were 284 open Zack field nonconformance reports, of which 277 required either rework or the implementation of an adequate procedure to complete hardware installation. ) In examining the circumstances surrounding the issuance of the NCAR it was determined that during the period May 23 to October 2, 1979, Consumers Power i i Company had issued seven nonconformance reports, all of which recommended 100% reinspection of work as a corrective action.,0n October 9,1979, a meeting was held between Bechtel Power Corporation and Consumers Power Company "to discuss certain immediate concerns regarding the Zack Company -) (HVAC subcontractor) Quality Assurance Program." The meeting notes indicated that Consumers Power Company had noted "a lack of responsiveness" by Zack. Commitments regarding corrective action made by Zack to Consumers through Bechtel, indicated "a report on problems, causes and recommendations to be part of a forthcoming formal action plan" to be prepared by November 12, 1979, were not met prior to the date of the MCAR. l The investigation determined, that as of March 19, 1980, corrective action had not been completed on any of the above-mentioned seven Consumers Power Company nonconformance reports. The preliminary findings of the investigation were discussed with Consumers Power Company site management on March 19, 1980, and with Consumers Power corporate management, by tele-phone, on March 20, 1980. During the latter conversation an understanding was reached that a stop work order would be issued to theEd hany. 'This understanding was confirmed by a letter,~ dated. reh 21, 1980 %,om p Region III to Consumers Power Company. gg w /. r . I
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g .g 'e \\ q , m. During this investigation twelve of twenty-one allegations were substantiated. Ten items of noncompliance with 10 CFR 50, Appendix B, Criteria, were iden-t tified regarding the activities of the Zack Company. Numerous examples of i a failure to maintain material control and traceability as well as procedural j violations were identified. In addition, one item of noncompliance, relating j to 10 CFR Part 50, Appendix B, Criterion XVI, failure by Consumers Power Company to promptly correct failures, deficiencies, deviations, defective j materials and equipment and nonconformance regarding the HVAC work, was identified, i e-- ? 9 e I 4-f k .a .A ,f_
\\ m ~ t DETAILS i i 1. Personnel Contacted . i Consumers Power Company, 6 s
- S. H. Howell, Senior Vice President
- J. Cook, Vice President - Midland
- W. Bird, Midland Quality Assurance Manager
- J. Wood, Quality Assurance Group
- H. W. Slager, Mate' rials Section Head-Design Production J. L. Corley, Chief, Quality Assurance - Midland
- D. R. Keating,- Quality Assurance Group Supervisor - Midland M. F. DeWitt, Quality Assurance Group - Midland T. C. Coote, Project Superintendent - Midland B. H. Peck, Construction Supervisor - Midland J. S. Strahl, Construction Control Supervisor - Midland J. S. Kreple, Engineer: PHO - Midland Bechtel Power Corporation
- J. A. Rutgers, Project Manager
- J. R. Barbee, Supervisor Codes and Standards
- M. Elgaaly, Project Engineering
- L. A. Dreisbach, PQAE E. Smith, LQAE L. Davis, Site Manager T. C. Valenzano, Project Superintendent of Services J. W. Lillywhite, Field Contract Administrator W. L. Braclay, PFQCE M. A. Dietrich, QAE P. Falkenborg, QAE i
E. F. Price, S/C I Zack Company
- C. L. Eichstaedt, Vice President / Operations Manager J. DeZutel, Vice President
- M. E. D'Haen, Quality Control Manager, Midland R. Akers, Quality Control Inspector L. R. Chapman, Quality Control Inspector D. C. Dartey, Quality Control Inspector J. K. Dittenbir, Quality Control Inspector R. L. Ewald, Quality Control Inspector T. B. Franchuk, Quality Control Inspector R. E. Milne, Quality Control Inspector D. R. Sanders, Quality Control Inspector R. McCarley, Project Manager - Midland L. J. Rytlewski, Superintendent - Midland R. F. LaRoche, General Foreman a
j .} R. G. Brown, Fabrication Shop Foreman I .} l ql 1 s' - )
- 7 C [
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+ i i q q Individuals 4 Individual 'A' i Individual 'B' ~ I Individual 'C' Individual 'D' P
- Denotes presence at Management meeting, May 2, 1980.
b 2. Introduction 9 i The Midland Nuclear Fover Plant, Units 1 and 2, are under construc-tion by Consumers Power Company at Midland, Michigan. Bechtel Power Corporation is the architect-engineering firm, as-well as the i l constructor of the plant. The facility will utilize a Pressurized Water Reactor (PWR) supplied by the Babcock and Wilcox Company. The Zack Company has been designated to provide and install the heating, ventilating and air conditioning (HVAC) systems for the Midland plant. i These systems serve both safety-related and non-safety-related areas of l the plant. 4 10 CFR Part 50, Appendix B sets forth eighteen Quality Assurance Criteria applicable to nuclear power plant construction activities. Consumers Power Company and its contractor organizations, among them Bechtel Power Corporation and Zack Company, have prepared Quality Assurance / Quality Control manuals and procedures setting forth the specific requirements applicable to their activities at the Midland site. These documents also specify that certain activities will meet specific industry codes and standards. The following documents are applicable to the HVAC activities which were examined during this investigation and were used as a basis for determining compliance or noncompliance with NRC requirements: Consumers Power Company QA Program Policy Nos. 4, 5, 7, 8, 9, 10, 15, 16, 17, and 18. Bechtel Specification for Heating, Ventilating and Air Conditioning Seismic Class I equipment and Ductwork Installation for the Consumers Power Company Midland Plant, Units 1 and 2 - Specification Guide No. 7220-N-151 A(Q). Zack Company Quality Assurance Manual. Zack Company Procedures Nos. MB-QCP-1, 3, 6, 7, 8, 20, and 21. ASME Material Specification Designations A36, A527-1 and A575. i ASME Section II. American Welding Society, AWS D1.1.1977. l l f l. h ( , y ; ;- - - ym. . :.e c a
l q l i (Specific instances of noncompliance are identified in this report by l l j a reference in parenthesis to the appropriate Appendix B criterion. The applicable procedure or standard is not in all instances identified). 3. Receipt of A11enations On March 6, 1980, Individual 'A' contacted RIII personnel. Indivi-dual 'A' stated he was quite concerned with the quality control (QC) i } program of the Zack Company, the HVAC subcontractor, at the Midland Nuclear Power Station construction site. Individual 'A' advised he was concerned with th'e Zack QC section's activities in terms of material traceability, procedural violations, the training of the QC inspectors, and the falsification of records. Individual 'A' provided a written statement (Exhibit I) in which he set forth his specific concerns. l Subsequently, Individual 'B' provided essentially the same information as Individual 'A' to RIII personnel. In addition to his written statement, Individual 'A' provided infor-nation concerning the lack of independence of an audit of the Zack, Midland, QC function by the Zack Company, as well as providing three additional allegations, as follows: I f { a. Parts fabricated at the Midland fabrication shop were made from j the verbal description and instructions of the fabrication shop foreman. Blueprints or written instructions were not used to fabricate the duct parts; b. Duct parts fabricated at the Midland fabrication shop were not traceable. The work was not documented, and when it was docu-mented, travelers had not been annotated with either the correct coil or angle numbers (if the coil or angle number was noted at all). Traveler number F942/940 was marked to show angle. iron control number 71, 697, and 662-3 had been used, when the correct number should be 887. Traveler ticket number 944/942 was marked to show angle control numbers 41, 697, and 662-3 had been used, when the correct number should be 887 (on the 2 inch by 2 inch by 1/4 inch ang".e iron) and 944 (on the 3 1/2 inch by 3 1/2 inch by 1/4 inch angle iron). Both traveler numbers, F942/940 and _( F944/942 were marked as quality control inspected on August 24, 1978; Two welders were using the same identification stamp, CU7. c. 4. Review of Manasement Corrective Action Report During the preliminary stages of the investigation, the existence of a Consumers Power Company Management Corrective Action Report;(MCAR) dealing with the performance of the Zack Company et the Midland Nuclear Power Plant construction site became known to RIII. MCAR number MD-1 was issued by Consumers Power Company on January 8, 1980. 'The MCAR I ' } ..,p..- & s ..w.
) i showed the Zack Corporation had failed to initiate corrective action i on a large number of Nonconformance Reports (NCRs) and audit findings i in a timely manner and to address other requirements and commitments of the Quality Assurance (QA) Program. The MCAR also indicated there were 284, open, Zack field NCRs of which 277 required either rework or the iisplementation of adequate procedures to complete hardware instal-lation. These were in addition to the NCRs generated by Consumers Power. g I During the period May 23 - October 2, 1979, Consumers Power Company i , issued seven NCRs, all of which indicated 1007, reinspection of Zack's work as the rec-ndad carrective actionf-- vu uctober 5, 1979, a meeting was held between Bechtel Power c6rporation and Consumers Power i Company, "to discuss certain immediate concerns regarding the Zack i Company (HVAC subcontractor) Quality Assurance Program." According to the meeting notes, Consumers Power Company noted "a lack of responsiveness" by Zack Company, and inquired as to the steps being taken to correct the nonconformances and to reverse quality deviation I trends. Bechtel Power advised the Zack Company had been informed that t - "no future fee payments will be made until these items are answered and Zack's timeliness improves." Bechtel also stated, the Zack QA manager had written that all outstanding findings and QC FM's will be answered by October 12, 1979. Fee payments to Zack were' resumed in February 1980. None of the seven Consumers' NCRs referred to above had been closed out as of March 19, 1980. During the October 8,1979 meeting, Bechtel Power also indicated the 4 1 president of the Zack Company had outlined a thirteen point, tentative action plan to improve the Zack QA program. i Consumers Power Company also requested "Bechtel QA to expedite Bechtel. Engineering for answers to questions on Zack welding procedures." On October 9, 1979, the Zack president prepared a memorandum, which was sent to Bechtel the same date, stating an individual was assigned "to implement a system for controlling NCRs at Midland, with priority given to old NCRs." c; In a memorandum, dated November 28, 1979, a copy of which was furnished to Consumers Power Corporate QA, the Consumers site QA stated that. during discussions with Bechtel Subcontracts on November 19, 1979, it was indicated the Zack Company had been granted an extension to L November 22 for submittal of the final report relative to corrective Ii actions. The memorandum also stated, "Zack has been requested to show l' cause by December 15, 1979 as to why they should be allowed to continue construction based on: (a) Their ability to manage the quality program, p and (b) their ability to satisfactorily implement the contract." The notes of a meeting held on December 13, 1979' indicated the indi-vidual, who was assigned by the Zack president to control NCRs, stated he did not have a clear cut procedure for closing NCRs. The notes 3 er .g. 9 i [ - ~,
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- 4.,
l n n ) i also indicated that the, then, Zack site QC manager said he was not l prepared at that time to discuss in process inspections, but that these inspections were limited due to lack of manpower. He said he had one fully qualified inspector on the day shift and one on the i night shift. I At about the end of December or the beginning of January, Zack assigned ~ s a new QC manager to the Midland site and increased the number of QC inspectors. By letter dated January 30, 1980, Bechtel Power Company responded to 4 MCAR number hD-1 and provided Zack's response, dated January 16, 1980. 11owing information was obtained regarding the current status of s f the specific items in MCAR number MD-1: l a. NCR M-01-4-0-057,- dated May 23, 1979 i The recommended corrective action was 100% reinsoeetion of Zack m welds due to first inspection misses on hangers and supportE . I ~Consumers Power advisea sney naa iaentifica unacceptaole welds l which had been previously accepted by Zack. Several vertical j welds and all overhead welds were unacceptable. It was estimated 30% of the welds inspected were unacceptable. .i Bechtel personnel advised there were 39 deficiencies identified, which were related to Consumers' NCRs and that a progress report from Zack, dated March 17, 1980, showed all but five of these had been resolved. However, Zack personnel advised the 100% reinspec-tion of welds made prior to May 23, 1979, the date of the Consumer NCR, would entail thousands of welds and only an estimated 1% had r been reinspected. t b. NCR M-01-4-9-074 dated July 24, 1979 The recommended corrective action was 100% reinspection of all dron-in tvoe anchor Doir.s. wasumers Yower Company advised the / ~use of this type of bolt was discontinued in July 1979, and that corrective action was deferred pending a prescribed fix by Bechtel Engineering. Bechtel Subcontracts stated they did not know when j this would be forthcoming..Zack personnel stated they were in i the process of locating these bolts by means of a walkdown. They indicated they were two-thirds of the way through the Auxiliary Building and planned to complete the task of identifying those installed by the end of May 1980. i c. NCRs M-01-4-9-104 dated September 27, 1979 and M-01-4-9-106 dated Octob&r 2, 1979 The recommended corrective action called for 100% reinspection of HVAC air hmadI4a= mani = =t tn wenzy swyn anstallation requirements. 3 9-1 5a - ~.. f. a. .~u, n. -.$w .e r- +,, w. .-,-v s n ~--- -= 6 ~
u. 3 3 Re: 104; Zack personnel advised about 22 of 120 items had been reinspected and they hoped to closeout this item by the end of May j 1980. No problems had been found so far during the reinspection. i i Re: 106; Zack advised this item was closed out by issuing some new Zack NCRs which were still open. l d. NCRs'M-01-4-9-083 dated August 14, 1979; M-01-4-9-086 dated j August 21, 1979; M-01-4-9s087 dated August 22, 1979 I l I The recommended corrective action m m 100Y reinspection / rework l -of all welding performed without required preheat. t l Zack personnel advised that not all of the welds involved had I been identified. They estimated 90-100 hangers, having two to I six welds each, were involved. They said that about one month prior to this investigation a letter had been sent to Bechtel describing the action proposed to correct the problem. Bechtel I personnel stated they did not know when a response would be given
- s 2;d.
'~ None of the above-listed Consumers Power Company NCRs, generated during the period May 23 - October 2,1979, had been closed out as of March 19, 3 j ,1980 (Criterion XVI). - L I a The status of the MCAR was discussed with Consumers Power Company site management on March 19, 1980 and by telephone with Corporate management on March 20, 1980. An understanding reached during the latter conver-sations was confirmed by letter dated March 21, 1980, from Region III to Consumers Power Company, a copy of which is attached to this report ,'j as Exhibit II. On March 20, 1980, Bechtel Power Corporation issued a l stop work order to the Zack Company, i 5. Alleantions Based on interviews with Individuals 'A' and !B' on March 6, 10 and 12, 1980, nineteen allegations were received. These allegations, and {theinformationobtainedregardingthemduringtheinvestigation,are set forth below. Allenation No. 1 - Travelers (the documents accompanying the Zack / products) indicating the materials and procedures are pre-signed as 2g ri being accepted by the QC section at the Midland job site. The items i are fabricated at the Midland job site, but the pre-signed traveler I indicates the asterials were fabricated by the Zack Company in Chicago. l The primary way of determining where an item was fabricated was by paint. The items fabricated at the Midland job site are not painted, as the Midland job site does not have the facilities to paint. All i l-items fabricated at the Chicago shop are painted, as the Chicago shop [' ' does have the facilities to apply paint. (The items fabricated by Zack were required to have a traveler showing the materials and pro-cedures applicable to the item. Travelers were pre-signed to show acceptance by the QC section at the Midland site). 1 1 { h 2 ~. ~. .,-_.._a. 5 . 1;, 3e 'l e p
o emp A / ~ Items have been fabricated at the Zack Company shop in Chicago and have been sent to the Midland job site with the necessary travelers. Once at the Midland job site, the fabricated items have been scrapped, for one reason or another, and replacements have been fabricated at 4 the Midland job site. The travelers from the Chicago shop were not annotated to show the item from Chicago had been scrapped. The replacements made at the Midland job site were made using the Chicago travelers, and new travelers were not made for the replacement item fabricated at the Midland job site. Finding - It was noted a number of travelers had been initialed by QC l inspectors on the left hand side of the proper sign-off space on the traveler. The various QC inspectors interviewed stated the initials on the left side of the traveler indicated the QC inspector had verified that the sketch on the traveler was correct, and the initials did not mean the iten had been either completed or accepted by the QC inspector. l It was also established that field fabricated and/or repaired items l were painted by seens of aerosol spray in the field fabrication shop after itews had been inspected and accepted by the QC inspectors. Paint, or the lack of it, did not provide a basis for determining whether an ites was fabricated in Chicago or at the Midland site. Allegation No. 2 - Travelers were being " signed off" as Quality j Assurance received at the Midland job site, yet the items described i by the travelers were not completed. Examples of this practice were: i (1) Traveler number V03-42B-F10171, flanges and vanes were not~ installed. (2) Traveler number V03-SH2-F9437, vanes not installed and one end of the duct was still raw material and not finished. (3) Traveler number V26-SH2B-46.1-P1515, welds were loose, not gas 1 tight as required. 6 (4) Traveler number V04-SH2-277A-F10676, vanes were neither welded nor screwed-in as required. (5) Traveler V10-428-10171, vanes were neither welded nor screwed-in as required. l (6) Traveler number V10-42B.1-F10172, flanges were not installed. 1 (7) Traveler number V26SH2B-47.1-1516, joints were loose and not gas tight. (8) Traveler number V3SR2-2C-F10397 was in the process of being installed at the 599' elevation in the auxiliary building, when it was discovered to have defective vanes (undersized), defective welds on flange to duct joint, and improper veld spacing on the vane rail. However, the piece was noted to have been inspected I completely. g 1 Y S b 9 } y ,, + -
R ',1 (9) Traveler number V2-SH1-1-2A-F8403 was signed as being received from Chicago, yet was found being fabricated on site using the same traveler. t Finding - The following information was obtained concerning the above-j listed travelers. i f ' - (1) Travelar =" '-- "^? '22 !!";7;. 22:5 ; r-----I stated a traveler I r- / Tid not exist with this number, i f $P # _ ]y(2) Traveler number V03-SH2-2-F9437. Zack personnel advised the l original item was fabricated to meet the Seismic Class 2 requirements instead of Class 1. The item was subsequently scrapped. l A replacement piece, partially completed, was found in the field J l fabrication shop. It was established that: i (a) A Nonconformance Report (NCR) had not been prepared when the ~ ~~~ ~~~~ original ites was found to be nonconforming (Criterion XV). (b) A new traveler was not initiated for the replacement piece (Criterion V). (c) Turning vanes used in the replacement piece were not traceable (Criterion VIII). (3) Traveler number V26-SH2B-46.1-P1515. Zack personnel stated the loose flange was to facilitate field installation and the piece 3 I was to be field tested for gas tightness after installation in Ije E 7 J accordance with Bechtel Specification 7220-M-151A(Q), Revision 7. 4 However, it was established that: t j (a) The welder identification was not recorded on the traveler (Criterion V). .(b) The coil control number was recorded on the traveler as 383, but the control number was not visible on the item (Criterion VIII). (c) Two control numbers, 929 and 727-2, were marked on the angle iron used on the ites, but control number 727-2 was not 3 recorded on the traveler (Criterion VIII). 4 (d) The traveler indicated Welding Procedure Number QCP-22 was to be used. This procedure is a shielded metal arc welding process. However, the weld appeared to have been welded with a gas metal arc welding process (Criterion II). (e) The traveler number was not placed on all of the sub-l components (Criterion VIII). l l l i ~ '4) f s rs<, m --e-w
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q (4) Traveler number V04-SH2-277A-F10676. This item was determined to be a non-safety-related ites. I (5) Traveler number V10-42B-10171. Vanes were welded in the duct. I However, it was established that: l (a) Turning vanes used in the duct were not traceable l (Criterion VIII). (b) The welder identification was not recorded on traveler i (Criterion V). (c) The traveler indicated Welding Procedure Number QCP-22 was to be used. This procedure is a shielded metal arc welding process, but the weld appeared to have been welded with a gas metal arc welding process (Criterion IX). (6) Traveler number V10-42B.1-F10172. Flanges were installed. However, it was established _that: (a) Turning vanes used in the duct were not traceable (Criterion VIII). (b) The welder identiffcation was not recorded on the traveler (Criterion V). (c) The traveler indicated Welding Procedure Number QCP-22 was to be used. This procedure is a shielded metal arc welding process, but the weld appeared to have been welded with a gas metal are welding process (Criterion IX). (7) Traveler number V26-SH2B-47.1-P1516. Zack personnel advised that the loose flange was to facilitate field installation. Also, the piece would be field tested for gas tightness after installation l in accordance with Specification 7220-M-151A(Q), Revision 7. However, it was established that: (a) The welder identification was not recorded on the traveler (Criterion V). (b) The coil control number was recorded on the traveler as 383, but the control number was not visible on the item. Also the traveler number was not shown on all sub-components (Criterion VIII). (c) The traveler indicated Welding Procedure Number QCP-22 was to be,used. This procedure is a shielded metal are welding process, but the weld appeared to have been welded with a gas metal arc welding process (Criterion IX). 1 (d) Certain flange-to-duct welds had undercut exceeding the 1/32" I allowed by the Bechtel specification (Criterion X). l l 5 [. 5 l J . =
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.q ) i -l (8) Traveler number V3-SH2-2C-F10397. This item was scrapped. A new ites was being fabricated in the field fabrication shop under a ? } new traveler number V3-SH2-2D-F12685. It was established that: 1. (a) The traveler indicated Welding Procedure Number QCP-22 or QCP-34 was to be used. The procedures are shielded metal [ are welding process, but the welds appeared to have been [ -l welded with a gas metal arc welding process (Criterion IX). .l (b) Turning vanes used in the duct were not traceable l (Criterion VIII). (9) Traveler number V2-SH1-1-2A-F8403. This item was found in the field fabrication shop. The foreman stated work had not been performed on this ites at'the field fabrication site. The traveler indicated Welding Procedure Number QCP-1-PSC5 was to be used. This procedure was qualified for welding on material thickness between 0.0672" and 0.269" and base material conformed a to SA414, Grade A. The traveler indicated the sheet metal in this duct was 18 gauge (0.0475") and was galvanized carbon steel which is ASTM A527 (Criterion IX). While conducting inquires into the above allegations, RIII personnel observed that turning vane stock in lengths of ten feet was stored in i a rack in the field fabrication shop. A large amount of the turning vane stock was observed not marked with either material control numbers or color codes, and therefore was not traceable to the applicable i material certification. This stock had been used in the fabrication l of various items (Criterion VIII). 3 l Allegation No. 3 - Traveler Numbers V22SH1-1-P31(3/864)-F11030 and V26-SH1B-11-F10807. Original fabrication of the hangers required documentation of the materials used. Repairs were made to the hangers and the repair materials and procedures used were not documented. Findina - Traveler Number V22SH1-1-P31(3/864-)-F-11030. This traveler was replaced by Traveler Number V26-SHIB-12-F10802. It did not appear that repairs were made to hanger number V26-SHIB-11-F10807. However, it was established that: ) (a) The angle iron control number was not recorded on the traveler (Criterion VIII). l (b) The welder identification symbols were not recorded on either traveler (Criterion V). l (c) Angle iron marked V26-SE1B-11-F10807 was installed in hanger number V26-SHlB-12-F10802, and vice versa (Criterion VIII). (d) Traveler Number V26-SRIB-11-F10807 showed the angle iron was ) welded to a 4" x 5.4" x 45" channel. The angle iron, as .j installed, was welded to a 7" deep,-and 2-1/4" wide channel (Criterion V). i { 3 . x x,
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I 9 (e) All of the angle irons were not marked with control and/or traveler numbers (Criterion VIII). -i Allegation No. 4 - Traveler Number V27-SH3A-29-F4410 was marked Quality Assurance inspected and was considered to have been completed. An unscheduled reinspection of the piece disclosed excessive porosity, missing welds, and heavy souges in the side of the duct. t I h' Finding - Traveler Number V27-SH-3A-29-F4410 was marked QA inspected , h on June 5, 1979. On June 22, 1979, a Hold Report, Number 53, was pre-pared for "not painted per requirements of 7220-M151-A, Section 15.0." On August 8, 1979, Nonconformance Report, Number 491, was prepared, t l citine the above reason. On October 10, 1979, Nonconformance Report. ENumber 677 J as prepared, citing " Flex connection is damaged. Welds' have excessive porosity, also one longitudinal weld has k"." Zack f personnel advised this item had been returned to Chicago for repair. Allegation No. 5 - Repairs are being made at the Midland job site and travelers are not prepared to record the repairs made. Items prepared elsewhere (Zack, Chicago) are repaired at the Midland job site using M gQ procedures and materials different from the materials and procedures j l used during the original fabrication. Finding - It was noted the following four ducts were the only ducts presently being repaired at the Midland field fabrication shop. The repairs were to the spacing of the flange-to-duct weld: Duct Drawing Traveler Nonconformance i Number Number . Number Report Number 1 V34 SH1 F9395 B114 5 V34 SH1 F9396 B113 1 4 V34 SH1 F1306 BillA 3 V34 SHI F1306 B111B It was established that: .1though the traveler for the specific ites was not annotated (a) to document the repairs; Nonconformance Reports were initiated in accordance with Zack Procedure Number QCP-9, revision 1, to }lC indicate the repairs. The procedures and materials used durin,; the repair of the four available duct pieces were identical to those used during the original fabrication. (b) The identity of the welder performing the weld repair was not documented (Criterion V). (c) Welding Procedure Number QCP-1 (PSCS) was used to fabricate ducts No. V34-SH1-1-F9395, No. V34-SH1-5-F9396, No. V34-SH1-2-P1306, No. V34-SH1-3-P1-306, and No. V34-SH1-4-P1306. The sheet metal l of the ducts is ASTM A527 with a thickness of 18 gauge (0.0475"). l The Zack Company Welding Procedure Number MB-QCP-1 (P-5CS), N j i f i _l S 'l 9 8 'b, d' ( n i'l 4
f t ._ol__ l Revision 2, requires that "(2) welding of material in the ,i thickness range of 1/16 (0.0625) inch to 3/16 (0.1875) inch." The procedure was actually qualified to weld in the thickness range of 0.0672 inch to 0.269 inch (Criterion IX). i (d) The travelers for ducts No. V34-SH1-F9395, No. V34-SH1-5-F9396, No .406 and No. V34-SH1-3-1306 stated the welding M N pro. V34-SH1 i cedure to be used was Number QCP-1-PSCS. This procedure requires the use of carbon dioxide as the shielded gas. Indivi-duals stated that carbon dioxide was not available at the Midland y [hg site, and therefore this procedure was not followed in performing j these welds (Criterion IX). .l Allesation No. 6 - The Midland job site does not have established i Quality Assurance " Hold Points" such as no follow-up on shipped loose i flanges, etc. Findina - Neither the applicable code nor the Quality Ascurance Program required the establishment of mandatory QA " Hold Points." A " Hold Area" -- - was-in existence in the laydown area. { Allegation No. 7 - The Zack Company at the Midland job site does not l ] use any welding pre-heat techniques. Welding pre-heating has never been documented at the Midland job site. The Zack Company does not have either gas or electric heaters at the Midland job site to be used for welding pre-heating. Findina - The problem of pre-heating was identified by Consumers in August 1979 and was documented by Consumers Power Company in three nonconformance reports, as well as in a Management Corrective Action Request, MO-1, dated January 8, 1980. It was determined that welding which required pre-heat was being monitored by QC inspectors on a random surveillance basis and these surveillance activities were documented. This was confirmed through a review of two Zack special inspection reports, dated March 10 and 14, 1980. Allesation No. 8 - Steel coils, Numbers 341'and 381, were recently. received at the Midland job site without the written material certi-t fication accompanying them. Findina - It was established that: (a) Haterial certification for steel coils Numbers 341 and 381 was L available at the Midland job site. Steel coil Number 341 was purchased under Purchase Order Number C642. Steel coil Number 381 was purchased under Purchase 6rder Number C743. + (b) The Zack quality assurance group had not reviewed Purchase Order Number C743. Such review was required by the Zack QA Manual, Amendment I tc Section 5, Rev.'0, Paragraph 3. l i l j e 4
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I e. _ _. _ - 4 q s ( i ASTM Haterial Specification Designation A527-71, Paragraph 3.2 sets forth specific information required in orders for material made to this specification. Purchase Order Number C743 did not include information on the " coating type and designation," or, 1 " chemical treatment," as required by material specification ASTM A527. Purchase Order Number C642 did not include infor-mation on whether the material should be " oiled or not oiled" or the applicable year of the specification, as required by ASTM A527 (Criterion IV). Allesation No. 9 - Air monitors purchased by the Zack Company for I installation at the Midland Nuclear Power Station were made without specifying or approving the welding procedure to be used. The air i monitors, made without an approved welding procedure, have been released for installation at the Midland Nuclear Power Station. Findina - It was established that nineteen air monitors manufactured by Air Monitor Corporation were received on site. Four have been installed in non-safety-related systems, and installation in the field did not i i require welding. However, Air Monitor Corporation started manufacturing i the units without prior acceptance of a welding procedure, by the buyer, l as required in Bechtel Specification Number 7220-M-151A(Q), Revision 7 4 (Criterion IX). ) Alletation No. 10 - Parts fabricated in the weld shop (fab shop) are not made from blueprints. Welders get oral instructions from the foreman on how to fabricate the part. / Findina - It was established the traveler contains sufficient i information to allow workman to fabricate parts; furthermore, the size and length of weld are included in plate details located in the fab I shop and are available for reference, if needed. Allesation No.11 - Duct parts in the fabrication shop have no trace-ability, work is usually not documented, and when it is documented, the travelers have neither the coil nor angle number. Findina - Numerous cases of material traceability and control problems are identified in various paragraphs of this report. Allesation 12 - Duct hangers are being installed without the travelers for the parts being annotated to reflect the correct angle iron control numbers (i.e., Traveler Numbers F942, F940 and F944 were annotated with-one set of numbers, yet the duct hangers were marked with a second set of numbers). Findina - Traveler Number F940 for Ranger No. V19-9(3/C898) F940. Angle iron control numbers 697 and 662-3 were recorded on the traveler; however, the identification number was not marked on the angle iron (Criterion VIII). ( - 'b m .~- s - - ; s ..r e s m Y ~, l~, N -4 *N w ? ~ ev t ~ +- -~- A0 vv"- + 6 v
u. i e s i Traveler Number F942 for Hanger No. V19-11(6/C898) F942. Angle iron I control numbers 711, 697, and 662-3 were recorded on the traveler; however, only control number 887 was marked on two pieces of the angle irva and an identification number was not marked on the other angle j iron (Criterion VIII). i Traveler number F944 for Hanger No. V19-13(7/C898) F944. Angle iron i l' control numbers 711, 697 and 662-3 were recorded on the traveler; however, only control number 877 was marked on one piece of the angle I iron and an identification number was not marked on the other angle l iron (Criterion VIII). i i g Allegation No. 13 - The Zack Company does not have any established, ecr ^4 written procedures to document the repair work done at the Midland i job site. i g Finding - Section 16 of the Zack Company Quality Assurance Manual states, "This section contains the methods used for identification, control and resolution of nonconforming conditions found in equipment (Zack or Owren (sic) furnished) materials, fabrications, storage and/ or installation.... responsibility shall also include taking those steps necessary to prevent recurrence." i A selected review of Nonconformance Reports and Hold Reports disclosed each report documented the basis for the hold or nonconformance and details of the resolution, some of which involved repairs. 'I j Allegation No. 14 - Quality Control Inspectors do not receive indepth i training in Quality Control / Quality Assurance procedures prior to being placed into their positions as Quality Control inspectors. Findina - The Zack Company was committed to comply with the requirements of the American National Standard (ANSI N45.2.6-1973) Qualifications, Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants in certifications of their Quality Assurance / Quality Control personnel.' The personnel files of each QC inspector including their resume, the required reading list, i the training records, test scores and examination reports, medical qualifications (natural or corrected near-distance acquity, color vision) and certificate of qualification were reviewed.- The Zack QC inspectors at the Midland site met, or exceeded, the minimum require-4 ments of ANSI N45.2.6-1973. The Zack QC Manager at Midland exceeded i
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the minimum qualification requirements of the standard to fill his position at a Ievel III QC inspector. l. Three Zack Company QC Inspectors, employed at the Midland site, were requested to demonstrate how they performed their assigned duties. i '. The QC Inspectors were asked to demonstrate their techniques for inspecting installed equipment and to demonstrate how they determined the esterials met specifications and enterial quality control used in the manufacture and installation of IVAC systems. -; \\ >l f6l ..i wgg
w q One QC Inspector demonstrated proficiency in examining equipment, locating and understanding material specification requirements and i the correlation of one detailed drawing to another. A second QC i Inspector demonstrated similar proficiency, but showed less ability in correlating information by cross referencing control drawings. The 1 i third QC Inspector demonstrated acceptable proficiency in the field and demonstrated less proficiency than the other inspectors in correlating 2* cross referenced print information and material control verification. The three areas examined in the field were the 599 elevation of the auxiliary building, the 568 elevation of the auxiliary building and the service water building. I Allegation No. 15 - Welding rods have been received for use at the Midland job site without the necessary certification papers, and those a rods have been used in fabrications and installation without the weld l h p rod certification documents. ll} Finding - An inventory was made of the Zack Company, Midland, weld rod Jo St on March 13, 1980. The inventory disclosed the following welding rods p.. _ _._.were either being issued or were in storage awaiting issue: i l Electrode Electrode Manufacturer's Zack P.O. Manufacturer's i Manufacturer Class Diameter Control Number Number Cert. Date i Hobart 6011 1/8" 90317A C-4007 Undated Hobart 7018 1/8" 90384Z076 C-12305 1/3/79 Hobart 7018 1/8" 90013A179 C-12313 1/24/79 Lincoln 7018 1/32" 37G C-580/14203~ 2/10/77 i i The welding rod issue room was locked and access to it was controlled by the QC inspectors. The welding rods in storage were at the fabri-4 g cation shop in a locked cabinet, and access to it was controlled by j QC inspectors. I During a review of the manufacturer's Typical Certificate of Conformance j to Specification for Filler Material, the following observations were made concerning the promptness of certificate review by Zack QA/QC j personnel, I i Zack Purchase Order C-13241, May 14, 1979, for 1/8" and 1/32", E-6011 electrode. l Chronology: I May 16, 1979 Date of the Hobart Certificate of Conformance for i, _, 1/8" E6011 weld rod, serial number 90198Z. May 17, 1979 Zack, Chicago, ships to Zack, Midland, on load #38: a. 100#,3/31",6011 weld rod, Ticket Number F-4125. b. 600#,1/8",6011 weld rod, Ticket Number F-4126. j ! Y 1 ...n.... J 2.- -,, -, - + _
o - - _. i p y l May 18, 1979 I,oad number 38, above, is received at Zack, Midland. I May 29, 1979 Zack, Chicago, performs QA review of the Hobart Certificate of Conformance for 1/8", E6011, serial number 90198Z. June 6, 1979 Zack, Chicago, ships to Zack, Midland, 600#, 3/32", I E-6011 (Ticket number F-6044) on I,oad #42. October 17, 1979 Zack, Chicago, performs QA review of the Hobart Certificate of Conformance for 3/32", E-6011, serial number 90155A. Hobart Certificate of 9 Conformance is neither dated nor signed by Hobart. J March 11, 1980 Zack, Midland, QC Inspectors tag five boxes (each box weighing approximately 50 pounds) for HOI.D, due to lack of documentation (Certs not available) for 3/32", E-6011, 90155A. March 17, 1980 Zack, Midland, receives copy of the Hobart Certificate of Conformance for 3/32", E-6011, i l serial number 90155A, from Zack, Chicago. I Review of the Zack, Midland, Noncompliance listings disclosed five j boxes (250 pounds) of Hobart E-6011 3/32" diameter weld rod received i during the period May 17, 1979 - June 6, 1979, were not placed on Hold for " lack of documentation (Mat'l Certs)" until March 11, 1980. This review indicated the weld rod had been issued and utilized prior to receipt of weld rod material certification and this condition was not l identified on a timely basis. The remainder of this weld rod, 450 l pounds in 9 boxes, was not placed on hold and_its use could not be-determined (Criterion XVI). In addition to the above, three other instances were noted in which the lack of weld rod material certifications were not promptly i identified. These instances were: Zack Purchase Order C-4007, September 28, 1979, for 1000f, 1/8" and 3/32" diameter electrode. Chronology: i October 26, 1979 Zack~, Chicago, performs QA review of Hobart Certi-ficate of Conformance for E-6011 electrode,1/8", L,, serial number 90317A. The Bobart Certificate of Conformance was neither signed nor dated. 7/ : October 29, 1979 Zack, Chicago, ships to Zack, Midland, 100f,_3/32" 6011, weld rod (Ticket number F-11419) on I,oad #67. October 31, 1979 Above load is received at Zack, Midland. i i I 5 ? s
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.o ,a i November 7, 1979 Zack, Chicago, ships to Zack, Midland, 500#, 3/32", 4 6011, weld rod (Ticket number F-11575) on Load 71. November 8, 1979 Hobart Certificate of Conformance date for 3/32", E-6011, serial number 90397A, weld rod. November 16, 1979 Zack, Midland, performs receipt inspection of the 500# of weld rod shipped on November 7, 1979. I November 19, 1979 Zack, Chicago, performs QA review of Hobart Certi-2 ficate of Conformance for E-6011 electrode, 3/32", serial number 90397A, dated November 8, 1979. j March 11, 1980 Zack, Midland, QC Inspectors HOLD tag for " Lack of ? Documentation:" I box, Hobart, E-6011, 3/32" serial number 90397A. March 17, 1980 Zack, Midland, receives copy of the Hobart Certi-ficate of Conformance for E-6011 electrode, 3/32" diameter, serial number 90397A, from Zack, Chicago. i A review of the Zack, Midland, Nonconformance Reports composite listings disclosed only one box (50 pounds) of 1500 pounds of 3/32" diameter, Hobart E-6011, control number 90397A weld rod were placed on " hold" during the period October 31, 1979 - March 11, 1980, for " Lack of Dorumentation (Mat'l Certs)." t Zack Purchase Order C-4044, December 18, 1979, for.035 and.045 i welding wire. Chronology: December 19, 1979 Zack, Chicago, ships to Zack, Midland, 288# in 8" spools, A675,.035 wire (heat #411J6431), ticket number F-11656, Load #79. December 26, 1979 Load #79 is received at the Midland job site. December 27, 1979 Date of the AIRCO Quality Conformance Report for A675.035" diameter wire, heat #411J6431, lot
- 91017A18.
i January 3, 1980 Zack, Chicago, performs QA review of AIRCO Quality l Conformance Report for.035 wire, heat #411J6431, lot #91017AIB. L ~ January 11, 1980 Zack, Chicago, ships to Zack, Midland, 12 spools, A675,.045" diameter, AIRCO wire, ticket number F-11448, load #82. January 22, 1980 Load #82 is received at the Midland job site. 'I a >l i 0 j\\ e e-, +
February 14, 1980 Date of the AIRCO Quality Conformance Report for .045" wire, heat #411J6431, type A675. i l February 25, 1980 Zack, Chicago, performs QA review of AIRCO Quality { Conformance Report for.045" wire, heat #411J6431. l March 11, 1980 Zack, Midland, QC inspectors place Hold tags on: i 4 a. 18 spools (12 pounds each, 216 pounds), AIRCO, .035" diameter welding wire, heat #411J6431, j Control #91017AIB. l b. Six spools (12 pounds each, 72 pounds), AIRCO, .045" diameter welding wire, heat #411J6431. March 17, 1980 Zack, Midland, receives copies of the AIRCO Quality Conformance Reports for the.035" and.045" diameter welding wire, from Zack, Chicago. --~~ A review of the Zack, Midland, Nonconformance Reports / Hold composite listings disclosed 18 spools (216 pounds) of the 24 spools (288 pounds) of the.035" diameter wire and 6 spools (72 pounds) of the 12 spools (72 pounds) of the.045" diameter wire were placed on hold during the period December 26, 1979 - March 11, 1980. The March 13, 1980, inventory of the Zack, Midland, weld rod storage facility (fabrication shop) disclosed the following items had been i marked " Hold - Lack of Documentation (Mat'l Certs)." i Electrode Electrode Manufacturer's Heat Number of Manufacturer Class Diameter Control Number Number Containers Aton Arc 7018 1/8" 02-1-G902T CG 421H5281 9 cans Hobard 6011 3/32" 90164Z I box t AIRCO .045" 70616AIC 421A6821 5, 12 lbs. spools Hobart .035" 1709393 L83330-30 lbs. The hold tags for the above were dated March 11, 1980. Review of Zack, Midland, material certificates and receiving records, and inquiries of Zack, Midland, QC inspectors, during the period March 13-27, 1980, did not disclose any documents during the investigation (Material Certifi-cates Travelers) identifiable with the above listed welding electrode. The lack Company weld rod issue room was examined on March 13-14, 1980. During this examination, it was noted the stickers on the door of the warming oven used to identify the material contained in the oven had. identifying numbers of 37G for weld electrode stored in the lower por- - tion and what appeared to be the numbers "376" for the material in the upper portion. A Zack employee stated the 376 number was really 37G. x The lower portion of the oven contained E-7018-3/32" weld electrode, and the upper portion contained E-7018-1/8" weld electrode. Material certifications for E-7018-3/32" weld rod with control number 37G were located. A I -n-fv - -- -. J. q., g., ; g ~e-s
y Material certification could not be located for E-7018-1/8" weld elec-trode with a 37G number. Based on the Weld Rod Issue Sheet, it was determined that approximately 60 pieces of E-7018-1/8" wtld electrode from control number 37G were consumed in one day. The source of the E-7018, 1/8" diameter, weld electrode issued from the rod is'aue room could not be determined (Criterion VII). A11eastion No. 16 - The Zack Company uses American Welding Society j number 7018 electrode welding rods. The storage of the number 7018 rods is to be in metal costainers where~the moisture is controlled. 4. The Zack Company stores.7018 rods i.e cardboard boxes, and the moisture I content is not controlled. Findinz - The March 13, 1980, inventory of the weld rod storage area 3 in the Midland Job Site Fabrication' ebop disclosed the following AIRCO, 7018, Low Hydrogen weld rod had been marked on March 11, 1980 by Zack, Midland, QC inspectors for being, " Improperly Boxed - Should Be in Metal Containers:" Ld ....f a....'.
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~ j Diameter Control Number Cardboard Boxes i 3/32" 911-29C4C 6 3/32" 911-29C4B 5 1/8" 9920C4C 16 1/8" 9920C40 1 i 1/8" 910-2C-SA 1 1/8" Unknown 1 3/32" Unknown L 34 Cardboard Boxes During the course of the review of the Manufacturer's Typical Certifi-cate of Conformance to Specification for Filler Material, the following observations were made concerning the promptness of segregation of nonconforming materials: x Zack Purchase Order C-14212, 7018, 3/32" diameter,'iot #91129C-4B. Chronology: December 10, 1979 Zack, Chicago loadA, "1000# 3/32" E-7018 electrodes, traveler number F-11570. December 15, 1979 Above described shipment arrives at the Midland site. ~ March 11, 1979 Zack QC, Midland, tas 5 cardboard boxes (250 pounds) sc to be returned to Chicago as the rods had not been-in metal containers. March 27, 1980 Zack, Midland,QCManager,~advisedthe57ardboard~ boxes of weld rod.had been returned to 1stk, Chicago, [ on March 11, and the boxes had been returned toithe manufacturer. 4 = O N / [ r ( .c.
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i p q 1 i Review of the Zack, Midland, Nonconformance Reports disclosed five i cardboard boxes (250 pounds) of the 1000 pounds (200 boxes) of the 7018 AIRCO weld rod were not marked until March 11, 1980 as noncon-a forming for'" Improperly Boxed - Should be in Metal Containters;" although the weld rod was received at Zack, Midland, on December 15, i I 1979 (Criterion XVI). f On March 27, 1980, the Zack, Midland, QC Manager advised the 34 card-board boxes containing AIRCO 7018 welding electrode had been returned to Zack, Chicago, on March 11, 1980, and the 34 cardboard boxes of j 7018 weld rod were subsequently returned to the manufacturer. Allegation No. 17 - Fire dampers at the Midland Nuclear Power Plant l l were installed by the Zack Company without using an approved welding procedure and without documenting the welding. The installation of 'h[ the fire dampers and the subsequent repair of the fire dampers were not documented by the Zack Company. Findings - Travelers and Quality Control Survey Reports for equipment installation and/or ductwork installation for V22C duct 10, 10A, V22C i duct 40, V22B duct 40 and V22Sh 1-1 ducts 15, 29 and 62 were reviewed. During these reviews, the Zack Co. could not demonstrate which proce-l dure had been prescribed, if any, for the welding of the fire dampers 3 associated with the above referenced ductwork. The weld procedure was not referenced on the travelers for the above listed pieces, which i were located in the Auxiliary Building at the 614' elevation and were i 3 associated with the Battery Rooms. I I During the' review of welding of fire dampers, the validity and approval i status of applicable procedures which may have been used was examined. l One procedure, MB-QCP-33, SMAW Welding of Structural Steel to Sheet i Steel and Sheet Steel to Sheet Steel for Galvanized Materials with E-6011 Electrodes, pertained to the welding of the fire dampers. This particular procedure had.three revisions. Revision "0" was approved by Bechtel Power Corp. for use on September 6,1979. Revision "1" was disapproved by Bechtel Power Corp. on November *2, 1979 with " work may not proceed" instructions. Revision "2" was approved by Bechtel for use on January 15, 1980. Discussion with Zack Co. personnel revealed i that safety related fire dampers asy have been installed during the i period of November 12, 1979 to January 15, 1980, when QCP-33 was not an approved procedure. However, within the scope of the reviews I performed and with the lack of adequate documentation, this could be neither substantiated or refuted. As a result of a 10 CFR Part 21 notification by the Ruskin Manufacturing Company pertaining to NIRD73 fire dampers, Zack Company personnel were attempting to identify those fire dampers which might be affected. The Ruskin Manufacturing Company had supplied a listing of the dampers which asy be affected, and which were shipped to the Midland site. These dampers were identified on the listing by serial number and sise. Approniastely forty of these dampers had been installed. Zack Company QC personnel appeared to have difficulty la locating and identifying affected safety-related Ruskin dampers. A comparison of the noncon-l
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N . c 4 - s x (a n,, 3 s ~L x-formance tags issued on Ruskin daspers with the listing' supplied by, Ruskin identified numerous discrepancies and ambiguities. Further, 2ack Company personne1' could.not produce equipment installation records indicating the final' inspection of installed, serialized, safety-related _Ruskin fire dampers (Criterion XVII). ~ ~ z Alle_a_ation No. 18 - A recent au'dit of the Zack; Midland, QC function 3 - sas, conducted by an individual having prior management' responsibilities U MN* at-2ack, Midland, and the audit had not been conducted by an impartial individual. Findinas - The previous Zack, Midland, Project Manager (Mr. F. D. Thompson) became the Zack Company QA % nager in December, y 1979. On March 6 and 7, 1980; Thompson participated in the annual audit of the Zack, Midland, QC function. A review of the ^"Qualityr Assurance Job Site Audit Report" for March 6 and 7, 1980, disclosed that Thompson, the present QA Manager, and ifr. Harry Geyer,' Project QA Manager, corrprised the audit team. Geyer appeared to have QC 3 responsibility in many of the areas examined during the. investigation. a Thompson was respensible for auditing areas in which he had'immediate prior responsibilities (Criterion XVIII); ~ x ,Z Alleza!.ic,n No. 19 _Two welders were using the ssae identification j ~ stamp,6CU7. n -Y Fiudinas - A review of welder qualification and welder identification number records'showed that two, qualified, welders had been issued an-4..
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{ identical welder identih. cation number,'CU7. Both welders had identi- ~ fied their welds using this symbol. Zack Company personnel stated the second welder receiving CU7, as an identifying symbol, welded primarily -in the Upper Spreading Room, and these CU7 weld symbols were changed to l~ J,U7B using, yellow, Nissen Marker. Welds on hangers number 35 and 36 i detailed drawing number V26SH1 carried dual welder identification number of CU7 and CU7B (Criterion IX). ? 6. Additional Allegations _3' On April 14, 1980, Individual 'A' contacted Region III, and made an additional allegation. This allegation concerned activities by the- ' r., y Zack Company following the issuance of the stop work order on March 20,
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4 1980. + - s 4 ;,. .~ 7 y ' W On April 18, 1980, Region III was advised 9 prc.blems which were 1.:,
- 9 encountered following the stop work are r, ; Jimarily concerning the U1
. traceability of materials. These rail e s e the information obtaGed i concerning them are set forth belev. H w.: Allenation No. 20 - Where traveler sketches did net match the description of the installed hangers;.new travelers were being drawn i - 2 ? to'show the installed hanger. The old travelers are being destroyed. Information regarding material certification that was not on the.old travsler was;being placed on the new traveler. ~* .c s ~ h cA < x .se } Y' a ' t s. v. [ +: .i. m .---.+*9 n,...,. m_ ..w-m 7, mw r w,< +s -+ ,?--- .qw - M~ ' ;k;) 3:' ~;n '} f f_ ^
Finding - The six Zack QC inspectors at the Midland site were inter-viewed and provided the following information. l Three of the six inspectors were engaged in the reinspection of the installed HVAC hangers required by MCAR, MD-1, January 8,1980 (Para-graph 4 of this report). During the reinspection they had encountered problems dealing with the agreement of the traveler sketch to the installed piece. In some instances the installed piece did not resemble t I the traveler sketch. In other instances the welding procedure called i for on a traveler did not agree with the welding procedure used during fabrication. Also, the certificates of conformance for materials used during fabrication and installation were not recorded on the travelers. In the instances where the traveler sketch and the actual installed piece did not agree, or where the welding procedure prescribed on the traveler did not agree with the procedure used during fabrication or installation; the QC inspectors were researching the Bechtel civil drawings (the 'C' drawings). In researching the 'C' drawings, they found field changes had been made and the hangers had been installed in accordance with the 'C' drawings and the field changes, but the traveler had not been updated. The installed hangers were marked with a nonconformance tag and a nonconformance report was written. The recommended method of corrective action on the nonconformance reports was to change the traveler drawing. In instances where there was only a minor change to be made to the traveler (i.e., where a longitudinal brace had been cdded to the hanger and the brace had i not been shown on the traveler sketch) the recommended method of i corrective action on the nonconformance report was to draw the added brace on the traveler sketch. In other instances where a major i change had to be made (i.e., where the installed hanger did not agree at all with a traveler sketch, as in the case of a double duct run being n abstituted for a single duct run) the recommended corrective action was to draw a new traveler. None of the three quality control ins'pectors conducting the reinspection of the HVAC hangers was aware of any of the old travelers being destroyed after the traveler had been superseded by new travelers. Where the welding procedure on the installed hanger did not agree with the welding procedure prescribed by the traveler, the quality control inspectors again referred to the 'C' drawings. In referring to the 'C' drawings they found the welding procedure called for on the traveler = (e.g., IAPSCS) was in error, as the.'C' drawing would prescribe an entirely different welding procedure (e.g., QCP-22). In the instances where the welding procedure describ,ed on the traveler and the procedure described on the 'C' drawing were in conflict, the quality control inspectors found that the welding procedure actually used during fabri-cation and installation agreed with the welding procedure prescribed by the 'C' drawing. In these instances the inspectors were placing conconformance tags on the installed hangers and issuing nonconformance reports. The recommended corrective action on the nonconformance report was to change the welding procedure on the traveler to reflect the correct welding procedure used. 26 - 1 L.a _..r. s L 'Wfg* KW. 4 'M
1 _o 1 = -~ Where the identified problems could not be rectified by referring to the 'C' drawing, the quality control inspectors were issuing i nonconformance tags and preparing nonconformance reports in order to j identify the problems. None of the nonconformance reports for these problems had been closed out at the time of the investigation. Each of the quality control inspectors was reviewing the traveler for material certification numbers. In the instances where the material j certification numbers were not on the traveler, but were marked on the installed piece, the quality control inspectors would issue a hold tag. The inspectors would then research the material certifications and i attempt to determine if quality material had been used during j fabrication and installation. In the instances where the material certification was available to the quality control inspectors, they would record it on the traveler and then close out the hold tag by using that information. In the other instances where the material certifications were not available for their review the quality control inspectors would issue a nonconformance tag for the piece in question i l and prepare a nonconformance report. After issuing the nonconformance report, the quality control inspectors would attempt to identify the material through the Zack quality assurance section in' Chicago. Where the quality assurance section could determine the mat'erial used during fabrication and installation, the quality control inspectors at Midland l 1 would then recommend in their nonconformance reports'that the material j certification information be incorporated into the traveler. Where the material used during fabrication and installation could not be determined at all, the quality control inspectors would recommend in their noncon-formance reports that the ites in question be scrapped. During the course of the interviews of the quality control inspectors, Individual 'C' provided written statements-(Exhibits III and IV). Individual 'C' stated he had encountered two instances where material traceability had become a problem. In one instance angle iron marked with control No. 752-1 was used to fabricate hangers. While reviewing the material certifications for the 752-1 angle iron, Individual 'C' could not locate the material certification, and later determined that material certification did not exist at all for angle iron control No. 752-1. Indr idual 'C' did determine the angle iron should have been control No. 758-1 under traveler No. F-4106.~ Individual 'C' stated the problem with these two control numbers was caused during 3 - the preparation of that traveler and that the'8 of the number 758-1 was not readily distinguishable and at first glance appeared to be a 2. Individual 'C' stated he brought this problem to the attention 1 of the Zack, Midland Quality Control Manager, and the Quality Control Manager told Individual 'C' to change the numbers on the angle iron from 752-1 to 758-1. Subsequent interview of the Quality Control' Manager and' Individual 'C' disclosed the Quality Control Manager had advised Individual 'C' to change the number from 752 to 758 on both the traveler and on the material. Individual-'C advised that he had prepared a hold report to describe this problem and that the hold i report had not been closed out at the time of the investigation. m e x LI [ $ 7 - Qn w,n. x 1 .f
e (. Individual 'C' also stated that he had encountered a problem with channel iron with control number 801-2. During his review of material certifications, Individual 'C' could not find the material certifi-cation for channel iron 801-2 in the size of 3 inch by 5 pound. The l available material certification under control No. 801-2 was for 4 inch by 5.4 pound channel iron. This channel iron was also shipped under traveler number F-4106. In referring to traveler F-4106, Individual 'C' found that the 3 inch by 5 pound channel iron did not have a control j number written on the traveler at all. Individual 'C' was instructed i by the Quality Control Manager at Midland to contact the Zack, Chicago, l Quality Assurance Section to obtain additional information pertaining to this channel iron. Individual 'C' was informed by memo from the Quality Assurance Section that the correct control number for the j channel iron should be C-666. Individual 'C' prepared a hold report J and placed the channel iron on hold until the certifications for the j material were received. ) Interview of the QC inspector in charge of document control disclosed that in the instances where new travelers were being prepared to document discrepancies between old travelers and the actual installed hangers, the old travelers were not being destroyed. The old travelers and the documents relating to them were retained in the individual file for each hanger. This file also included the new traveler that was l prepared to resolve the discrepancy and the related inspection reports pertaining to that hanger. A selective review of hangers and hanger files confirmed that original travelers were being retained in the hanger files in those instances where a new hanger or a new traveler had to be prepared to resolve the discrepancy between the actual installed hanger and the old traveler. Alleaation No. 21 - Individual 'D' stated examples of bad welds made by the Zack Company during HVAC installation could be found in the control room. These bad welds had been accepted by the quality control inspectors during the initial inspection, and this area had not been placed on the Zack reinspection list. [ Findina - Random observations in the Midland control room disclosed numerous improper welds in the HVAC installation. Many of these welds q showed excessive porosity and slag inclusion. One hanger, No. V26-SH-3, R having defective welds was selected for further review. A review of the Zack files did not reveal an in-process inspection report for hanger No. V25-SH-3. Also, the review disclosed that this hanger had not been scheduled for reinspection by the Zack Company. However, Consumers i Power Company had made note of poor in process hanger inspections by the Zack Company on Consumers Noncompliance Report H-01-4-9-079, as well as being a part of the Management Corrective Actiot Request (MCAR) No. MD-1, dated January 8, 1980. Both the Consumers Power Company's Nonconformance Report and the Macagement Corrective Action Request l required the total reinspection of all installed HVAC hangers, including those installed in the control roce. Both the Consumers Power Company Nonconformance Report and the Management Corrective Action Request are still open and work remains pending on both. . 0 1 '.s s 5,m-
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(~, 7. Other Matters Markina of Galvanized Carbon Sheet Steel Findina - While in the Zack, Midland, fabrication shop sheet steel was t observed to be marked in a dual manner. Each 4' x 12' steel sheet bore l duplicate identification numbers. The sheets were marked with the coil 1 number in yellow, Nissen marker, as well as having the coil number and the Zack Company Purchase Order Number marked with a black felt-tip marker (Eberhard Faber Marquette). i j While in the vicinity of Battery Room 351, Elevation 614, Auxiliary Building, an installed duct system was found to be marked in black, t "V22-F-21, Aux 614 F5848, 2VM-0S-B. Similarly, in the Upper Cable Spreader Room two installed duct pieces were marked in black, "2402 V26-SH1, F9110, 28 x 16", and "2402, V26-SH1-33, F9117, 28 x 12. Inquiry of Zack, Midland, QC inspectors disclosed the duct pieces, described above, were Seismic Class I, and the black marker was used as the yellow, Nissen marker had a tendency to smear before i;;i ;. ~ Inquiry of the Bechtel Power Systems Quality Assurance Representative revealed the black marker was not a currently approved marking material, but a design change was in the process, but not yet approved, of being made to allow the use of the Eberhard Faber Marquette on galvanized carbon steel (Criterion V). f i Calibration of Portable Weld Rod Carriers Finding - During a visit to the Zack weld rod storage and issue rooms / on March 13, 1980, four of twelve portable weld rod carriers (caddies) 7 were found to be lacking identification control markings and were void .pk (C of any calibration stickers. Records indicated two of the units were out of calibration (due November,1979) and two units had not been recorded at all (Criterion IX). De-energized Weld Rod Carrier Finding - During an examination of the fabrication shop on March 13, 1980, a de-energized weld electrode warning caddy was noted in a portion of the building where welding operations were perfcreed. Further examinations of the caddy revealed the caddy was cold to the touch and it contained a mixture of E-6011 and E-7018 welding electrode. A cursory count of the weld electrode contained in the caddy indicated that at least twelve E-7018 and at least eight E-6011 weld electrodes were in the caddy. The caddy did not appear to have an identifying serial number. No Filler Metal Withdrawal Form was available which could account for the weld electrode in the caddy (Criterion IX). Gas Metal Arc Welding Findirt - During the examination of the Zack Company fabrication shop, on March 13, 1980, a 45' by, nominally, 4' diameter duct was ' 3 1 5 t f(>~~ A,
( - being repair welded using a gas metal arc weld process. The duct was identified on Zack traveler number F-9396 and on drawing number V34-SH1-5. Subsequent to this examination, the material certifications were sought for the weld filler material being used, and sn examination of the weld filler material spool was requested. RIII personnel were .j informed the material certifications were not available, and the weld filler material spool (with the remainics wire) had been discarded. 1 Nonconforming condition were not identified for those duct pieces i which were known to have been previously welded with the discarded 1 weld filler material. At a later time during the investigation, a partially used spool of 0.035" diameter, E-703-3, weld filler material was produced by Zack Company personnel and was claimed to be the spool whi-h had been in use at the time of the fabrication of the duct piece, Traveler number F-9396. Zack personnel claimed the spool had been j retrieved from the trash. Material certifications were eventually produced for the spool which was claimed to have been retrieved. This spool was identified as 0.035" diameter Hobart HB-25, heat number 183330, centrol number 1709393. Zack Company personnel indicated that the wire remaining on the spool would be utilized (Criterion XV). Electrode Processing i Finding - Electrode processing was observed at change of shift, or. I March 13, 1980. It was noted, weld rod was returned to the attendant in heated rod caddies by welders of the day shift. Approximately 12 g "(#7018) electrodes in one rod caddie were cold to the touch. The attendant did not know that processing of this rod was to be entirely t 4 Ldifferentthantheheated(thisrodshouldbethrownaway) electrodes. 4 i It was clearly apparent from questioning that the attendant was not $.) f' familiar with the applications of the AWS DI.1, Part B, Section 4.9 requirement that low hydrogen electrodes (7018) must be redried after being allowed to go without heat for greater than four hours. Since he had no way of knowirg how long the rod had been cold, his only action was to bend and throw the rod away, as only a. weld rod storage oven, not an oven of sufficient temperature range to permit rod reconditioning, was available. Use of White Nonconformance Tan Finding - The Zack Company lay down area, located adjacent to the j fabrication shop was examined on April 23, 1980. During this examina-tion, it was noted that essentially all Nonconformance Tags applied to 1 numerous, NIBD 23, Muskin fire dampers stored in this area were mada of i a white paper and appeared to be a Xerox copy of the regularly issued yellow Noncomformance Tags. These tags were applied as a result of 10 CFR Part 21 notification pertaining to installation of negator type closure springs. The Service Water Building was also examined on April 23, 1980. Zack Company Nonconformance Tags placed on hangers located in the centermost service water pump bay were made of white paper which also appeared to be Zeroz copies of the required yellow l Nonconformance Tags (Criterion XV). l f 3o _ y L. I ,_._._m. 5 ( f i _'* l
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A 3 / Nonconformance Tan Item Identification l Finding - During the investigation, Zack personnel placed Nonformance j Tags ca, NIBD 23, Ruskin fire dampers as a result of a 10 CFR Part 21 notification. Many of these tags identified the damper only by the damper size and a drawing number which would identify the duct layout y schematic and hanger location. Some tags identified an elevation. O t t Other tags specified only a damper size. There are several safety-l related and non-safety-related Ruskin dampers of identical size used in the heating, ventilating and air conditioning systems. An identifying item number and piece mark number wac not entered on any of the approximately 60 Nonconformance Tags reviewed pertaining to j the Ruskin damper Part 21 nonconformance (Criterion XV). Permanent Weld Identification and Documentation 1 i Finding - Zack Company was requested to prodata the permanent documen-I tation associated with the welding for hangers numbered 33, 34, 36, 37, 38, and 21A located in the Upper Spreading Room and detailed on drawing _ ______ number V-26SHl. No permanent documentation could be produced which would identify a given weld with a welder's symbol, type electrode, date and inspector's initials (Criterion V). Findina - During.he investigation, several duct hangers were examined which are located in the Upper Spreading Room. The hangers examined are detailed on drawing number V26SHI and are hangers numbered 33, 34, 36, 37, 38 and 21A. Each of these hangers has at least one weld which has i not been marked with a welder identification number and one hanger has four multiple weld areas which do not have welding identification ' numbers (Criterion IX). Other Observations The following observations were made by RIII personnel during the course of this investigation: An installed hanger, No. V9-SH1-7, did not resemble the sketch of the hanger on the traveler, No. V19-7(1/C893). The original hanger (in the configuration as shown on the traveler) was fabricated by the Zack facility in Chicago. i The hanger (in the configuration as installed) was fabricated and installed without a new traveler being prepared. (Criterion V) e physical dimensions of the angel iron of an installed hanger, i No. VI-3(7/C886) F916, were different from the dimensions listed on the traveler for that hanger. The height of the hanger prescribed by the 10 I traveler for that hanger was 43 3/4", but the actual height of the installed hanger was approximately 37". The installed angle brace was a 2" x 2" angle, instead of the 3 1/2" x 3 1/2" x 1/4" angle required by the traveler. (Criterion V) A procedure for the final inspection of items field fabricated at the Midland site did not exist. (Criterion X) 1 l q h 2 ... n m
l i A hanger, V19-Sh 1-7, did not have either the traveler number or the material control number identified on all of the sub-components. This hanger was fabricated with an angle iron marked with the identification j for hanger number VI-3(9/C886)-F916). (Criterion VIII) 1 A hanger, No. VI-3(7/C886)-F916 did not have either the traveler number or material control number marked, or otherwise identified, on all of the ( i sub-components. (Criterion VIII) The %ack Company was storing numerous sections of angle iron in the i Poseyville, MI, "Laydown Area". The sections of angle iron were not marked with material control numbers or any other identification markings to insure material traceability was maintained. (Criterion VIII) Sections of angle iron used to fabricate a duct, No. V26-Sh2B-46.1-P1515 i l had material control number 727-2 written on them. A review of the material certification for angle iron control number indicated the material was ASTM A575. It was determined the Zack Company did not have a qualified welding procedure to weld on ASTM AS., material in accordance with AWS us.1.21st coce turiterion IX). 8. Management Meeting Subsequent to this investigation, a meeting was held with the Consumers Power Company, Bechtel Power Corporation and Zack Company personnel identified in Paragraph 1 of this report, at the Region III office on May 2, 1980. The purpose of this meeting was to discuss Region III's concerns regarding the implementation of the Consumers Power Company's quality assurance program at the Midland Nuclear Power Plant, Units 1 and 2, as pertaining to the Zack Corporation and the Region III Immediate Action Letter dated March 21, 1980. In addition to discussing Region III's concerns and the need for prompt Consumers Power Company management attention / involvement to resolve these concerns, enforcement options available to the NRC were discussed. Attachments: A. Exhibit I, Copy of Typed Transcript of Statement by Individual 'A' B. Exhibit II, Copy of Immediate Action Letter dated March 21, 1980 C. Exhibit III & IV, Copy of Typed l Transcript of Statements by Individual 'C' is 4 4
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~ Bay City, Michigan (LOCATION) I 8 March 12, 1980 l (DATE) I, (Individual "A"), hereby make the following statement to CHARLES H. WEIL, who has identified himself to me as an Investigator of the United States Nuclear Regulatory Commission. I make this statement freely with no threats l or promises of reward having been made to me. Mr. Weil has assisted me in the preparation and typing of this statement. I have been employed by the Zack Company (the heating, ventilation and air 3 conditioning subcontractor at the Midland Nuclear Power Station construction l site) for the last seven months. For the last two months, I have worked as a Quality Control Inspector for the Zack Company. During the course of my employment the following items have come to my attention: l Travellers (the documents accompanying the Zack products) indicating the materials and procedures are pre-signed as being accepted by the Quali+.y Assurance section at the Midland job site. The items are fabricated at the Midland job site, but the pre-signed traveller indicates the materials were fabricated at the Zack Company shop in Chicago. The primary way of determining the difference of where an ites was fabricated was by paint. The items fabricated at the Midland job site are not painted, as the Midland i job site does not have the facilities to paint. All items fabricated at the Chicago shop are painted, as the Chicago shop.does have the facilities to 1 apply paint. Travellers were being " signed-off" as Quality Assurance received at the Midland job site, yet the items described by the travellers were not completed. Examples of this practice of sign-off of unfinished work are: i Traveller number V03-42B-F10171, flanges and vanes were not installed. Traveller number V03-SR2-F9437, vanes not installed and one end of the duct was still raw material and not finished. Traveller number V26-SH2B-46.1-P1515, welds were loose, not gastight as required. Traveller numbers V04-SH-2-P277A-F10676 and V10-42B-10171 vanes were neither welded nor screwed-in as required. Traveller number V10-428.1-F10172, flanges were not installed. Traveller number V26SR28-47.1-P-1516, joints were loose and not gestight. Exhibit I 3 b ( ~ [ .:}.7[gg 3; ~ } .y ~- ~
( ~, .l ~ Traveller numbers V22SH1-1-P31(3/864)-F11030 and V26-SHIB-11-F10807, original fabrication of the hangers did require documentation of the materials used. i i Repairs were made to the hangers and the repairs were not documented as to additional materials or procedures used. V3SH2 2C-F10397 was in the process of being installed at 599' which it was 1 discovered to have defective vanes (undersized) defective welds on flange to duct joint and improper weld spacing on vane rail. The piece, however, was noted to have been inspected completely. t F8403 V-2SH1 was sign as being received from Chicago yet was found being fabricated on site with same Traveller. l Traveler number V27-SH3A-29-F4410, was marked Quality Assurance inspected j and was considered to have been completed. An unscheduled reinspection of I the piece disclosed excessive porosity, missing welds, and heavy souges in l the side of the duct. The Zack Company does not have any established, written procedures to- ~ ~ j document the repair work done at the Midland job site. Repairs are being made at the Midland job site and the travelers were not prepared to indicate the repairs made. j Repairs to items prepared elsewhere are repaired at the Midland job site u.ing procedures and materials different from the materials and procedures used during the original fabrication. j The Midland job site does not have established Quality Assurance " Hold Points." Such as no follow ups on shipped loosa flanges etc. Quality Control inspectors do not receive indepth training in Quality Control / Quality Assurance procedures prior to being placed into their positions'as Quality Control inspectors. The Zack Company at the Midland job site does not use any welding preheat techniques. Welding pre-heating has never been documented at the Midland job site. The Zack Company does not have either gas or electric heaters at the Midland job site to be used for welding pre-heating. The Zack Company uses American Welding Society nunber 7018 eleccrode welding l rods. The storage of the number 7018 rods is to be in metal containers, where the moisture is controlled. The Zack Company at the Midland job site are stored in cardboard boxes, and the moisture content is not controlled. l-i Welding rods have been received for use at the Midland job site without j - the necessary certification papers, and those rods have been used in fabrications and installat..,n without the weld rod certification documents.- .j p Items have been fabricated at the Zack Company shop in Chicago and have been sent to the Midland job site with the necessary travelers. Once at the Midland job site the fabricated items have been scraped, for one reason l Exhibit I tf si 2-i l ?- .e. 'b -[ 4 UUe f;,, g $ f
s or another, and replacements have been fabricated at the Midland job site. The travelers from the Chicago shop were not annotated to show the item from Chicago was scrapped. The replacements made at the Midland job site were made using the Chicago travelers, and new travelers were not made for i the replacement ites fabricated at the Midland job site. Steel coils, numbers 341 and 381 were recently received at the Midland job site without the written certification accompanying them. i d Air monitors installed by the Zack Coepany for installation at the Midland Nuclear Power Station were made without an approved welding procedure in I existence. The air monitors, made without an approved welding procedure, I have been released for installation at the Midland Nuclear Power Station. Fire dampers at the Midland Nuclear Power Plant were installed by the Zack j Company without using an approved welding procedure and without documenting the welding. The installation of the fire dampers and the subsequent repair of the fire dampers were not documented by the Zack Company. l I have read the foregoing statement consisting of three pages. I have made any necessary corrections and I have initialed those corrections. I have signed my name in the margin of each page. This statement is the truth to the best of my knowledge and belief. i /S/ (INDIVIDUAL 'A') l WITNESS: /S/ Charles H. Weil NRC REGION III, Glen Ellyn, Illinois i f I .l i I Exhibit I 4 7 N. ~,, - -... ,j ,,m.~ J,.
~. _. l l 4 Midland, Michigan April 18, 1980 (Date) I, (Individual 'C'), hereby make the following statement to CHARLES H. WEIL, who has identified himself to se as an Investigator of the United States Nuclear Regulatory Commission. I make this statement freely with no threats j or promises of reward having been made to me. i j I am presently employed by the Zack Company at the Midland Nuclear Power Plant Construction Site, Midland, Michigan. My position with the Zack l Company is Quality Control Inspector, I,evel I. I have been employed by { the Zack Company since January, 1980. The Zack Company is responsible for the installation of the heating, ventilation, and air conditioning systems at the Midland Plant. The Zack t Company is presently doing a complete reinspection of installed ductwork hangers at the Midland Plant. In my position as a Quality Control Inspector i it is my responsibility to inspect completed ductwork for completeness, quality, and fabrication and installation in accordance with the prescribed codes. i During the reinspection, I have found two' areas that have caused me to be l I concerned: 1. The installed ductwork being reinspected is being placed on " hold" or being marked as "non-conforming" at a high rate. Most of the problems seem to be in the area of accountability on paper. In many instances the weld procedure described on the traveler, the traveler is the written instructions on how a piece of hangers is to be fabricated and installed, does not agree with the weld procedure used during i installation or fabrication. I have found the problem to be that the weld procedures placed on the traveler during traveler preparation were in error and not the weld procedure actually used during' instal-lation of the hanger or during its fabrication. I have found that for the most part the weld procedure used during installation or fabrication agrees with the weld procedure specified in the detail drawings (blueprints). 2. During the reinspections I have found several instances where incorrect material control numbers, the number assigned to identify material from its purchase through fabrication to final installation were incorrect. I found that the control numbers entered on the traveler and placed on the material were not traceable through records to any materials received at the Midland Site, l heo examples of this being: A. 1\\" X 1\\" I k" angle from arriving on the site. ras marked with control number 752-3. During the reinspection of the installed j hangers, I attempted to trace the material certifications for l control number 752-1. I found that material certification for control number 752-1 did not exist. However, I did find material certification for control number 753-1 under traveler number F-4106. Exhibit III g i 7 lk _ f. ' .~ ~-- . y.9, s g.~.n. s -m
l -p ~ i I believe the problem was caused by whomever prepared the traveler, as the 758-1 was hard to distinguish from the number 752, and f therefore the numbers were transposed from an 8 to a 2 on all materials for that control number. I called this problem to the attention of my supervisor, MIKE D'HAME. The Quality Control Manager for Zack at the Midland Site. D'HAME told me to change l all of the numbers of the travelers for the angel iron from 752 to 758, and then to go to the laydown and change the control -l ) numbers on the materials from 752 to 758. l B. During the reinspection I found 3" X 5# channel iron to be marked with the control number 801-2. When I went to find the material cergificationsforcontrolnumber801-2,Ifounditwasfor4"XI informed D'H l 5.4 channel iron. i se to call HARRY GEYER at the Zack Company in Chicago. I tele-GEYER sent me a phoned GEYER and described the problem to him. note, stating, "Ron Milne, Cert for 3 X Si channel which was shipped on Traveler # F4106." I referred to traveler F-4106. I found four pieces of 3" X 5" channel iron was shipped under that travelgrandthetravelerdidnothaveacontrolnumberforthe Immediately above the entry on the travel for i 3" X 5 chganel. channel iron was the control number 801-2 fog 4" X 5.4, j the 3" X 5 The material certification for the 3" X 5 channel channel iron. iron sent to se with the note by GEYER was from the Calumet Steel Company, Chicago Heights, IL. This certification showed the Zack control number of C-666 with an order date of April 3, 1978. The date on traveler number F-4106 was May 9,1979 and the material i was receipt inspected at the Midland Site on may 10, 1979. I informed D'HAME of these discrepancies. D'HAME told me to change the control numbers on the channel iron from 801-2 to C-666, and to also change the control numbers on the travelers. D'HAME also told et to destroy the note from GEYER. I intend to use GEYER's note to cross-reference the material certifications on the travelers and on the non-conformance reports. Both of these examples involve nuclear safety systems. I cannot understand l how the changing of the control numbers on either the traveler or on the ^ material would iasure total material traceability. ] Mr. Weil has assisted me in the preparation and typing of this statement. I have read the foregoing statement consisting of 2 pages. I have made any I have signed necessary corrections and I have initialed those corrections. This statement is the truth to the best my name in the margin of each page. of my knowledge and belief. (Individual "C") WITNESS: Charles H. Weil Exhibit III i 2-i. il ~' ' Y p ~ "e--w---e> en
1 t (~, 4 g ~ Midland, MI 4/25/80 (Date) I, (Individual "C"), hereby make the following statement to Charles H. Well, t who has identified himself to me as an investigator of the United States Nuclear Regulatory Commission. I make this statement freely with no threats or promises of reward having been made to me. i ? i With refrence to my statement taken 4/18/80 the 2nd & 3rd last sentences of paragraph 2B of my statement are in error. l D'Hame uever told me to change the numbers from 801-2 to RM 666, and he never told me to destroy the note from Geyer. I assumed from Geyer's note I was to change the numbers, but I never did change those i numbers. No one in RM supervision at the site told me to destroy the note from Geyer. The remainder of my statement of 4/18/80 is true & l correct as written. I have read the forgoing statement consisting of 2 pages. I have made all necessary corrections and I have initialed those corrections. I have signed my name in the margin of each page. This statement is the truth to the best of my knowledge and belief. t l I /S/ (INDIVIDUAL 'C') WITNESS: /S/ Charles H. Weil .5 Exhibit IV i ? 'l .h
i s ^ , ws' gg [ ~ j% D I PRINOtPA1. STIJF l'S ArEI pp, Docket Nos. 50-329 ofo i _ DADM ilPAD 50-330 gg EA-80-56 -trr.w u st.o i oIkh rI t.ti The Consumers Power Company /\\ ATTN: Mr. Stephen H. Howell Senior Vice President l 1945 West Parnall Road { Jackson, MI 49201 Gentlemen: During an investigation of activities at the Midland site, which began in March and which continued through July 1980, we found major deficiencies-in Consumers Power Company's quality assurance program, as related to the heating, ventilation and air conditioning con ractor's activities. As a result, we propose to impose civil penalties in the amount of Thirty-eight Thousand Dollars. The items of non:omplian:e are set fortn in Appendix A. The '.otice of Proposed Chil Penalties is attacied as Appendix B. In 1 resp:nding to this matter, you should follo..he instructions in Appendices A an: B. I i The investigation disclosed noncompliance w't, ten of the eighteen different criteria for a quality assurance program, as set forth in 10 CFR 50, Appea. dix B. Major quality assurance deficiencies were found regarding com;iiance with approved pro:edures and pract'.ces during f abrication.and installation, and the overall traceability of materials used for fabri-6 I cation. On March 21, 1980, we issued an Immeciate Action Letter confirm-ing your Stop Work Order in the heating, vent'lating and air conditioning safety-related areas. The significant findings of this investigation were discussed during a meeting between you and J. G. Keppler, Director, Region III and members of the respective staffs on May 2, 1980. The unders andings reached at that meeting were set forth in a letter cated May 22, 1980, from James G. Keppler. Your reply of June 30, 1980, to that letter has been reviewed. Aoditional inspections are being conducted at the site tc follow your progress in correcting problems identified during your in'tial audits and during our investigation of the HVAC contractor. Your response to the enclosed Notice of Violation, and our continuing inspection program will determine I h i t CERTIFIED MAIL RETL,RN RECEIPT REQUESTED { JAN 0 91981 l qb' So dg x u M k w L.i.i.hb L d ~ =~7
~ - t u s Fe-e-Ccek - [ whe'ther additional escalated enforcement action, such as additional civil penalties or orders to suspend construction activities are required to j ensure future compliance. Sincerely, l t
- 0riginni Signed By
" fi& # % 1o,Jr. t Direct $r Office of Inspection and Enforcement i
Enclosures:
1. Appendix A, Notice of Violation 2. Appendix B, Notice of Proposed j Imposition of Civil Penalties Distribution: PDR EDO Reading File NSIC IE Reading File LpDR TIC State of Michigan ACRS (3) ATTN: Hon. Frank J. Kelley SECY Attorney General V. Stello, IE 7th Floor, Law Bldg. R. DeYoung, IE Lansing, MI 48913 l J. Sniezek, IE J. Henderson, IE Department of Commerce D. Thompson, IE Public Service Commission CA ATTN: Daniel J. Demlow F. Ingram, PA Chairman J. P. Murray, ELD Long Commerce Park J. Lieberman, ELD P. O. Box 30221 K. Cyr, ELD Lansing, MI 48909 J. Crooks, OMPA J. J. Cummings, CIA Department of Public Health Enforcement Coordinators: Division of Radiological Health Regions I, II, III, IV, V ATTN: Donald E. VanFarowe D. Hood, NRR:LB3 Chief IE Files 3500 N. Logan St. bN pM. b i Central Files Lansing, MI 48909 l CP Book E.iE. hfEUS EI Reading File 12.-11-9 0 EI:I LD D:EI E DIA D: h. d ' t JRiesland J son KCyr DT son R oung VS el'l 1/Q/80 12//N80 12//l /80 12 80 /g/80 6, y./80 12/ ' 6 WPU:JD f.'/ Y F pe c 12/3/80 4 BROCK 6(A) .,';p$e,/ g*- j'pf p' .jf H af. 4' i f p s) 1 7 40' N s s 9A -k? t d d"
i p1 i Appendix A d NOTICE OF VIOLATION i Consumers Power Company Docket Nos. 50-329; ~; (Midland) 50-330 t EA-80-56 i Based on t,he 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 below. 1. 10 CFR 50, Appendix B, Criterion IV (Procurement Document Control), states, in part, that " Measures shall be established to assure that applicable regulatory requirecents, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material..." S ~ Consumers Power Company Quality Assurance Program Policy No. 4 (Procurement Document Control), Revision 8, states that" Assigned Quality Assurance personnel review procurement specifications to verify the adequacy of quality requirements stated therein." The Bechtel Associates " Technical Specification for Heating, Venti-i lating and Air Conditioning Seismic Class I..." (Specification Guide Number 7220-151A(Q), Revision 6, Section 2.0, Codes and Standards), requires that duct fabrication and installation methods, materials, and workmanship shall conform to the ASTM standards. American Society for Testing and Material (ASTM) material specifi-cation designation A527-71, paragraph 3.2, states that orders for material to this specification shall include certain specified information, as necessary, that adequately describe the desired product. The Zack Company Quality Assurance Manual, Amendment I to Section 5, Revision 0, paragraph 3, states that "All Purchase Orders initiated by the Zack Company are subject to review by the Zack Company Quality .j Assurance Department." Contrary to the above, measures did not assure that adequate quality was suit' ably specified in material procurement 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 ..i 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 describe the desired product. i I I p# l. i Y \\ . w.s w A
Appendix A (Continued) 2-I 'l \\ This is an infraction (Civil Penalty - $3,500). 2. 10 CFR 50, Appendix B, Criterion V (Instructions, Procedures, and l' 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, i or drawings ?.." 4 e A. Consumers Power Company Quality Assurance Program Policy No. 5, I (Instructions, Procedures and Drawings) Revision 8, states that I " 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, R vision 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..." i (2) The Zack Company Procedure No.. MB-QCP-7, Revision 2, Paragraph j' l 6.6, states that "in addition to the walder placing his identi-i fication number on his work, this information shall be docu-i 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." i 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 and the accompanying documents indicated that the duct was partially 4 , completed without a traveler. i Review by the NRC inspector during the week of March 17, 1980 I indicated that the installed hanger No. V19-5H1-7 does not 4 resemble the sketch on the traveler (Traveler No. V19-7(1/C893) F938). The original hanger (configuration as shown on the 4 traveler) was fabricated in Zack's Chicano shop. The new hanger (configuration as installed) was 'nstalled without a traveler. 4 Review by the NRC inspector during the week of March 25, 1980 indicated that the sketch on traveler No.- V26-5H1B 11F10807 showed that the angle iron,was welded to a -4" x 5.4" x 45' f I 3: )$ k .b ny, 9, ?,A s , l,3 ? a
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l i. r.. i A;;pendix A (Continued) 3- / channel. The angle iron, as installed, was welded to a channel approximately 7" deep and 2-1/4" wide. t 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, tRe angle l brace was a 2" x 2" angle instead of a 3-1/2" x 3-1/2 x1/4" j angle as required by the traveler. t l 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 l were not recorded. I \\ This is an infraction (Civil Penalty - 54,000). 'l During the period March 17-28, 1980, it was established that ,j the welders' identification was not recorded on the following - -j J travelers: 'l 4 (a) V26-SH2E-46.'.-P1515 V20-SH1B-12-F10802 i (b) V10-428-F10171 V34-SH1-3-F1306 (c) V10-428.1-F10172 V34-SH1-4-F1306 (d) V26-SH2E-47.1-F1516 V34-SH1-1-F9395 i I (e) V26-SH1B-11-F10807 V34-SH1-5-F9396 This is a deficiency (Civil Penalty - 50). E. Consumers Power Company, Quality Assurance Program Policy Number-5 i (Instructions, Procedures and Drawings), Revision 8, states, in part, that Quality Control Procedures also provide additional detailed instructions for carrying out the quality functions. 4 The Bechtel Technical Specification for Heating, Ventilating and Air Conditioning (7220-M-151A-Q), Revision 6, Section 5.18, i - J requires that marking material be Carboline Co. X-1000-90, ) Ameron Co 2032 or Nissen metal marker by Nissen Co. j Contrary to the above, and as of the date of this' investigation,' 4 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 j, contractor. 4 .n g This is a deficiency (Civil Penal.ty - $0). 3. 10 CFR 50, Appendix B, Criterion VII (Control of Purchased Material, 'i~ Equipment, and Services), states that " Documentary evidence that material and equipment conform to the procurement requirements '7 .,. l 3 s. Fi .n .7 - - ~ ~ r- . ~ - * ~
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.l* i.;;;n oi> ; (Cant .ec) 4-shall be available at the nuclear power plant... prior to instal-1ation or use of such material and equipment." ~ Consumers Power Company Quality Assurance Program Policy No. 7, Revision 9. (Control of Purchased Material, Ecuipment, 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." e TheZackComganyQualityControlProcedureMB-QCP-6Rev.3,Sec.5.3, l 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." l Section 5.4 states that " items rejected due to documentation problems i are placed on HOLD until each problem is resolved." l Section 5.9 states that "each shelf within the weld rod issue room... j 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-4 tained thereon." g 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 ioentified by the 37G number. A portion of the rod stored in the warming oven with unknown and/o'r i questionable identification had been issued for use in the field. I i This is an infraction (Civil Penalty - $3,000). I 4. 10 CFR 50, Appendix B, Criterion VIII (Identification and Control of I 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 itet, as required throughout fabrication, erection, installation, and use of the item..." 1 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 QA 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 a l h 1 n m 3 t.. + e s
i A;4en::ix A (Con e::) - l with the traveler number placed on all sub-component parts, the traveler shall be identified with the control numbers to. insure the traceability of the material, and to prevent intwrmingling of incorrect material. All identification (control number and/or traveler number) shall remain on the i t-avelers and component parts throughout 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 beah placed on the material, and thgt the material has been properly identified with its control number..." Contrary to the above, measures did not assure the identification -l of safety related HVAC components throughout fabrication, erection and installation as evidenced by the following: i Duct No. V26-SH28-46.1-P1515, prior to March 21, 1980, (a) did I 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 controls No. 929 and No. 727-2,. but only angle iron control No. 929 was recorded on the ~ _ _ -. - traveler; and (c) the coil control number was recorded on the traveler as 383, but the control number was not on the item. i j Duct No. V26-SH28-47.1-1516, prior to March 21, 1980, did not i have either the traveler number or the control number identi-l fied on all of the sub-components. I Hangers No. V26-SH18-11F10807 and No. V26-SH18-12-F10802, as of 4 I March 28, 1980, (a) did not have the angle iron control number j recorded on the traveler; (b) did not have either the traveler number or the control number identified on all the sub-components; and (c) had angle iron marked V26-SH18-11-F10807 installed on hanger number V26-SH18-12-F10802 and vice versa. Hanger No. V19-0(3/C898) F940, as of March 28, 1980, did not l have either the traveler number or the control number identi-fied on all of the sub-components. 1 Hanger No. V19-11(6/C898) F942, as of March 28, 1980, (a) did not have either the traveler number or the control number identified on all of the sub-components; and (b) was fabricated Ji with two pieces of angle iron marked with control number 887, when the control numbers recorded on the travelar 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-components; and (b) was fabri-cated with one piece of angle iron marked with control number 887, when the control numbers recorded on the traveler did 4 - not include number 887. 4 3
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e Appendix A (Continued). I Hanger No. V19-5H1-7, as of March 31, 1980, (a) did not have either the traveler number or the control number identified o.' all of the } sub-components; and (b) was fabricated with an angle iron marked with hanger number VI-3 (9/C886) F916. During the week of March 17, 1980, an NRC inspector found numerous I sections of angle iron stored in the Poseyville laydown area wert without identification. t I 4 Hanger No. V1-3 (7/C886) F916, as of March 31, 1980, did not have 1 I either the traveler number or the control number identified on all sub-components. During the period March 17-20, 1980, an NRC inspector found a large i 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. V10-428-F10171 l (3) Duct No. V10-428-1-F10172 (4) Duct No. V3-SH2-20-F12685 This is an infraction (Civil Penalty - $4,000). 5. 10 CFR 50, Appendix B, Criterion IX (Control of Special Process), states, " Measures shall be established to assure that special processes, including welding, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, j specifications, criteria, and other special requirements." i ConsumersPowerCompanyQualityAssuranceProgramPolicyNumber9(Control of Special Process), Revision 8, states that For such special processes as welding, where the required level of quality cannot be measured by inspection only of the ites, Consumers Power, its Suppliers, and their lower tier Suppliers, accomplish these processes under controlled condi-tions in' accordance with applicable codes, standards, and specifications using qualified procedures, equipment and personnel." A. The Zack Company QA Manual, Section 10, Revision 0, states that "It shall be the responsibility of the Quality Control Inspector to insure that all welding shall be perfomed by only those welders who i have been qualified for this work, and that each qualified welder uses the established welding procedures for the work." I Contrary to the above, prior to March 31, 1980, measures did not assure that welding was accomplished using qualified procedures, as evidenced by the fact that: 1: 74 1 t, ,i 1. .. y s. .- -. b. ~~~- ~- - - - - - - - - ~ - - , ~ -
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I A shielded metal arc welding process was shown on the travelers, but a gas metal arc welding process was used in the fabrication of the following items: (a) Duct No. V26-5H28-46.1-P1515 (b) Duct No. V10-428-F10171 i + i (c) Duct No. V10-428.1-F10172 t e j t (d) Duct No. V26-$H28-47.1-P1516 j (e) Duct No. V3-5H2-2D-F12685 )i Travtlers for ducts No. V34-5H1-F9395, No. V34-5H1-5-F9396, No. V34-5H1-4-F1306 and No. V34-SH1-3-1306 stated the welding } l procedure to be used was Number QCP-1-P5C5. This procedure i requires the use of carbon dioxide as the shielded gas. Dur-ing the week of March 25, 1980 individuals advised the inspector that carbon dioxide was not available at the Midland site, and i therefore this procedure was not followed in performing these welds. i j This is an infraction (01 11 Penalty - 53,500). l } B. The Zack Company Quality Control Procedure MB-QCP-6, Rev. 3, i i requires in Section 5.12 that " issuance and return of weld filler metal is controlled through the use of a Filler Metal Withdrawal I Authorization form which is maintained with issued material from l the time it is issued and until it is returned." Section 5.13 j requires that " low-hydrogen electrode is issued in portable rod wamer caddies. Eacn caddy is energized (i.e. plugged in).at all 4 l times, except when in transit to and from the location at which welding is performed." Section 5.14 requires that " holding ovens j and portable rod warmer caddies are to be maintained at the temp-i eratures specified in AWS D1.1-79, Section 4, paragraph 4.5... 4 their temperature is checked by a-QC Inspector once every two (2) j months and documented on the Rod Oven Temperature Check form..." 4 l Contrary to the above, procedures to control weld filler metal at the Midland construction site were not followed as evidenced by i the fact that: 1 ^ On March 12, 1980, a rod warmer caddy in the welding i booth area of The Zack Co. fabrication shop was not r 1 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 1 the portable rod warmer caddies disclosed temperature records did not exist for two caddies. The temperature records for two j-other caddies indicated the temperature for those two caddies was last checked prior to November,1979. s '?
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o l'* i Appendix A (Continued) ' This is an infraction (Civil Penalty - $3,500). 1 C. Consumers Power Company Quality Assurance Program Policy No. 9, I (Control of Special Processes), Revision 9, dated March 18, 1980, Section 3.1, Process Qualification and Control, states that "when j performed by a supplier, the requirement to perform special processes [ in accordance with applicable specifications, codes, and standards, l 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 Subcontractor shall submit written 'I 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 Compary qualified and approved welding procedures." The Zack Company welding Procedure i Nucer MB-QCP-1 (P-5CS), Revision 2, requires that (1) base mett.1 l conform to the specifications for SA414, Grade A, and that l' (2) welding be of material in the thickness range of 1/16 (0.0625) inch to 3/16 (0.1875) inch. The procedure was actually qualified to .s i j 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 evidenced 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 M8-QCP-1 (P-5CS) was used to fabricate ducts No. V34-SH1-1-F9395, No. V34-SH1-5-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-SH2B-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 Conformance, dated November 5, 1979, the Air Monitor Corporation welded air monitors without prior buyer review and acceptance of welding procedures. The air monitors l. were subsequently received onsite. ? i.! a j +
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,,-..::6,0;> A (Cer.tir.uec. E-i. This is an infraction (Civil Penalty - 54,000). D. Section 6.9 of the Zack Company Quality Control Procecure MB-QCP-3, Revision 2 requires that when safety related welding has been completed, the welder who performed the work shall mark j each weld he has made with his welding symbol number. j Section 6.5 of the Zack Company Quality Control Procedure MB-QCP-7, Revision 2, requires that upon completion of a welding activity, 1 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 i identification number. This is an infraction (Civil Penalty - 53,000). 1 I I E. Paragraph 4.1.7 of the Zack Company Quality Control, Procedure MB-QCP-3, Revision 2, requires that when a welder has seen tested i and qualified to weld on this project, he will be assigned a unique wel:er I.D. stamp and this stamp,eill not be reassigned to any j other individual. Contrary to the above, during the period February 2E - March 20 1980, two qualified welders were assigned the sa:ne held stag, No. CU7. This is an infraction (Civil Penalty - $3,000). c 6. 10 CFR 50, Appendix B, Criterion X (Inspection) states that "A program for inspe: tion of activities affecting quality sna*1 be established and executed by or for the organization perfcvin; the i activity to verify conformance with the documented instrt.:tio.s, pro-cedures, and drawings for accomplishing the activity... Consumers Power Company Quality Assurance Program Policy Neiber 10 (Inspection) Revision 8, states that " Inspection and surveillance are performed to assure that activities affecting quality coc1y 4 with documented instructions, design documents and applicable i codes an'd standards." i A. The Zack Company QA Manual, Section 6. Revision 0, states that "... Procedures have been established for... inspection..." Contrary to the above, review of ir.structions and procedures 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.
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Appendix A (Continued) ~ i This is an infraction (Civil Penalty - $3,000). i 8. Bechtel Specification No. 72220-N-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 i i extgrnalsurfacesofcompletedweldsbeexaminedforundercutting. I i Contrary to the above, the program for inspection was not adequate i to assure compliance with applicable specifications as evidenced by I 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 I accepted by Zack QC on February 15, 1980. i j This is a deficiency (Civil Penalty - $0). 7. i 10 CFR 50, Appendix B, Criterion XV (Nonconforming Materials, Parts, or Components) states that " Measures shall be established to control ' l materials, parts, or components which do not conform to requirements in j order to prevent their inadvertent use or installation..." 4 l Consumers Power Co.t.pany Quality Assurance Program Policy Number 15 (Nonconforming Items), Revision 8, states that, "... Nonconforming } items (structures, systems components, parts, materials) are identified j by marking, tagging, segreg,ating, or by documentation..." A. TheZackComE'.".YQ"* lit Y ^55"r*"c' M*""*1' 5**ti"" 18 "*vi'i"" ' states that .when it is determined that a nonconfor'mity exists', it shall be tagged with a nonconformance tag by the Quality, Control j Inspector who then shall initiate a nonconformance report..." Contrary to the above, measures which would prevent the inadvertent i use or installation of nonconforming materials had not been estab-lished as evidenced by the fact that: l Duct No. V03-5112-2-F9437 was fabricated to Seirmic Class 2 requirements instead of the prescribed Seismic Class I require-ments. As of March 21, 1980 a nonconformance report was not initiated for the duct fabricated to the requirements of Seismic i Class 2. a { 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 nonconfoming. F This is an infraction (Civil Penalty - $3,500). l 8. Paragraph 6.3 of the Zack Company Quality Control Procedure MB-QCP-8, Revision 2, states l f r 3 i ... ~. l-1 3,. , x 4e Qw. ~ @W w ..u .,~
- ~
~ t Appendix A (Continued), 1 r "In conjunction with initiatir.g' the NCR form, the QC inspector initiates a yellow nonconformance tag (s). The hard copy is j attached to the nonconforming item (s) and the soft copy is I attached to the NCR form. / Each tag identifies the itee by name, piece mark and item number. The yellow nonconformance tag, by it's application, flags the item as prevents further work on or with the item." ponconforming and l ) Contrary to the above, during March and April,1980, non-conformance l tags had been applied to Ruskin NI8023 fire dampers without explicitly J 1 identifying the item by name, piece mark, and item r.ueber. 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. j Thisisaninfraction(CivilPenaltyiS3,000)._,_..__ j 8. 10 CFR 50, Appendix B, Criterion XVI (Correctiv'e Action), states " Measures shall be established to assure that conditions-adverse t: cuality, such 4 4 as... nonconformances are promptly identifisc'and cor acted." s i Section 3.0 of Consumers Power Company Quality Assuren:e #rogram Policy j Number 16, (Corrective Action), Revision ~8 statet taa '"crrective j t action is initiated to correct conditions adverse to qua'ity of items and i activities." Section 3.4 states that " suppliers... wh: perfore services i for the nuclear plant, implement and follow a systelt for :ctrective action according to the Supplier's approved procedures.", a j A. Contrary to the above, during the ' period May 23 - On.r.ber 2,1979, none of the seven non-conformance reports genersted sy the Consumers 4 Power Company had been promptly corrected as evicen:ec ty.tte fact i ] that as of March 19, 1980 they had,not been c1cses cut. e I This is an infraction (Civil Penalty - 54,000). i 8. The Zack Company Quality Assurance Manual, Sectic, *.6, Revision 0, dated February 2$, 1979, states "The site or plant taality Control Inspector shall be responsible for inspecting tne material ca equip-merit as it is received... Items placed on "H3LD" will be for deficiencies found in receipt inspection, e.g.: 1. No material j certification..." t 4. Contrary to the above, measures were not adequate to assure that i conditions adverse to quality were promptly identified, as evidenced .l by the fact that: 1 Review of the Zack Company (at; t.6 Midland site) noncompliance i 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 6,19Y9, lacked a material / 6l ', _ Al % a c h a
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i l Appendix A (Continued) l u I certification and were nct placed on HOLD until Mar:h 11, 1980. The remainder of this weld rod, 450 pounds in 9 boxes, was not f placed on HOLD and its use is unknown. l 250 pounds (5 boxes) of 3/32" diameter, low hydrogen 7018, g welding rod, received at the Midland Job Site on De: ember 15, i 1979, were not marked as nonconforming for being "icproperly l boxed" until March 11, 1980. 7 This is an infraction (Civil Penalty - $3,500). [ 9. 10 CFR 50, Appendix E. Criterion XVII, states that, "Sufficier.t records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the following: Operatir.g togs and the i i results of reviews, inspections, tests, audits, monitoring of work i I performance, and material analyses... Records shall be ide.tifiable i and retrievable." i Consumers Power Company Quality Assurance P-ograr Fo* icy N.iber 17, i (Quality Assurance Records) Revision i, Section 1, states thst " Consumers Power and its Sugpliers comp,ile recorcs as specified tr. ap;11:able 4 1 procedures... + The Zack Company Quality Control Prc:e:ure I'.B-QCP-21, Res. 3, site procedure for inspecting installation of equipment, recuires nat the construction site quality cent ol inspecter is resporsibie fc-in process inspection and documentation cf all iters being insta11ec and for final i inspection of equipment installed. It furtner sta,es "tr.at t ese fun:tions ,i l will be documented on the following fcam: Quality Centrcl Su-vey Report i Form No. 4." Contrary to the above, sufficient recc-ds te furnish evice ce of activities i affecting quality were not maintained as evidenced by the fact that equipnient installation inspection recc-ds did not exist for t e safety l related fire dampers installed during the period November,1979 - January, 1980. This is an infraction (Civil Penalty - 13,0*0). ,L"
- 10. 10 CFR 50, Appendix A, Criteria XVIII, states that "A corprehensive
'*l, 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 .;p perfomed... by appropriately trair.ed personnel not having direct responsibilities in the area being audited." Consumers Power Company Quality Assurance Program Policy Nam , V, ' (Audits), Revision 9, Section 1, states that "... Audits to ver i f compliance to the requirements of the nuclear plant Quality Assurance ) Program are conducted by qualified personnel who have no resp:nsibilities 4 in the areas audited'..." l l' r 3l 'm >4 f \\ ~ .a a. 9 j,y to >. ~ o
e ^ . t Appendix'A (Continued) 13 - L b9, The Zack Company Quality Assurance Manual, Section 19, Rev. O, states J< 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 qpt by personnel with direct responsibilities in the area being audited. Mr. Ed Thompson, Zack Codhany QA Manager and Mr. H. Geyer, Zack Company Project QA Manager, performed an aucit on j 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 s at the Midland site in December 1979, a period incluoed in the audit. This is an infraction (Civil Penalty - $3,000). i 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), i.. m ? at the time of these items of noncompliance, tha 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-eignt Thousand Dollars ($38,000) are proposed. This Notice of Violation is sent to the Consumers Power Company pursaant to the provisions of Section 2.201 of the NRC's " Rules of Practice," pa-t 2, Title ~10, Code of Federal Regulations. In determining the am:, ant cf civil penalty for each item of noncompliance, a penalty of $3,003.was proposed for infractions involving on'e example.. An additional $500 was proposed for those i infractions involving two examples.. For infractions involving three or more examples, 'the maximum civil penalty for infractions, $4,000, was presosed. In one instance, the maximum civil pet.sity for an infraction was prcoosed because of the more serious nature of the item of noncompliance. The tensumers Fower Company is hereby required to submit to this office; within twenty-five (25) days of the date of this notice, a written statement or explannion in reply, including for eac;. ii.r.: of noncompliance: (1) admission or cenial.of the alleged item of noncompliance; (2) the reasons for the item of noncom-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.be achieved. . 3 1 T A ^%, f._.e u c \\ 4 , - i + s ' +~ h ? 7 ^y .O y 4 st _. m_#..gg. k. t\\ ) 5 ' I) k j,* I .k '. M/
.. ~,.. - ,C0 Appendix B NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES l .j Consumers Power Company Docket No. 50-329 EA-80-56 Docket No. 50-330 j i l This office proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (42 USC 2282), and to 10 CFR 2.205, in i j the cumulative amount of Thirty-eight Thousand Dollars ($38,000) for the specific items of noncompliance set forth in Appendix A to the cover letter. In proposing to impose civil penalties cursuant to this section of the Act and in fixing the proposed amount cf the penalties, the factors identified in the Statements of Consideration published in the Federal Register with the rulemaking action which adopted 10 CFR 2.205 (36 FR 16894) August 26, 1971, and the " Criteria for Determining Enforcement Action," whi:h was sent to NRC i licensees on December 31, 1974, have been taken into account. The Consumers Power Company may, within twenty-five (25) days of the date of this notice, pay the civil penalties in the cumulative amount of Thirty-eight Tnousand Dollars (538,000) in whole or in part by a written answer.or may pretest the ir. position of the :"vil penalties i Shoule the Consumers Po tr Company i fail to answer within the time specified, this office will issue an orcer i.T.pering the civil penalties in the amount proposed above. Should the f Consumers Power Company elect to file an answer protesting the civil penalties, such answer may (a) deny the items of noncompliance listed in the f.otice of i Violation in whole or in part,-(b) demonstrate extenuating circumstances, (c) sho error in the Notice of Violation, or (d) show other reasons why the penalties should not be imposed. In addition to protesting the civil" penalties in whole or in part, such answer may request remission or mitigation of the penalties. Any written answer in accordance with 10 CFR 2.205 should be ' set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.2C1, but may incorporate the statement or explanation by specific reference (e.g., giving page and paragraph numbers) to avoid repetition. The Consumers Power Company's attention is directed to the other provisions of 10 CFR 2.205 regarding, in particular, failure to answer and ensuing orders; answer, consideration by this office, and ensuing orders; request for hearings, hearings and ensuing orders; compromise; and collection. Upon failure to pay any civil penalty due, which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, the-matter may be referred to the Attorney General and the penalty, unless compro-5 mised, remitted or mitigated, may be collected by civil action pursuant to ? Section 234c of the Atomic Energy Act of 1954, as amended (42 USC 2282). m I + 0 ,t / J C,lf)fM- ;\\ s M/ / j i s N y r my ' 7 y i n ?Q + W 9: - 1 X 9&% $ ' ', t',
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( ( !$% 17 N. I Docket No. M Docket No. 50-330 ) Consumers Power Company ATTN: Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 Gentlemen: } l This refers to the inspection conducted by Messrs. R. J. Cook, E. W. K. Lee, R. N. Sutphin, and T. E. Vandel of this office on July 16-18, 1980, of activities at the Midland Nuclear Power Plant Construction site authorized by NRC Construction Permits No. CPPR-81 and No. CPPR-82 and to the discussion of our findings with Mr. J. W. Csok, Vice President, Midland Project, D. B. Miller, Site Manager on~ July 18, 1980, and Mr. W. R. Bird, QA Manager, Midland Project on August 6, 1980 at the conclusion of the inspection. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and_ representative records, observations, and interviews with personnel, During this inspection, certain of your activities appeared to be in non-i compliance with NRC requirements, as described in the enclosed Appendix A. Based on our inspection findings and sur general understanding of the i corrective actions you intend to take.in connection with the noted item of compliance, we are satisfied that the provisions in our letter of March 21, 1980 have been satisfactorily completed. Your staff was informed of this on August 14, 1980. This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2 Title 10, Code of Federal 3egulations. Section 2.201 requires you to submit to this office within thirty days of your receipt of this notice a written statement or explanation in reply, including for each item of noncompliance: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Be sure to address each of these items in your response. 3 I, .f
SEP 1 'I sea Consumers Power Company In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document t Room, except as follows. If the enclosures contain information that you or T e your contractors believe to be proprietary, you must apply in writing to l this office, within twenty days of your receipt of this letter, to withhold such information from public disclosure. The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the
- application is contained in an enclosure to the application.
We will gladly discuss any questions you have concerning this inspection. i Sincerely, I t l James G. Keppler Director
Enclosures:
1. Appendix A, Notice of Violation 2. IE Inspection Reports No. 50-329/80-21 and No. 50-330/80-22 cc w/encls: t Central Files Reproduction Unit NRC 20b PDR Local PDR NSIC TIC ~ Ronald Callen, Michigan Public Service Commission Hyron M. Cherry, Chicago e RIII RIII- 'RII / RIII RI I .RIII Vandel/np Knop # Fio lli qll' p 4 ag Sutphin f4 qi I Cook Daniels a 9/9/80 ?- l T/"/8" RIII $1-k i ~ EWK Lee ^! .=
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(, Appendix A NOTICE OF VIOLATION Consumers Power Company Docket No. 50-329 f i Docket No. 50-330 i Based on the results of an NRC inspection conducted on AuFust 4-6, 1980, it appears that certain of your activities were not conducted in full ' compliance with NRC requirements as noted below. This item is an infraction. 10 CFR 50, Appendix B, Criterion XVIII, states, ic part, that "A com-prehensive 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 Zack Company Quality Control Manual, Section 19, s'tates, in part, j " Audits will be performed as follows:... Vendor / Supplier and Sub-contractor - Per the requirement of the contract." Contrary to the above, it was established on August 6,1980 that suffi-cient records could not be exhibited to establish that an audit had been performed of Photon Testing, Inc. or that a contract existed prior to August 11, 1980 for qualificatman of Zack Company welders. i 9 1 ,/ 0 g9 \\ p3 4 y: L. s
~ (' (, U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III { Report Nos. 50-329/80-21; 50-330/80-22 Docket Nos. 50-329; 50-330 License Nos. CPPR-81; CPPR-82 Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland, Units 1 and 2 } Inspection At: Midland Site, Midland, Michigan j Inspection Conducted: July 16-18, August 4-6, 11-14, 1980 Inspectors
- T. E. Vande
[ E d E. W. K. Le' // k/h4 } R. Sutphin 7 0 2//u R. J. Cook. Approved By: R. C. Knop, Ch f f? /D Projects Section 1 Investigation Followup Inspection on July 16-18, 1980 (Report Nos. 50-329/ 80-21; 50-330/80-22) Areas Inspected: Review of the heating and ventilating contractor (Zack - Company) Quality Assurance program manual, quality assurance / quality control procedures, as well as work procedures, welding procedure speci-fications; and review of Zack activities relative to program corrective i action. Thi inspection involved a total of 95 inspector-hours on site by four NRC inspectors. Results: One item of noncompliance was identified. (Failure to perform audit - Section II, paragraph 8) -i \\/' (
(' ( i DETAILS i' Persons Contacted l Principal Licensee Employees
- J. W. Cook, Vice President Midland Project
- T. C. Cooke, Project Superintendent
- *W. R. Bird, QA Manager Midland Project
- *D. R. Keating, Section Head, IE&TV
- D. B. Miller, Site Manager
. M. J. DeWitt, QA Engineer
- , G. B. Johnson, Project Management Organization, Field Engineer Eechtel Power Corporation (Bechtel)
- D. R. Appel, Engineering Ann Arbor
- *W. J. Creel, QA Engineer
- *L. S. Dreisbach, Project QA Engineer j
- *J. E. Russell, Assistant Project QC Engineer
- D. H. Puchy, M&QS Ann Arbor
- R. K. Siple, QC Engineer M. A. Dietrich, QA Engineer
, D. F. Pierce, Subcontracts Department C. W. Cross, Subcontracts Inspector Zack Company (Zack)
- C. L. Eichsthedt, Jr. Vice President / Operations Manager
- *M. E. D' Haem, QC Manager R. B. McCorley, Site Manager
- Denotes those present at the exit interview on July 18, 1980.
~
- , Denotes those present at the exit interview'on August 6, 1980.
Other licensee, Bechtel, and Zack personnel were contacted during the inspectien. Functional er Program Areas Inspected The functional or program areas that were inspected are delineated in Sections I and II of this report. 4 ? k i i ~* + J ji
4 t SECTION I Prepared by E. W. K. Lee Reviewed by D. H. Danielson, Chief I' Engineering Scpport Section 2 I 1. Review of Quality Control Procedures The inspector reviewed twelve Zack Company field quality control procedures relative to the installation and fabrication of heating, ventilating, and air conditioning components. The procedures re-l viewed included document control, training, storage, installation, fabrication, material control, inspection, and testing. It was i determined that 10 CFR 50, Appendix B, and FSAR requirements were met. No items of noncompliance or deviations were identified. 2. Review of Welding Procedures i The inspector reviewed the following Zack Company procedures: Procedure No. WPS-1, Revision 3, " Weld Procedure Specification a. i for Gas Metal Arc Welding (Short Circuit) of Zinc Coated Struc-tural and Sheet Steel" b. Procedure No. WPS-2, Revision 1, " Welding Procedure Specification for Shielded Metal Arc Welding of Zine Coated Sheet and Structural Steel" Procedure No. WPS-7, Revision 1, " Welding Procedure Specification c. for Qualification / Certification of Welders Using GMAW, SMAW, CAW Processes" It was determined that the AWS Code requirements were met; however, the inspector is concerned about the format and contents of the procedures'(i.e., range of welding parameters are not stated in the procedure and two types of coated electrodes are covered in y one procedure) which can easily lead to procedure' violations when production is resumed. No items of noncompliance or deviations were identified. O
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d l SECTION II Prepared by R. J. rook R. Sutphin T. Vandel )f Reviewed by R. C. Knop, Chief l Project Section 1 { 1. Zack Quality Assurance Manual Review i Zack Quality Assurance Manual (ZQAM) \\ i The intpector checked on the status of the Zack Quality Assurance i Manual and reviewe'd its contents. The manual dated July 11, 1980, 8 was reviewed and approved by Bechtel Power Corporation on July 11, 1980. It was also reviewed and approved by J. Corley,' for CPCo, and recorded in his letter of acceptance dated July 15, 1980. The - manual-includes a section on each of the 18 criteria of 10 CFR 50, Appendix B. The inspector noted that a policy statement was not l included in the manual and that details for the control.of the manual j and for revisions of the manual were not included. A representative I from Bechtel advised that a policy statement had been presented with i an earlier draft of the manual ar.J was on record and the procedures for control and revision of the manual would be included in Zack PCQP-7, Document Control, which was in the draft stage. The manual meets nominal minimum requi'tements for a quality assurance policy manual provided appropriate measures are included in PQCP-7 for the control of distribution and revisions of the manual. i 2. Consumers Power Company Overview Activity Consumers Power Coupany has developed overview inspection programs for the installation of HVAt' systems. Since the investigation of Zack by the NRC, Consumers Pever Company h&s conducted three over-view inspections pertaining to reinspection efforts and receiving - and storage by the Zack Company. 'These overview inspections were conducted on May 12, 1980, June 5, and July 2, 1980. Some discrep-ancies were noted during the June 5,1980 overview inspection. No discrepancies were noted during the other two overview inspections, t To enhance the over-inspection capability of Consumers Power Company, an independent inspection firm (Conam) was contracted to perform QC inspections of Zack work activities. Consumers Power Company generated an internal meno stating that the Conas personnel would be certified in accordance with Procedure No. B-3M, " Qualification Certification of Inspection and Test Personnel;" that Conam per-sonnel would not be used in the field to cover work unless properly certified; and that on going ~ work-will not proceed in an area for , j* 4.= 7 's .s 2 g-m.- ,s
~ C C ) which Conam have responsibility until certification has been j - completed for the activity being covered. All Conam personnel on site were qualified and certified to perform inspections prior to Bechtel Power Corporation authorizing resumption of work by the Zack Company on August 14, 1980. l 3. Zack Organization Review I j The inspector reviewed selectively the plans, procedures, records, and results to date of the Zack training, qualification, and re qualification activity. Three categories of personnel at two locations are involved, i.e., quality personnel, cognizant ~ production personnel, and welders - both at the site and at the r Zack plant in Chicago (Cicero). The review indicated that the program at the site was adequate and progressing at a satisfactory rate. All of the I.evel 1 and below quality personnel had completed j training in the new QC procedures that had been released. Cognizant l production personnel training was in process and essentially completed. Welders were being requalified and/or qualified in new welding procedures. Additional training is anticipated to cover approximately six new QC procedures yet to be released. Records of training at the Zack Company plant were not available for review. CPCo QA personnel were monitoring the training program for adequacy. I Selective training for closing out: corrective action requirements from NCR's is also anticipated. An audit of training at the Zack Company plant will be conducted by the licensee. i Management at the site reafYirmed during the exit interview all i necessary training for personnel associated with the Zack work will have been satisfactorily completed prior to their participation in work activity on safety related HVAC systems. j 4. Material Reassessment _ Review a. Drop-in Anchor Bolts During the follow up review of activities initiated to rectify QA/QC discrepancies noted during an investigation of the Zack Company, the Resident inspector examined the mechanism for - identifying the location of those. drop-in type anchor bolts which may have been installed using improper test criteria. i A listing of suspect areas.where anchor bolts of questionable. - 3 integrity may have been used was generated.. This listing was comprised of the Auxiliary Building at elevations 568, 584, ~ I 599,-614, 632-6, 634, 659, 674-6,'685; pipe chases, evaporator building, and turbine building I-and II. The list appeared to be based on HVAC construction activities which may have trans-pired at the time when the questionable drop-in anchors were used and cade available on site. However, this could not be rigorously determined by the inspector. Each blueprint for' 4 each of the areas on the listing was compared to the "as 9 s - 3.' 1l + J 'T -iJi'
s._.- installed condition" for each hanger and a determination was i made by Zack (and noted on the blueprint) for the location of the questionable anchors and other pertinent information pertaining to the hanger installations. From this information, + a-" log book" list was generated which would identify t. angers by number and/or location and class which had the questionable anchor bolts installed. The blueprints used for the field 4 inspection work were retained. This was confirmed by the NRC .i by examining three randomly selected blueprint numbers. The information for the location of questionable drop-in anchor bolts was submitted to Bechtel Power Corp. for input into the overall site evaluation for the use of drop-in anchor bolts, j Bechtel Power Corp. has not yet submitted a resolution for'the use of drop-in anchor bolts. This was noted by the inspectors during the Exit Interview. Also. <hring the Exit Interview, the inspectors stated that the casu, for the listing which identified areas where suspect .- - - -- drop-in anchors may have been installed could not be concretely { established. Therefore, it could not be determined that every i questionable drop-in anchor bolt had been located. The l inspectors stated that a conscious and documented determination needed to be performed for each area of the plant with HVAC systems as to whether the su'spect drop-in anchor bolt:s could exist in an area, and if they could not exist in an area --- why not. b. Welding to 3/4" and Above Base Metal 4 Consumers Power Company Nonconformance Report No. M-01-4-9-083 identified that HVAC hangers and/or supports had been welded to alloy steel structure members with cross sections greater than 3/4 inch using E-6011 electrode without preheat. As a partial resolution of the nonconformance, a reinspection by Zeck vaa performed to determine those hangers which had been welded to the thicker cross sections. Areas chosen for-reinspection appeared to be based on determining those areas which would have contained thicker cross section structural steel. However, similar to the above discussion, it could not be determined by-the NRC that every area had been evaluated to establish that thicker cross section steel did or did not exist in the area - with HVAC systems. I The results of these inspections identified those hangers in the areas inspected which had been welded to structural steel. I greater than 3/4 inch thick..The hangers-involved were listed in a separate " log book" by hanger number. The results of these inspections were submitted to Bechtel Power Corporation 'f, <6- -l i ( y y[_ k-U?^ ,o S', , lf
s, for evaluation. Bechtel Power Corp. has not completed the 1 evaluation of welding to thicker cross sections using E-6011 1 electrode without preheat. This was noted during the Exit j Interview. 4 Also, during the Exit Interview, the inspectors stated that an 3 1 2 assurance needed to be developed which would indicate that every ? t area containing thicker cross section structural steel and HVAC i l systems had been identified and the affected hangers / supports identified.' This concern of welding to thicker cross section material without preheat was extended to those non-safety + related hangers / supports which may have been attached to j affected safety related structure steel. As a condition of the Zack Company resuming work, Consumers Power Company directed Bechtel Power Corporation that "all reinspections must be specifically identified, evaluated, and when necessary, accomplished and findings dispositioned, before new work may proceed. This activity is to include any - { -- - sir.ey a.ivu. required in response to consumers Power Company NCR's, Bechtel Deviation Reports, and Zack NCR's... Also to be included in this evaluation is the welding by Zack of non-Q items to Q structures, particularly in the area of pre-heat requirements for thicker sections of materials." The purpose of this directive was to assure that the Zack Company would conduct necessary reinspections and assess the' impact of proposed new" work on unresolved discrepancies and to assure accessibility of previously installed items requiring rework. This directive was transmitted to the Zack Company by Bechtel i Power Corporation on' August 14i 1980 when Bechtel Power 4 I Corporation premitted Zack to resume safety related work. c. Hanaer Reinspection A portion of the resolution of the QA/QC discrepancies noted during the investigation of the Zack Company requires a 100% reinspection of installed safety related hangers. -To deter.aine _ the affected hangers, each Zack Company drawing used for hanger location (and type) was reviewed by Zack7and a listing of each safety related hanger was developed and retained in a separate " log book." From this " master listing," and as a part of the~ inspection process, the " traveler"'for each hanger is locat;ed -and the necessary QC documentation is verified with any dis- "crepancies being noted.. Subsequent to the-QC documentation review, the hanger is inspected using the drawings, and the: discrepancies noted on Nonconformance Reports. Entries are o made to the " master list" indicating the status of. inspection _l and applicable nonconformance. reports. Errors in the " master list" are note ' on an errata sheet retained in the " log book"- l j 7 '- j s _.i-f* -+ -m', --m ~ ,O ); r l~y ; w J, _j ; n Y u.._ bi bY h>d' ", );, f;,^:1L -.g a-m +~ 4 3.
h j with the " master list." Approximately 1300 hangers are noted z-on the " master list." Of these 1300, approximately 40% have j been reinspected. All aspects of documenting and determining the reinspection status of the safety related duct hangers was reviewed by the NRC inspectors. ? l S. Reinspection Overview I. a. Bechtel Corporation QC Bechtel Subcontractor Quality Control has direct responsibility for overinspection of Zack Company QC activities, and surveillance .i inspections are performed by two Bechtel QC inspectors designated to overinspection of HVAC installation and/or repair. Project Quality Control Instruction No. SM-1.03 delineates the inspection activities required during surveillance inspections by the Bechtel .{ QC inspectors to ensure that HVAC system installations and inspec-l tions are being performed as specified in Technical Specification No. 7220-M-151A(Q). i j For each surveillance inspection performed by the Bechtel Co. QC j inspectors, a Subcontract Surveillance Inspection Record is generated to document the activities inspected and to document any " unusual occurrences or acted exceptions." Each Subcontract Surveillance Inspection Report is given a unique " Log No." and a " Report No." A sepaEate log is kept to document the compila-tion of discrepancies noted on the Subcontract Surveillance Inspection Reports. During discussion with the licensee pertaining to thse. overview surveillance inspections,.it was stated that at least one Subcontract Surveillance Inspection Report would be generated each day work was being performed on HVAC systems. I Quality Control Notices Manual Project Surveillance Procedure No. SF/ PSP G-9.1 states that if an " unusual occurrence or noted exception" is detected, that the subcontractor (in this case the Zack Company) can opt to generate a'nonconformance report. If the subcontractor does not generate a nonconformance report, -'] the QC Engineer is obligated to submit a Deviation from Sub-contract Documents Report (or Deviation Report) to the Project Field Quality. Control Engineer for distribution and disposition. ~, " Deviation Reports written by Bechtel QC and Nonconformance Reports written by Zack will (are to) be factored into that. (Consumers Power Co.) Trend Report" for assessment pertinent to stop work actions. 6. Licensee Corrective ~ Action '~ ~ The inspector was informed of. the changes in progress by the licensee to the Quality Assurance Program Procedure No. 15-4 entitled "Stop Work Orders." 1 I .g.. A if a ..n ,.4,...~
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The CPC0 Stop Work Procedure revision draft includes a provision i for stop work consideration when the trend report tracking graphs demonstrate an increase in NCR or deficiency rates which exceed 1 l the four-month trailing average (which is the average of the latest four-month deficiency rates). This provision appears to be an appropriate objective approach for stop work criteria deter-7 minations provided there is an effective quality management overview i and guidelines established for interpretation of significance of the indications. Zack Nonconformance Reports and Bechtel Deviation Reports are to be included in the trending program. These Nonconformance Reports and Deviation Reports are included in the trend program essentially when written with minimal delays encountered during normal internal distribution. The Quality Assurance Manager advised during the exit interview that the final draft of.the Stop Work Procedure would address this aspect of using the trend program graphs. As a condition for the resumption of safety-related work by the Zack Company, Consumers Power Company agreed to develop within 30 days of the release from the Stop Work Ord,er of March 20, 1980, a mechanism to assure that Zack QC inspections are performed in a timely manner l and thus avoid " backlog" inspection conditions which existed prior to March 20,- 1980. Consumers Power Company had"previously made a commitment to the NRC by letter, dated June 30,1980 (J.W. Coo'c to J.G. Keppler), that, "A full scope audit of Zack activities will be initiated approximately l 90 days of the lifting of the Stop Work. This audit will include j the Midland site and the Chicago facility"... and "A review will be made of the overall Zack performance in conjunction with the full scope audit to be carried out 90 days after the Stop Work is lifted." 7. C1,a,ssification of Fire Dampers and Other Components as Equipment During the inspections and/or' investigations associated with installation of heating, ventilating, and air conditioning systems,- some confasion appeared to exist as to whether fire dampers and other componenta should be classified as ductwork accessories or equipment. The procedures governing installation of equipment appear more rigorous than the procedures for installation of accessories. To remove this L ambiguity, the licensee has revised Technical Specification No. 7220-M-151A, Technical Specification for Heating, Ventilating, and L Air Conditioning Seismic Class 1 Equipment and Ductwork Installation, by adding Section 1.2.4 which states "The words " components" and " accessories" are used interchangeably throughout this specification," and by adding Section 1.2.5 which states "At the contractors option, the installation documentation of components / accessories may be the I same as for equipment. The date of this revision (Rev. *) is August 6, '1980. l 1: .g. 7 L-i (F G ,.,f d k -f 7,5 - s y
\\ 8. Qualification of Zack Company Welders i Baued on the large number of questionable welds which had been installed by Zack Company welders prior to the issuance of the "stop work", the qualification of welders qualified since then was questioned. It was discovered that since the Stop Work Order of March 20, 1980, eight Zack Company welders had been qualified 1 in the use of some of the weld procedures at Photon Testing Inc., e } Midland, MI. The licensee indicated that Photon Testing Inc. had j qualified some of the welders prior to the "stop work." The inspectors inquired as to whether an audit had ever been performed of Photon Testing Inc. to validify the quality and capability of t this organization to qualify the Zack Company welders. Sufficient records could not be exhibited to establish that Photon Testing Inc. had been audited in their ability to qualify welders or that a contract had ever been established to qualify welders. The NRC informed the licensee that the qualified Zack Company welders would either require requalification through another approved source or the quality of welder qualification at Photon Testing Inc. would y need to be verified. An audit of Photon Testing Inc. was performed on August 11, 1980 by representatives of Consumers Power Company, Bechtel Power Corporation and the Zack Company. An audit check list based on the AWS Code was used. Two independent assessments were made. As a portion of this } audit, the applicability of 10 CFR 50, Appendix B criteria to Dhoton Testing, Inc. and the interface with the Zack Company were considered. Criteria V, VI, VIII, IX, X, XII and XVII appeared to have particular application to Photon Testing, Inc. and contractural agreements with the Zack Company. No discrepancies were noted in these audit surveys. The Zack Cenpany issued a contract to Photon Testing, Inc. on August 11, 1980 for st vices to qualify welding procedures and welders to AWS D1.1-79 and AWS D1.3-78. Failure to perform an audit of Photon Testing, Inc. for services to qualify Zack Company welders is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion XVIII as identified in Appendix A. (329/80-21-01; 330/d0-22-01). 9. Material Certification The investigation into questionable construction practices for the installation of HVAC systems revealed several discrepancies which were related to the availability and validity of material certifi-cations and the traceability cf materials being used. Therefore, at the request of the NRC, the licensee agreed to perform an aLdit of the Zack Company material certifications on site prior to the J resumption of safety related HVAC work. - ' 7 = ,.-3 is %t - u 7-
>.-.g. Consumers Power Company ar,sembled.an audit team and conducted au audit of Zack Company material certifications on August 7-11, 1980 4 in accordance with Consumers Power Company Quality Assurance Pro-cedure No. 18-1, Audits. Consumers Power Company examined 104 of i approximately 400 material certifications. Sixteen of these material certifications were not signed documents; two certifications were for j type 316 stainless steel when the specification requires use of g type 304 stainless steel; and three certifications,were for ASTM A36-77 when the specifications address use of ASTM A36-75. An Audit Finding Report M-01-14-0-01 was issued on August 8, 1980. As a condition for the resumption of safety related work by the Zack Company, Consumers Power Company imposed the following commitments f pending satisfactory resolution of the audit findings: 4 "1. There is to be no fabrication or installation of material I for which there are unsigned material certifications. Any I material found during the course of work that has unsigned i material certifications is to be identified as nonconforming. and segregated. I l "2. There is to be no fabrication or installation of material that is not as specified in Section 5.0 of Specification M-151A, 4 i including the proper year orJedition of any standards referenced, l unless Contractor (Bechtel) approval is obtained as required. i = Any material found during the course of work that is not as specified is to be identified as nonconforming and segregated. i "3. Any material received from Chicago that is represented by unsigned material certifications or is not material as specified in Section 5.0 of Specification M-151A is-to be identified as nonconforming and segregated from acceptable - materials." i This directive was transmitted to tiie Zack Company by Bechtel Power Corporation on August 14, 1980 when Bechtel Power Corporation per-mitted Zack to resume safety related work. 10. Welding Parameter Verification Zack Company plant and field quality control procedures PQCP-6 and FQCP-6 require that the QC inspector verify at periodic intervals that " welding parameters such as current voltage, and gas flow, are: within the limits required by the applicable WPS (welding procedure). However, these parameters were not explicitly. delineated in.the: 3 applicable welding procedures. The. licensee revised welding proce-dures No. WPS-1 and WPS-2 for 3as Metal Arc Welding and Shielded _ ~ 4 Metal Arc Welding (respectively) to. include quantitative date. for current, voltage, and gas flow where applicable. 6 c . 11 '. Y 'n s Ib ~ ~ ~., z y~
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During the review of these procedures, the Resident Inspector noted that welding procedure No. WPS-1 stated, " Electrodes of 0.035" are used when one or both base metals are less than.1382", (10 Ga.), thick." However, the Velding Procedure Qualification Test Record (PQR) used a 0.045" diameter electrode size for less than 10 gauge qualification. AWS D1.1-79 Section 5.5.2.3, Gas Metal Arc Welding, 1 requires a welding procedure qualification be performed for a change l in electrode diameter. i As a condition for the resumption of safety related work by the Zack Company, Consumers Power Company imposed the following commitment. "there is to be no MGAW welding of A-36 or A-572, Grade 50, material less than 10 gauge with.035 diameter weld wire pending qualification of procedure WPS-1 for the.035" weld wire. An alternative to the qualification is to clarify Section 5.2 cf Procedure WPS-1 to delineate on which materials the different diameters of weld wire may be used. This item is to be addressed by September 5,1980. Unresolved Matters Unresolved items are matters about which more information is required in order to ascertain whether it is an ecceptable item, an item of noncompliance, a failure to meet a licensee commitment, or a deviation. There were no unresolved items disclosed during the inspection. i 4 Exit Interview The inspectors met with licensee" representatives (denoted in the Persons Contacted paragraph) at the conclusion of the inspection on July 18, 1980. The inspectors summarized areas of concern that the licensee should give consideration to completing prior to releasing the HVAC contractor to resume work. The licensee acknowledged the concerns. The inspectors met with the licensee on August 6,1980 at the conclusion of the August 4-6 portion of the inspection. The inspector identified five items which are addressed in Section 4b, 6; 8, 9, and 10, that requires resolution. Three of the items (addressed in Sections 8, 9, and
- 10) required resolution prior to the NRC approving resumption of work by the Zack Company.
On August 14, 1980 a telecommunication transpired between NRC-RIII, the Resident Inspector, Consumers Power Company corporate personnel, Consumers Power Company site personnel and Bechtel Power Corporation. During this telecommunication, the NRC stated that no further objections existed which would preclude resumption of safety related work by the Zack Company, provided the constraints listed in Sections 4b, 9, and 10 were invoked. These constraints were later verified by the Resident Inspector. All items of the Immediate Action Letter dated March 21, 1980 were deemed to be completed. .1 -el li k, m _ ). m
a YElobYnuicopy l AUG 7 1980 DocketNo.5[329 bb Docket No. 50-Consumers Power Company ATTN: Mr. Stephen H. Howell Vice President 1945 West Parnall Road i. Jackson, MI 49201 1 i Geatlemen: I l This refers to the inspection conducted by Mr. R. J. Cook of this office on July 1-31, 1980, of activities at Midland Nuclear Power Plant Construction l Site authorized by NRC Construction Permits No. CPPR-81 and No. CPPR-82 and to the discussion of our findings with Mr. J. L. Corley, and others of your staff at the conclusion of the inspection. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, 4 observations, and interviews with personnel. No items of noncompliance with NRC requirements were identified during the course of this inspection. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the en-closed inspection report will be placed in the NRC's Public Document Room, except as follows. If this report contains information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this letter, to withhold such informatian from public disclosure. The application must include a j full statement of the reasons for which the information is considered pro-prietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.
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l YELLOW FILE COPY 4 i Consumers Power Company Agg 7,. We will gladly discuss any questions you have concerning this inspection. i Sincerely, I G. Fiore111, Chief Reactor Construction and 1 Engineering Support Branch i
Enclosure:
IE Inspection Reports No. 50-329/80 ; and No. 50-330/80-23 i cc w/ enc 1: Central Files Reproduction Unit NRC 20b l PDR Local PDR NSIC TIC Ronald Callen, Michigan i Public Service Commission j Myron M. Cherry, Chicago i i i 4 i g RIII RIII RIII f l Cook /np Knop. Fiorelli i 8/5/80 1 -l '-c ?
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I \\ 5 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 50-329/80-22; 50-330/80-23 f Docket No. 50-329; 50-330 License No. CPPR-81; CPPR-82 l Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant, Units 1 and 2 Inspection At: Midland Site, Midland, MI Inspection Conducted: July 1-31, 1980 fS'ff0 hC W I Inspector: R. J. Cook b'Y 8/f/fo Approved By: R. C. Knop, Chief Projects Section 1 Inspection Summary Inspection on July 1-31, 1980 (Report No. 50-329/80-22; 50-330/80-23) Areas Inspected: Examination of site conditions; detensioning of reactor vessel holddown bolts; follow-up review of construction measure for installation of HVAC systems; investigation into construction activities of the Zack Company and caseload forecasting. This inspection effort involved a total of 64 inspection hours by one NRC inspector. Resulta: No items of noncespliance or deviations were identified. .i 8 0 g~ t 4 (3 ) Y z i 7 i y
1 4 9 s. DETAILS Persons Contacted ) Consumers Power Company Personnel D. Miller, Site Manager T. Cooke, Project Superintendent {
- J. Corley, Site Project QA Superintendent i
D. Keating, IE&TV Section Head i F. Pimentel, NDE and Welding Supervisor H. Allen, QA Mechanical Bechtel Power Corporation Personnel i L. Dreisbach, Project QA Engineer E. Newman, Project Field QC Engineer The Zack Company Personnel i M. D'Haen, QC Manager ) Numerous other principal staff and personnel were contacted during the reporting period. 1
- Denotes those present during the exit interviews conducted during the reporting period.
Functional or Proaram Areas Inspected 1. Site Tours j i l At periodic intervals during the report period, tours of selected j areas of the site were performed. These tours were intended to l assess the cleanliness of the site; storage conditions of equipment and piping being used in site construction; the potential for fire or other hazards which might have a deleterious effect on personnel and equipment, and to witness construction activities in progress. The Resident Ir.spector was advised during the report period that an analysis had been perfonned to determine if any deleterious affects could be expected if ash follout from Mt. St. Helens should strike the site. No deleterious affects are anticipated. l 2. Detensionina of Reactor Vissel Holddown Bolts During the reporting period, the Resident Inspector was cognizant of licensee efforts at detensioning reactor vessel holddown bolts in Unit 1. By mid-month, all of the Unit I holddown bolts had been detensioned to the first stress plateau. No additional bolts were i broken during this evaluation. I ( l }, 3 k 3 ,e g mw-se--w m4,w-m- e9-
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Follow-up Review of Corrective Measures for Installation of Heatina, Ventilating and Air Conditionina (NVAC) Systema During the reporting period, the Resident Inspector participated in an inspection conducted by Regional Based Inspectors to evaluate the ) activities which have transpired to improve QA/QC for the installation of HVAC system. ~ t [ The inspectors determined that the "stop work" for installation of NVAC systems should remain in effect pending resolution of the remaining discrepancies. The Resident Inspector's contributions to this inspection effort are documented in NRC Inspection Report No. 50-329/80-21; 50-330/80-22. 4. Investination - Construction Activities Pertainina to Installation of Heatina. Ventilatina, and Air Conditionina (HVAC) Systems During the reporting period, the Resident Inspector examined for purposes of clarity and completeness, activities pertaining to welding of safety related fire dampers which occurred prior to the investiga-tion into alleged construction deficiencies by the Zack Company. The results of this effort will be contained in the investigation report (NRC Inspection Report No. 50-329/80-10; 50-330/80-11). i e 5. Caseload Forecast Panel a On July 28, 1980, the Nuclear Reactor Regulation (NRR) Caseload Fore-cast Panel toured the Midland Site to assess the licensee's predicted j completion and fuel loading dates. On July 29, 1980, discussions i pertaining to forecast scheduling were held at the Midland Service Center and were open to the public. Exit Interview l The Resident Inspector attended the Exit Interviews conducted by T. Vandel and K. Ward, Region III Reactor Inspectors on July 18 and 22, 1980, respec-tively. i The Resident Inspector met with licensee representatives (denoted under Persons Contacted) on July 24 and 31, 1980. The inspector summarized the ,o . scope and findings of the inspection effort to date. The licensee acknow-ledged the findings reported herein. Attachments: Preliminary Inspection Findings 4 l - r I * (: 1 (. s fg l-s f s V y 4 e \\
. a s t.. s.. v. e. s. .....s ....s,... .e T7.ELIM1?i AM 25571.C ;;,:. r;;.~.,;5 5 i 3. LICENSEE 2. REGIO:iA;. OTTICE I g; i Consue. ors Power Company V. 5. ::at ; ear he,...; story Cc::.is e:ca 1945 West Parnall koed Office of Inspection & Enforcement, kIII ( Jackson, MI 49201 in Roosevelt Road d'idiand Unit 1 (Midland, ?: ) C;en Ellyn,11. c6137 P.idhnd Unit 2 (Midland, H;) I. I 3. DOCKE7 EUM&ERS 4 LICENSE NUMBIAS !5. LATE 07 INSPECTION i fCF?A-61 CPPA-62 I 3G-329 50-330 July 1-2t.. 1980 T 6. Within the scope of the inspection, no ite=a of noncomp*1ance or deviation were found. 7. The following motsers are preli=inary inspection findings: 1 9 8. These preliminary inspection findings will be reviewed by E7.C Supervisien/ k nagement at the Region III offica and they will correspond with you concerning any essereemer.t estion.
- 4 Euclear4egulatory Commission inspecter l
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l a = _= x - =- .2---~ >-~- .--,_,s._.. 3 i 1 L (, u". s. Ci es.... e 4 C; ; v;. a.... c.e.1.i:.:.... i. i TFI* ;E;!..*.RY ;;;5PIC;;c:: T !D;!;05 i E 2 1. LICIK5EL 1. kEC;O: A;. GFi1CE Consu ers Power Company 1". 5. Nuclear Res:uletsry Co=.inston I 11,*.5 West Parnall Road Office of Isi pection & Enforcement, RI:1 ) i Jacksan, MI 49201 7% Roosevelt Road MIdiand 1* nit 1 (Midlan(, MI) 6;en Lilyn, II. 65157 Midland ~Jnit 2 (Midland, X;) 3. D3;i7.7 3C'.EERS \\ &. 1.;CI55L LY.hERS .S. LATE 07 IE57EC;10:; I 55-329 50-330
- CFPA-61 CPPA-82 July 25-31.1980
]x 6. Within the scope of the inspection, no itecs of r.once:pliar.ce or deviation were found. i -[ 7. The following matters are prelisin6ry inspection findings: i i I l 1 k l 6. These pre 11sinary inspection findings will be reviewed by ERC Supervision / Management at the Region III O!! ice and they will correspond with you concerning any enforcement action. } ( Nulleaf Regulatory Con =issior. Ir.spector
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. =. ~_ i l ~ SEP ' 51980 i Docket No-Docket No. 50-330 1 Consumers Power Company j. i ATTN: Mr. James W. Cook } Vice President Midland Project 1945 West Parnall Road .) Jackson, MI 49201 j Gentlemen: l This refers to the inspection conducted by Mr. R. N. Sutphin of this office on August 19-22, 1980, of activities at Midland Nuclear Power Plant Construction Site authorized by NRC Construction Permits No. CPPR-81 and No. CPPR-82 and to the discussion of our findings with Mr. W. R. Bird and others of your staff at the conclusion of the inspection. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel. No items of noncompliance with NRC requirements were identified during the course of this inspection. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, j Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Recm,~ except as follows. If this report contains information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty days of your receipt of this letter, to withhold such i information from public disclosure. The application must include a full I statement of the reasons for which the information is considered proprietary, l and should be prepared so that proprietary information identified in the l application is contained in an enclosure to the application. i /. \\ l / f(&$gp L i l i.) i t 4. ^< . 4;c I
'SEPi 15 880 Consumers Power Company l We will gladly discuss any questions you have concerning this inspection. f Sincerely, j I l s s . Fiorelli, C ief Reactor Construction and Engineering Support Branch
Enclosure:
IE Inspection l Reports No. 50-329/80-23 t and No. 50-330/80-24 cc w/ encl. Central Files i Reproduction Unit NRC 20b i PDR Local PLR NSIC TIC Ronald Callen, Michigan Public Service Commission Myron M. Cherry, Chicago e t ( l RIII / RIII RIII 'RII f s'g \\ U y j Sutphin/np Cookk Knop Fiore li 9/12/80 f e .+- 11 2. ~
3 U.S. NUCLEAR REGULATORY CCMMISSION l OFFICE OF INSPECTION AND ENFORCEMENT REGION III P Report Nos. 50-329/80-23; 50-330/80-24 j Docket Nos. 50-329; 50-330 License Nos. CPPR-81; CPPR-82 t Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant"., Units 1 and 2 Inspection At: Midland Site, Midland, MI Inspection Conducted: August 19-22, 1980 b { 3 !d --' g Inspector: R. N. Sutphin f,/ ,e . g.- G a/ / Approved By: R. C. Knop', Chiefr%[ ///f/IE Projects Section 1 Inspection Summary l Inspection on August 19-22, 1980 (Report Nos. 50-329/80-23; 50-330/80-24) Areas Inspected: Construction schedules; status of Part 21 items; out-standing items of noncompliance and unresolved matters; new CPCo Quality Assurance organization; examination of site construction activity; Zack Company status; 50.55(e) items. Results: No items of noncompliance were identified during the course of this inspection. O 's s @ pp S S Wl' ^ i s' ] s
i DETAILS Persons Contacted Consumers Power Company Personnel a t
- W. R. Bird, QA Manager i
T. C. Cooke, Project Superintendent T. L. Corley, Site Project QA Superintendent
- R. G. Wollney, Section Head, QA Administration l
D. E. Horn, Supervisor, QA R. E. Whitaker, Supervisor, QA i H. P. Leonard, Section Head,,QAE Midland l Dennis Johnson, Construction Control Administrator Ed Evans, Senior Engineer
- R. A. Sinervo, Construction Bechtel Power Corporation Personnel
- E. D. Newman, Assistant Project Field QC Engineer The inspector also contacted other contractor and licensee personnel during the course of the inspection.
\\ t
- Denotes those present during the exit interview.
Functional or Proaram Areas Inspected l 1. Construction Schec.ules i The inspector checked the status of construction and construction schedules for the overall project. No items of noncompliance or deviations were identified. 2. Part 21' Items a. NPS Industries defective fasteners. All pipe whip restraints with these bolts (fasteners) are on hold. 114 bolts have been identified and segregated. Some testing is planned to insure proper corrective action. 56 additional bolts are also being checked. Procedures for proper ordering will be checked prior to ordering replacement. This item remains open. b. B4M Cooler Support problem. The letdown cooler support lower bracket has been redesigned. A drawing has been prepared of the' bracket. Dws. No. 1106164D Revision 0. After final 4 analysis by Bechtel, a field change authorization will be issued for work in the field. This item remains open. No items of noncompliance or deviations were identified. i l Jj g s a f Ii lY ~ q y_
,. ~.. - s.- i,.' 3. New CPCo QA Organization i The inspector received a copy of the organization chart of the new i Quality Assurance organization in effect as of August 15, 1980. The i chart presented the merger of Becatei and CPCo QA personnel. All Manager, Section Head, and Supervisor per.itions have been filled. i Four vacancies remain to be filled in the QAE group, four in the l IE and TV group, one in Administration,,and two in Project QA ^ Services. ~ s The organization will be checked for compliance with commitments. 4. Zack Company Status i The inspector verified that the stop work order for the Zack Company HVAC safety related work was lifted and that required schedules were being developed. ~ w I l No items of noncoupliance or deviations were identified. 5. 50.55(e) Items The inspector reviewed with CPCo the status of'three (3) 50.55(e) items, and concurs that these items are closedP a. Uaft 2 containment rebar-spicing: The inspector reviewed comments on the status of the rebar spacing problem per report 50-329/75-01, 50-330/75-01; 50-329/75-02, 50-330/75-02; and i 50-329/75-03, 50-330/75-03. This ite's is closed. i b. Unit 2 containnent fire - repair of liner plath. fire damage: The inspector reviewed comments in inspection report 50-329/ j 76-01, 50-330/76-01, page 7,' item #4.,This item is closed. _ ( Missing rebar - omission of reinforcement steel:-The inspector ,1 c. reviewed comments in Inspection Repor.t 50-329/76-05, 50-330/-' 76-05, page 3, item #F.1. Thl.a itens.is closed. ~ ' Exit Interview '~
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The inspector met with site representatives ( enoted in; Persons Contacted paragraph) at the conclusion of the-inspection. The inspector summarized- " ~ ' the scope and findings of the inspection noted in this rspiet. ~ L <s ~, a, + - ~.. j, g s
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e 4 6 i f SEP 10 88; I Docket No. j Docket No. 0-Consumers Power Company { ATTN: Mr. James W. Cook i Vice President Midland Project 4 1945 West Parnall Road Jackson, MI 49201 Centlemen: This refers to the inspection conducted by Mr. R. J. Cook of this office on August 1-31, 1980, of activities at Midland Nuclear Power Plant Con-struction Site authorized by NRC Construction Permits No. CPPR-81 and l No. CPPR-82 and to the discussion of our findings with Mr. J. L. Corley i at the conclusion of the inspection. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel. No items of noncompliance with NRC requirements were identified during the course of this inspection. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room, except as follows. If this report contains information that you i or your contractors believe to be proprietary, you must apply in' writing to this office, within twenty days of your receipt of this letter, to withhold such information from public disclosure. The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the. application is contained in an enclosure to the application. e I 1 7 I A - I - a + .,f* 4 e c e b + en r
f ~ Consumers Power Company SEP ' O 980 h We will gladly discuss any questions you have concerning this inspection, j Sincerely, ( G. Fiore111, Chief Reactor Construction and Engineering Support Branch
Enclosure:
IE Inspection Reports No. 50-329/80-26 4 i and No. 50-330/80-27 cc w/ enc 1: l t Central Files I, Reproduction Unit NRC 20b PDR I,ocal PDR NSIC TIC Ronald Callen, Michigan i Public Service Commission j Myron M. Cherry, Chicago i 4 4 i a RIII g RIII RIII RIII M r gd-Cook /npj Sutphin Knop Fior li 9/,8/80 f. b ~ ~~ 2 fh[, 'e } ....J..-
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 50-329/80-26; 50-330/80-27 Docket No. 50-329; 50-330 License No. CPPR-81; CPPR-82 Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant, Units 1 and 2 Inspection At: Midland Site, Midland, MI Inspection Conducted: August 1-31, 1980 Inspector: R. J. Cook 7-9 O i Approved By: R. C. Knop, Chief 7-9 b Projects Section 1 Inspection Summary Inspection on August 1-31, 190 (Report Nos. 50-329/80-26; 50-330/80-27) Areas Inspected: Examination of site conditions; detensioning of reactor vessel holddown bolts; follow-up review of construction measures for installation of HVAC systems and subsequent release from the Bechtel i Stop Work Order of March 20, 1980 and meeting with Consumers Power Company i Director of Environmental Services, QA and Testing. This inspection effort i involved a total of 72 inspection hours by one NRC inspector. j Results: No items of noncompliance or deviations were identified. i /' 4epf.a i
) DETAILS Persons Contacted Consumers Power Company Personnel j D. Miller, Site Manager l T. Cooke, Project Superintendent i B. Marguglio, Director Environmental Services, QA and Testing
- J. Corley, Site Project QA Superintendent D. Keating, IE&TV Section Head F. Pimentel, NDE & Welding Supervisor M. DeWitt, QA Nechanical H. Allen, QA Mechanical J. Zimmerman, QA Mechanical i
Bechtel Power Corporation Personnel W. Creel, QA Engineer The Zack Company Personnel R. Akers, Lead QC Inspector Numerous other principal staff and personnel were contacted during the reporting period. i
- Denotes those present during the exit interviews conducted during the reporting period.
Functional'or Program Areas' Inspected 5 1. Site Tours At periodic intervals during the report period, tours of essentially all areas of the site were performed. These tours were intended to assess the cleanliness of the site; storage conditions of equipment and piping being used in site construction; the potential for fire or other hazards which might have a deleterious effect on personnel and equipment, and to witness construction activities in progress. 2. Detensioning of Reactor Vessel Holddown Bolts During the reporting period, the Resident Inspector was cognizant l of licensee efforts at detensioning reactor vessel holddown bolts in Unit 1. By midmonth, all of the Unit I holddown bolts had been detensioned to the lowest stress plateau. I i '.- 75 t = -r s 6 v v
A o i + 3. Follow-up Review of Corrective Measures _for Installation of Heating i Ventilating and Air Conditioning (NVAC) Systems During the reporting period, the Resident Inspector participated in additional inspection effort conducted by Regional Based Inspectors to evaluate the activities which have transpired to improve QA/QC for the installation of HVAC system. The Resident Inspector performed ( the final review of items requiring resolution prior to removing the "stop work" for installation of safety related HVAC systems. It was determined on August 14,190 that HVAC safety related work could resume provided that certain constraints pertaining to material certifications and the impact of proposed new work on unresolved discrepancies and previously installed items were invoked. The Bechtel Power Corporation released The Zack Company from the Stop Work Order of March 20, 1980 by letter dated August 14, 1980. The i Resident Inspector's contributions to these additional inspection l efforts are documented in NRC Inspection Report No. (50-329/80-21; 50-330/80-22). { 4. Management Meetinas i During the reporting period, the Resident Inspector met with the Consumers Power Company Director of Environmental Service, Quality Assurance and Testing to discuss the effectiveness of the onsite QA organizations, the impact of the integration of Consumers Power Company 4 and Bechtel Power Corporation QA personnel and recent reorganizati. 3 of the management structure. Exit Interview The Resident Inspector attended the Exit Interviews conducted by R. Knop, 4 Region III Section Chief, K. Ward, R. Sutphin, and R. Greer, Region III Inspectors on August 6, 13, 22 and 27, 1980, respectively. The Resident Inspector met with licensee representatives (denoted under Persons Contacted) on August 28, 1980. The inspecter summarized the scope and findings of the inspection effort to date. The licensee acknowledged the findings reported herein. i e i h- ~ ..- 2{ [W 4
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were found. 7. The follovir.& zatters are preli ir.ary ir.spe::ar. fit.11r.p t t P tIis. Ir, M. 4. These preitsisary inspectier, fir.dir.Es vi;; be rniewJ by FC Surcrvssier./ Manage Ant at the Region 111 Of fice and they v111 correspor.s witt. Sa.: soncerning any enforcement actier.. / v r. _ _ '-.. Eucaea e;ulatory Co==1sstor. Ir.spect l
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si.!i 07 :.MPI.;;;3 I 50-329 5s-330 crrh-1 *. s.>i'.s - 6 7 August t l 196 l ""~l 6. Within the scope of the it. spec tier.. r.c it ers of r.onc e:,Giar. e or deviat ic-were found. t U 7. The following matters are pr=* 1:.* riary inspec tac e fi:..:r.p : No further objections exist which w.suld prec t nf res:m; tie, ci saferv rel.ve.f work by the Zask Co. provided the c. met ratnes listed 1, r,,*rmera Fiwc r e.,t,; r.y letters to Bechtel Power Corparatt.*n dated August 6 391 Atratiet 11 ! W arr invoked. A 4. Tnese preliminary inspectier. findings wi;; he reviewed t > EEC Su;ersionen! Management at the Kegion II; Office and they will correspond with you concorpip5 any enforcement action. 1 d t'v-T j I Euclear IIeplatory Cor-issier. Insper r l Z k. ~} 2 l* .*o -., % ~ -e
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i,. a gf}l4r .. d.m'g M UNITED STATEg / NUCLEAR REGULATORY COMMISSION n i I REGION 111 e, f ne noosavatinoao GLEN ELLYN. ILLINol8 00137 %*ese*[ AUG I 9 TE2 9j$ ~ Docket No 50-32 Docket No. 0 Consumers Power Company AT1H: Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road l Jackson, MI 49201 1' Gentlemen: This refers to the routine safety inspection conducted by Messrs. C. E. Jones and K. R. Ridgway of this office on July 6-9, 1982, of ac-tivities at Midland Nuclear Power Plant, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-81 and No. CPPR-82 and to the discussion of our findings with Mr. B. W. Marguglio and others of your staff at the conclusion of the inspection. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and in-terviews with personnel. No items of noncompliance with NRC requirements were identified during the course of this inspoetion. l In accordance with 10 CFR 2.790 of the Commission'-s regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractors) believe to be exempt from disclosure under - 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by tele-phone within ten (10) days from the date of this letter of your intention l to file a request for withholding; and (b) submit within twenty-five (25) } days from the date of this letter a written application to this office i to withhold such information. If your receipt of this letter *..as been delayed such that less than seven (7) days are available for your review, please notify this office promptly so that a new due date may be estab-l lished. Consistent with Section 2.790(b)(1), any such application must l l l b s (-hd { f i paro ..y 4
e i 2 Consumers Power Company 2 Agg, g pgp l l be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons which are the bases for the i i claim that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4). The information sought + I to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within i the specified periods noted above, a copy of this letter and the enclosed inspection report will be placed in the Public Document Room. We will gladly discuss any questions you have concerning this inspection. l Sincerely, i R.Lv 8 esserd" tgdghtstga,d h/ P R. L. Spessard, Director Division of Project and Resident Programs
Enclosure:
Inspection Reports No. 50-379/82-15(DPRP) and No. 50-330/82-15(DPRP) cc w/ enc 1: DMB/ Document Control Desk (RIDS) Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB Michael Miller Ronald Callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris l Mary Sinclair Wendell Marshall Colonel Steve J. Gadler (P.E.) RIIIa R) gigway x RI] RIII RIII pBoyd/sv ,o sard y onis T'8/4/82 4 r i i I l i' k ..?' h
U.S. NUCLEAR REGULATORY COMMISSION t { REGIGii III I i* Reports No. 30-329/82 '*3(DPRP); 50-330/82-15(DPRP) Docket Nos. 50-320; 30-330 Licenses No. CPPR-81; CPPR Licensee: Consumers Power Company j 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant, Units 1 and 2 Inspection At: Midland Site, Midland, MI Inspection Conducted: July 6-9, 1982 f4. J l Inspectors:p s,k,!G a:/a t<4 K. R. Rid f/4. /fI sn ApprovedBy:h h of f/4 /f.' Reactor Project Section 1A / Inspection Summary Inspection on July 6-9. 1982 (Reports No. 50-329/82-15(DPRP): 50-330/82-15(DPRP)) Areas Inspected: Routine, announced inspection of resolution of noncom-pliances, open inspection items, 10 CFR 50.55(e) reports, and followup relative to IE Bulletins, Circulars and Information Notices. This inspection involved a total of 77 inspector-hours (44 onsite) by two NRC inspectors including 10 inspector-hours onsite during off-shifts. Results: No items of noncompliance or deviations were identified. O e g Y g o g s f o b o r '1b(( { t m s
[ DETAILS 1. Persons Contacted Consumers Power Company (CPCo) g I l
- B. Marguglio, Director, Environmental and Quality Assurance j
- D. Turnbull, MPQAD
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- D. Horn, Section Head, Civil Quality Assurance
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- M.'Schaeffer, Section Head, Electrical Quality Assurance
- R. Whitaker, Supervisor, Mechanical Quality Assurance T. Buczwinski, Technical Engineer - Operations l
- R. Frisch, Senior Technical Analyst - Operations
- K. Marbaugh, Quality Assurance Nuclear Operations
- D. Martin, MPQAD, NVAC i
- H. Leonard, MPQAD, HVAC, Quality Assurance
- G. Parker, MPQAD, HVAC, Quality Assurance j
- E. Goold, MPQAD, HVAC, Quality Assurance 1
C. Banner, Assistant Shift Supervisor l Zack Company 4
- J. O'Connell, Technical Services U.S. Nuclear Reaulatory Commission-
- R. J. Cook, Senior Resident Inspector t
+ Other personnel of the licensee and contractor were contacted during the inspection.
- Denotes those present during the exit interview.
{ 2. Licensee Action on Previous Inspection Findings i The inspector reviewed the documentation of the corrective actions taken - 1.,, to resolve the items of noncompliance identified in IE Investigation Reports No. 329/80-10 and No. 330/80-11, March 6 through July 314 1980, t. concerning the Heating, Ventilation and Air Conditioning (HVAC) work and reported in the Licensee's response letter of January 30, 1981, Serial No. 11174. This investigation was made in response to 21 allegations dealing with material traceability, violation of' procedures, falsfica-tion of records, and training of quality control inspectors. Twelve of-t the allegations were substantiated; the remaining nine were not substantiated. Nineteen items of noncompliance, 16 infractions and 3 deficiencies were identified showing noncompliance with 10 of the 18 criteria for a quality assurance program,.as set forth in 10 CFR 50,. Appendix B. The noncompliances were issued as a Civil Penalty against the licensee, letter EA-80-56, dated January 7, 1931, Victor Stello,'Jr. to Consumers Power Company, Attention, Stephen H.'Howell. 'hro of the items, No. I and No. 10 noted in the letter were later retracted as not being items of noncompliance, letter dated October 13, 1981f James G. Keppler to James W. Cook. ) 2 fl -N .) 9
During this investigation it was determined that although the licensee .I had earlier initiated a Management Corrective Action Request pertaining i to many of the nonconformances, corrective actions were not being taken i by the subcontractor, Zack Company and a stop work order was issued by Bechtel Power Corporation BPC) on March 20, 1980. A Confirmatory Action i Letter was issued by Region III on March 21, 1980. All work on safety-W l related portions of the HVAC system was stopped for about five months. l During this time the Zack Company's QA Program and implementing pro- { cedures were completely revised and approved by BPC and the licensee. Training and requalification of quality control personnel, production workers and welders was completed. The licensee developed and instituted a 100 percent overview inspection program for the HVAC work. An independent insoection firm. Conam. nas contracted to perform QC ' nspections of Zack Company work. Reinspection of some saferv r=1 mead i nangers, orop in ancnor oolts, and hanner velds was completed before the j . wp wurm uruer was 111ted on August 14 19An. The above corrective acuons war..u.ymeu oetore tne stop work order was lifted an th [. j inspe tions were documented in Inspection Report No. 50-329/80 , 21 an and No. 50-330/80-19, 22 and 23. I bood k d dD l This inspectionIwas conducted to determine that corrective actions had been taken to resolve the many affected HVAC components. The inspection consisted of reviews of Nonconformance Reports (NCR), HVAC duct hanger identification, restock requests for replacement j materials, training records, overinspection reports, etc. to deter-mine that the items of noncompliance had been corrected. In most cases the affected component was scrapped and the travelers for that component voided and new travelers for the replacement component issued. Th g 7 e original voided traveler was retained as. part of the records. (Closed) Item of Noncompliance, Infraction (329/80-10-02; 4. I 330/80-11-02Mctivities~affee. ting' qual'ity were not accomplished in accordance with documented instructions and procedures for fabri ~' cation. This noncompliance concerned the following five parts. J 4 (1) The replacement duct for Duct No. V03-SH2-2-F9437 was CA partially completed without a traveler. The corrective F [ [ action voided Traveler F9437 and the duct was scrapped asNew materia documented on Nonconformance Report (NCR) A-96. / was ordered on Restock Request No. 1534. Training was held sN 'y [ for supervisors, foreman and quality control inspectors on((Cd h $, 7 the following procedures: p Field Quality Control Frocedures (FQCP) - 3 and 5 48' Field Procedures (FP) Revision 0 - 3 and 5 p The installation was accepted by CPCo on CPCo Overinspection 01-H-36A-45. (2) The installed hanger No. V19-SH1-7 did not resemble the sketch on the traveler (V19 Hanger 7-F938). The corrective action voided Traveler F938 and scrapped the hanger on NCR's C-8, IdentificationnumbersarefroU[tp*eRegionIIITrackingSystem. t 8 sV r [. 3t " I,' gC k s /,gf S e v q
g, +;s -i A174 and A250. New material was ordered on Restock Request l No. 1541. Cognizant personnel were trained on Zack Fabrica- .]. tion and Installation Procedures FPQC-3, FPQC-5 and FPQC-7. 3 The installation was inspected and accepted by CPCo, Over-i inspection 01-M-36A-47. i (3) The sketch on Traveler No. V26-SH1B 11F10807 showed that the i angle iron was welded to a 4"x5.4"x45' channel. The angle iron, as installed, was welded to a channel approximately 7" r deep and 2 1/4" wide. l I Tne corrective action voided Traveler F10807 and scrapped the hanger as documented on NCR A252. New material was ordered j on Restock Request No. 1535. Training was conducted and i attendance recorded for cognizant personnel. 4 ?> The hanger installation was accepted following the CPCo j Overinspection 01-M-36A-37. (4) The height of hanger No. V1-3(7/C686) F916 was shown on the g traveler as 43 S/4"; however, the installed dimension was approximately 37". In addition the angle brace was a 2"x2" y angle instead of a 3 1/2"x3 1/2"x1/4" angle specified by the m*'" traveler. 5 The corrective action was as follows: jgt (a) Traveler F916 was voided.. (b) NCR C69 was issued to re with 3 1/2"x3 1/2"x1/4" place the 2"x2"x1/4" sagle iron angle. (c) NCR A265 was issued to replace the 2"x2"x1/4" angle with 3 1/2"x3 1/2"x1/4" angle. (d) NCR A553 added the welder identification and the weld { procedure to the traveler. (e). NCR C344 added material certification and accountability. (f) NCR C346 installed brace per Field Change Notice (FCN) 794; C850. (3) ~NCR A1016 Certification Nos. added, welds reworked and documented. s j (h) Training was conducted and documented for cognisant personnel. (i)' Installation was accepted after CPCo Overinspection i 01-M-36A-40. f, 7 4 h.y n. s.- L. .-.-J--...,..-..--_.. ,,......... ~. ~- ~~- ? [ ,i ',['e
= i 1 (5) A review of Zack drawing No. V26-SH1 indicated that the welder's identification number and the type of welding performed for each weld were not recorded. This drawing specified six hangers that received corrective action. They were located in the Upper Spreading Room and were { g identified as hangers No. 33, 34, 36, 37, 38 and 21A. l h CPCo verified that records for hanger No. 33 listed the i hl weld procedures and welders performing the welds and that i this information was documented on NCR A1138. Welding procedures were added to Traveler F3487. Welder's iden-l tification (ID), were added and the welds reworked. Corrective action for weld No. 34 included adding the weld procedure and welder's ID through NCR A1080. Traveler F3490 for hanger No. 36 was voided by F19101 and the hanger scrapped by NCR A1096. New material was ordered on Restock Request No. 4430. Traveler F3491 was voided by F19100 and hanger No. 37 was scrapped per NCR A1097. New material was ordered on Restock Request No. 4432. Hanger No. 38 was scrapped per NCR A1098 after the Traveler F3492 i had been voided. New material was ordered on Restock Request No. 4432. Corrective action for hanger 21A was to add the weld procedure per NCR A1105 and hanger to duct welds and certifications per NCR A1552. Training was conducted for all cognizant personnel. CPCo Overinspections were conducted as acceptance for the correction of the above items of noncompliance. b. (Closed) Item of Noncompliance, Deficiency (329/80-10-03; 330/80-11-03): Walder's ID was not recorded on 10 travelers. Corrective action by the licensee included scrapping six of the first 10 items listed, ordering replacement material and replacing the duct or hanger as described on the one existing and five revised travelers, h I The remaining four items had been fabricated in Zack's Chicago plant, reworked on site to conform to the traveler, and the f modifications documented to agree with procedural requirements. fd These items were accepted after the CPCo Overinspection, p I 01-M-36A-46 and 38, W n pi c. (Closed) Item of Noncompliance, Deficiency (329/80-10-04; [V 330/80-11-04): Use of an unapproved marking material, Eberhard Faber Marquette, to mark sheet metal stock and fabricated items installed in Seismic Class 1 ductwork without a contractor approved change. Zack Company used Eberhard Faber Marquette to 5 d i i
t L identify duct assemblies rather than the approved Carboline 4 Company X-1000-90, Ameron Company 2032 or Nissen metal marker by Nissen Company. A Supplier Deviation Disposition Request (S.D.D.R.) No. 1966, dated December 30, 1980, was prepared by Zack Company and i approved by Bechtel to use the former but not in lieu of the j latter (NCR D39 references S.D.D.R. 1966). Bechtel approved the former material after adequate proof testing 4 I results indicated no detrimental qualities. l j CPCo Overinspection 01-M-34A-30 indicated _all black magic markers j had been removed from the fab shop. l d. (Closed) Item of Noncompliance, Infraction (329/80-10-05; j 330-11-05) Documentary evidence did not exist that material and 4 equipment conformed to procurement requirements prior to instal-i lation or use at the plant site. A review of the noncomolia~ a - br CPCO incicatea Zack Company had purchased seversi different types of E-7018 and E-6011 weld rod. The rod purchased under Lot No. 37G was Lincoln LH-72 (E-7018) 3/32" electrode, material g,, certification No. C580. Deliveries of 100 lbs. and 200 lbs. had 1 I L been made at different times. Material certification No. C12305, dated December 28, 1978, was s for 500 lbs. of Hobart, Class 1/8" E-7018 welding rod, Serial 8 No. 90384Z076 ordered on Traveler F3769. When the NRC investigation was in progress the weld rod certiti-j cations were in Zack's Chicago office and the oven labels were l incorrect. Since that time Material Certifications have been { sent to the Midland site, even labels have been corrected to i identify the material. stored in the warning oven, and Procedure i FQCP1, Revision 0, " Receipt Inspection of Materials, Components and Accessories," was issued May 19, 1980. l The revised Procedure MB-FQCP-6, Revision 0, " Weld Rod Control," i Paragraph 7.6 requires, "Each shelf, within the weld rod issue roce, which contains weld filler metal, including the shelves inside the rod holding ovens, are marked as to the type, heat / lot and or control number of weld filler metal. contained theron. Holding oven shelf marking are applied to the exterior side of j-the door, in line with interior shelves." Training was conducted on FQCP-1 on June 25 and 26,1980 and on FQCP-6 on July 8 and 31, 1980. The CPCo overinspection 01-M-34A-01 was completed. (Closed) Itee of Noncompliance, Infraction (329/80-10-06; j e. ) i' 330/80-11-06): Measures did not assure the identification of I safety-related HVAC components throughout fabrication, erection l and installation. This noncompliance concerned 10 separate items,- .I two on ducts, six on hangers, and one each on turning vanes and' h lb ) i 6 1 Si 1, a e _,-.__._,.- ~, ..,s J.',_~
material storage. They are identified as item 4 in Civil Penalty Letter EA 80-56 referenced above. The inspector reviewed the documentation concerning each ites and considered all items closed. The corrective action is summarized as follows: (1) For Ducts 46.1, 47.1-and Hangers 11 and 12, their travelers l' were voided, the parts were scrapped, and new parts were 4 ordered on Restock Requests. CPCo Overinspections had verified these actions. Training was conducted on i l-Procedures-TQCP-1, FQPC-3, and FQCP-5. (2) For Hanger V26 SH1 Har 9 Traveler 940, the welding procedure and welder's ID were added by NCR C-31. Instructions for painting the welds were added by NCR A 140. Training was the same as indicated in (1) above. CPCo Overinspection was documented in Report 01-M-36A-41. i (3) For Hanger No. V19 SH1 Har. 11, Traveler F942 was corrected by NCR's A-90, C-6 and C-28 to replace the long braces, i remove the diagonal braces, and rework the weld. NCR 62 added the control number of the new material, weld procedures, i and welder identifications. CPCo Overinspections 01-M-36A-41, i 01-M-36A-38 and 01-M-36A-42 documented inspection results. t 't (4) For Hanger V 19 SH1 Har 13 Traveler F944, NCR's A89, C7, C29 ? and A762 added the traveler number to components, removed ~ diagonal braces and added one br' ace. A special inspection report indicated that pieces from Hanger 13 V19 SH1 had been - scrapped. CPCo Overinspections documented in Reports 01-M-36A-41, 01-M-36A-38 and 01-M-36A-42. ( (5) For Hanger V19 SH17 Har 7 Traveler F938, Traveler F938 was voided by F13134 and scrapped per NCR C8. NCR A174 scrapped the replacement hanger 7A. NCR A250 authorized scrapping l hanger 7A which was replaced by material from Restock Request No. 1541 to Traveler F12815. The hanger was accepted by 1, CPCo Overinspection Report 01-M-36A-41. (6) For sections of angle iron without ID number stored in the laydown area, CPCo peformed overinspection of the storage area. Subject materials were traced to Traveler F10470, 1 properly marked, and banded together. Surveys of the laydown area are conducted weekly and problems are reported j to the Project Manager for correction. Training was conducted with cognizant personnel to advise them of the specific problem and methods to prevent recur-rence. CPCo Overinspection Report 01-M-34-29 indicated the ites had been corrected. f
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i (7) For Hanger No. V1 Hgr 3 Traveler F916, The traveler number or control number were not identified on all sub-components of the hanger. NCR C9 was written to replace the 2"x2"x1/4" angle with 3 1/2"x3 1/2"x1/4" angle; NCR A265 authorized I similiar replacement. NCR A553 added the welder identifi-cation and weld procedure to the traveler. NCR C344 added l the material control number; NCR C346 added the longitudinal r; brace; NCR A1015 added the material control numbers and welds. { i j Later another problem, Hilti Drop-In Anchor Bolts, developed (NCR HD19). This problem was c1csed on the basis of CPCo's I NCR M-01-9-1-090. As a result of this problem on July 28, 1981, the hanger was removed and scrapped on September 3, 1981. It was replaced by hanger 3A on V1 Traveler F17152 (unique identification for replacement hangers). 1 (8) For turning vanes without proper ID, the ducts using these i turning vanes were scrapped. These were as follows: (a) Duct No. V03-SH2-2-F9473 (b) Duct No. V10-42B-F10171 (c) Duct No. V10-42D-1-F10172 (d) Duct No. V3-SH2-2B-F128658 The Traveler Nos. were F9437, F10171, F10172 and F12685 respectively and they were voided by NCR Nos. A-96, A-97, C-4 and a special inspection that witnessed and documented scrapping. Restocking Request Nos. 1534, 1535, 1535 and 1534 respectively were issued for replacement material. f. (Closed) Item of Noncompliance, Infraction (329/80-10-07; 330/80-l'l-07): Measures did not assure that welding was accomplished using qualified procedures. Travelers for the five ducts listed indicated the use of a shielded metal are welding process; however, a gas-metal-arc welding process was used to fabricate the ducts. t ) As a corrective measure the travelers for the five ducts were voided and the ducts scrapped as verified by NCR's. A special inspection was made that documented witnessing of the scrapping. Restocking Requests No. 1535 and No. 1534 were issued for re-placement material. The second part of this item of noncompliance states that T welding Procedure No. QCP-1-PSCS used on four ducts listed required the use of carbon dioxide, C0g, as the shield gas. ps l. Carbon dioxide gas was not available at the site; therefore, this procedure could not be followed. I 8 j l Number in NRC Civil Penalty Letter was in error for replacement material. i l 8 f; N 4 e e .f. 3.: '4 3 s i
=-- s A Supplier Deviation Disposition Request No. 1779 was initiated by Zack Company to Bechtel Power Corporation (BPC) to evaluate the adequacy of the welds prior to the use of CDs. i j BPC's evaluation, based on Test AWS D.1.3, indicated weld specimens simulated to the production welds as noted in CPCo NCR No. M-01-0-030 and Quality Surveillance Report No. 102, dated June 6, 1980, were adequate and acceptable. These welds i were not scrapped, travelers are active and installation is in progress. l 3 (Closed) Item of Noncompliance, Infraction (329/80-10-08; j 330/80-11-08): Procedures to control weld filler metal were not followed. 4 (1) E-7018 and E-6011 weld electrodes were found together in an unplugged, uncalibrated, and unserialized weld electrode warming caddy located in the fabrication shop. ane suoject weld electrodes were scrapped. The portable l weld electrode warming caddy was serialized (2026) and calibrated on March 13, 1980. The subject electrodes had only been used for the fabrication of expanded metal lockers 4 f7 in which weld filler metal is stored. This work was in progress during the inspection (week of March 10, 1980). fl The licensee stated that cognizant personnel have received { training relative to acceptable means of handling and con-trolling weld filler metal. CPCo completed Overinspection 01-W-24-16. (2) A review of the temperature records for the portable rod warmer caddies disclosed temperature records did not exist for two caddies. Temperature records for two other caddies. indicated temperature checks were last made prior to i November 1979. kh The licenses reviewed the temperature records of rod warmer I 4 h caddies owned by Zack at the Midland site. After the review A a system was established to calibrate all caddies and to '} maintain calibration records. Training was conducted covering Procedures MB-FQCP-6 Wald Rod Control and MB-FQCP-10 Calibration. CPCo performed two Overinspections, 01-V-2A-17 and 01-W-2A-18. { h. (Closed) Item of Noncompliance, Infraction (329/80-10-09; 330/80-11-09): Welding was not performed in accordance with qualified procedures or no qualified proc.edures covered ASTM A575
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(1) For Duct V2-SH1-1-2A-F8403, the traveler was voided and the duct scrapped per NCR A253. Training was held on WPS-1, Weld Procedure GMAW; WPS-2, Weld Procedure SMAW; and WPS-7, Certification and Qualification of Welders. CPCo performed i l Overinspection 01-M-36A-60. i (2) Sheet metal used in the duct fabrication was ASTM A 527 and the angle iron was ASTM A 36. Welding Procedure .} No. MB-QCP-1 (P-5CS) did not cover these materials. Bechtel j revised Specification 7220-M-151A (Q) Revision II and Zack Company revised their welding procedure to include welding of the above metals. The inspector reviewed this change and checked it for conformance with the American Welding Society, Structural Walding Code, AWS D1.1-75, Revision 2 i (1977) or AWS D1.1 (1979); Specification for Welding Sheet l Steel in Structures, AWS D1.3-1978; Welding Procedures and Performance Qualifications, AWS B3.0-1977, Table 2.1, Para-I graph 2.1 (P1A only); and Specifications for Welding of Sheet Metal, AWS D9.1-80. (3) The fabrication record for duct No. V26 SH2B-46.1 (P1515) indicated angle iron with control number 727-2 was ASTM A575 l material. Since Zack Company did not have a procedure for welding this material, Traveler P1515 was voided and the duct scrapped as documented by NCR C5. CPCo Overinspections 01-M-36A-60 and 01-W-2B-36 documented acceptance. (4) Air Monitor Corporation, under a certificate of conformance dated November 5,1979, welded. air monitors without prior buyer i review and acceptance of welding procedures. i The " Procedure Qualification Record" for Air Monitor Corporation was approved December 29, 1979. Welding Procedure Specifications AM-11B, AM-11E, AM-11H, and AM-11J were approved by Bechtel on the following dates: Revision 1 on April 22, 1980 Revision 2 on July 8, 1980 Revision 3 on October 4, 1980 Approval and acceptance of the air monitors was documented on Overinspection Report 01-M-36A-36. i. (Closed) Item of Noncompliance Infraction (329/80-10-10; 330/80-11-10): Welding activity was not identified by a welder identification number. This item concerned some welds on duct I hangers designated V26 SH1, Nos. 33, 34, 36, 37, 38 and 21A. The corrective action for each hanger was as follows: [8 (1) Hanger 21A, Traveler 12365 / Wald Procedure added per NCR A1105 Hanger to duct weld added per NCR 1552 a 10 f! k i c-- i +
4 (2) Hanger 33, Traveler F3487 NCR A1138, Wald Procedure and Welds added NCR A1607, added certifications (3) Hanger 34 Traveler F3488 NCR A1080, added Weld Procedure i l (4) Hanger 36, Traveler F3490 (later voided by F19101) NCR 72A, welds reworked I NCR A1096, scrapped (5) Hanger 37, Traveler F3491 (voided by F19100) NCR A1097 (Scrapped) (6) Hanger 38, Traveler F3492 (voided by F19099) NCR A1098 (scrapped) i i l CPCo performed Overinspection 01-W-2B-37 to document acceptance. I* j. (Closed) Item of Noncompliance, Infraction (329/80-10-11; 330/80-11-11): Two welders were assigned the same weld stamp, Mo. CU7. An investigation by Zack Company indicated this was an isolated instance identified by Zack Company during an NRC inspection. One of the two welder's ID was changed to CU7B. Each of his welds has bee. restamped with the new identification and l associated travelers were changed accordingly. This was l completed December 3, 1980. I Training was conducted on Procedure WPS-7, Qualification and Certification of Valders. CPCo performed Overinspection 01-V-2A-22. k. (Closed) Item of Noncompliance, Infraction (329/80-10-12; 330/80-11-12): Instructions and procedures for final inspection
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of field fabricated items at the Midland site were not documented. Procedures were revised to provide receipt inspection for h incoming material to be performed by CPCo. CPCo also performs f 4 h/I the fabrication inspection for' items fabricated at the site $$ i fabrication shop. Installed equipment receives a two part i inspection by CPCo. The first part concerns the installation to applicable specifications, codes or procedures. The second inspection is to determine that the installation meets quality acceptance. 1. (Closed) Item of Noncompliance, Deficiency (329/80-1'0-13; 330/80-11-13): Flange to duct welds have undercuts exceeding 1/32 inch. The undercut was reported to be on flange to duct welds on duct No. V26SH2B-47.1-P(1516). 11 [ ) 1 6 9
Traveler P1516 was voided and NCR A97 documents scrapping the duct. Replacement material was ordered on Restocking Request No. 1535. The replacement duct V22SH2A, Duct 47.1A-P3635, was considered complete by CPCo Overinspection 01-M-36A-39. A i training session for QC inspectors was held to clarify what would be identified as undercut. CPCo Overinspection 01-H-3 *A-39 i documented the resolution of the problem. I (Closed) Item of Noncompliance, Infraction (329/80-10-14; s. I 330/80-11-14): Measures which would prevent the inadvertent l use or installation of nonconfo terial had not been established. Duct No. V03 SH2 F9437 as fabricated to Seismic f 7 Class 2 requirements instead o scribed Seismic Class 1 e requirements. 4'4 The traveler for the duct was voided and the duct scrapped as yh h documented on NCR A96. Replacement material was ordered on 4 4 h Restock Request No. 1534. dWI Training was held on Procedure FQCP-8, Control of Nonconformances. CPCo Overinspection 01-M-34A-39 documented the completion of this ites. \\ A second example of this noncompliance concerned nonconforming ..j weld filler materici (no material certification) used in welding a piece of duct identified on Traveler F-9396. The material was ) not identified as being nonconforming. The corrective action consisted of Zack Company issuing a revised procedure to require Material Certifications for filler metal to be on site. The certifications for the weld filler material used on this duct (Traveler F9396) had been in Chicago and were sent to the site. The duct was not considered to be nonconforming; there-fore, nothing was doe with it. CPCo Overinspection 01-W-2B-38 documents closure of this item. (Closed) Item of Noncompliance, Infraction (329/80-10-15; n. 330/80-11-15): Nonconformance tags had been applied to Ruskin NIBD23 fire dampers without explicitly identifying the item by name, piece mark, and item number. On April 18 and 23, 1980, i , 8 white nonconformance tags were observed being used on Ruskin NIB 23 fire dampers stored at the Zack fabrication shop and on hangers installed in the Service Water Building. / An overinspection by CPCo documented the fact that all white NCR tags have been replaced with yellow ones. Also Zack Company NCR's D34-1 through D34-142 list the 142 Ruskin Fire Dampers that were received and this information is documented on the NCR. Dampers were identified as reauf red crior to installation. Training was ' conducted on Procedure FQCP-8, Control of Nonconformances. A list of the Ruskin Fire Dampers is attached to the NCR D34 and documented in CPCo Overinspection Report 01-M-36A-61. 12 't (
o. (Closed) Ites of Noncompliance, Infraction (329/80-10-16; 330/80-11-16): None of the seven nonconformance reports issued by CPCo during the period May 23 through October 2, 1979, had been corrected by March 19, 1980. The seven NCRs referenced above have been closed. The complete revision of the Zack QA Program and other corrective actions taken are described in the introductory pM paragraph to this section. ( i (Closed)ItemofNoncompliance, Infraction (329/80-50-17; f' p. 330/80-11-17): Measures were not adequate to assure that condi-tions adverse to quality were promptly identified. Review of l the Zack Co. noncompliance listings disclosed that 250 pounds (five boxes) of 3/32' diameter, Hobart E6011 weld rod, serial number 90155A, received at the Midland site on May 17 and June 6, 1979, lacked a Material Certification. The boxes were not placed l on hold until March 11, 1980. The remainder of this weld rod, / 450 pounds in nine boxes, was not placed on hold and its use is 7, unknown. f The licensee reported that certification had been received from Chicago and placed on file at the site. Certs for nine(9) boxes of E6011 electrode received on, March 17, 1980, were satisfactory. This completes certification for 14 i boxes of E-6011 3/8" electrode. CPCo's Overinspection documented the results on report 01-M 34A-01. The second example of this noncompliance concerns the receipt, at' the Midland Job Site on Deceimber 15, 1979, of 250 pounds (five boxes) of 3/32" low hydrogen E7018 welding rod which were not marked as nonconforming for being improperly boxed. i 'lhe licensee stated that NCR B127 and NCR 8128 were issued with instructions to ship the improperly boxed E7018 electrode to the supplier. The p'urchase order returned 34 cardboard boxes,14 boxes of 3/32 E7018 welding electrode-AIRCO and 20 boxes 1/8" E7018 welding electrodes-AIRCO. Other documents were presented to the inspector indicating receipt of the shipment by the supplier. q. (Closed) Ites of Noncompliance, Infraction (329/80-10-18; l I 330/80-11-18): Sufficient records to furnish evidence of activities affecting quality were not maintained as evidenced by the fact that equipment inspection records did not exist for i the safety-related fire daspers installed during the period i-November 1979 - January 1980. A review of this ites by the licensee indicated that quality inspection records for the fire j dampers are filed with the associated duct documentation rather I'f than with equipment records as originally believed. The dampers are not listed as equipeent in Bechtel Specification M151A. C'^ p o[ M'
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l ) 1 The licensee also stated that Zack Company inspected all Q listed fire dampers for location and serial number. Deficiencies are documented on the applicable inspection record. The inspection record on all installed fire dampers were checked by Zack Company. The inventory of all fire dampers was completed. i e method of verification consisted of a visual verification of j l inspection records for serial number. location, and discrepancy of installed fire dampers. i' r. (0 pen) Unresolved Item (329/80-34-01; 329/80-35-01): HVAC system fire dampers. The inspector reviewed documentation concerning the seismic calculations for the fire dampers. Specifications required i a 14 gage mullion on the dampers; however, Ruskin furnished the dampers with a 16 gage mullion. i k Bechtel, the licensee's engineer, calculated the seismic require-ments and documented the fact that fire dampers with the 16 gage mullions met seismic requirements. The engineers stated that their calculations indicated the item was_not_s. portable-=du 10 CFR 50.55(e) or 10 CFR Part 21. 1 The item was left open to permit the NRC Resident Inspector an opportunity to determine the reason this item had been reported under 10 CFR Part 21. (Closed) Open Item (50-329/80-15 03; 50-330/80-16-03): A plan s. I for checking the acceptability of bolts, nuts, sad washers upon I receipt was not in place. Technical Specification, 7220-C-121(Q) { dated April 9, 1982, Receipt Inspection Hardness Testing of Bolting and Component Support Material, had been developed, approved'for use, and implemented. 3. 10 CFR 21 and 50.55e Reportable Items (0 pen) 10 CFR Part 21, Ruskin Fire Damper (329/80-01-PP; a. 330/80-01-PP): Applies to negator type closure springs slipping from a spring holding bracket which is used in vertical NIB 023 fire dampers manufactured after June 1979. D e inspector reviewed documentation indicating all fire dampers had been located and identified. Time did not permit the inspector to determine if the damper modification had been completed. This I item and the one documented above will be reviewed by the NRC Resident Inspector. b. (0 pen) 10 CFR 50.55(e) Item (329/79-08-EE; 330/79-08-EE): Hilti Drop-In Anchors did not aset the tension testing requirements. The inspector reviewed the documentation for Hilti Drop-In Anchors concerning the HVAC system installation. Initially on November 30, 1979, there were approximately 900 anchors in the system to be replaced. H e inspector was informed that 100*. replacement was h ( h (\\ required due to the improper method of testing the anchors initially, At present 30 anchor bolts remain to be replaced. Twenty eight A 14 + 1 h* l
d j }. : i of these are in the control room and two are in a hold area. These 30 anchors are scheduled to be replaced when the design 7 changes for those areas are complete. The remaining Hilti Drop-l In anchors are controlled by CPCo NCR M-01-9-1-090, Revision June 30, 1982. This item remains open pending a review of l anchor replacement in the remainder of the plant. .t (Closed) 10 CFR 50.55(e) Reportable Item-(329/81-06-EE; c. 330/81-06-EE): The licensee reported a potentially reportable situation concerning the temperature of structural concrete during operation. The licensee determined that the plant could withstand one or more cycles of loss of the cavity cooling system without causing any detrimental effects on the safety of the plant j . i providing one containment cooling fan was operating. A procedure _ j change requiring one cooling fan to be running during operations had been added to the Site Commitment List (SCL). a i d. (Closed) 10 CFR 50.55(e) Reportable Item (329/81-07-EE; 330/81-07-EE): Westinghouse Electro Mechanical Division gate i valves failed to close against certain differential pressures. This problem was reported in IE Bulletin No. 81-02 and i Supplement 1. Evaluations later indicated that this was not a reportable item and it was withdrawn by the licensee. Evaluations carried out in response'to IE Bulletin No. 81-02 is discussed in j Paragraph 4.c. I (Open) 10 CFR 50.55(e) Reportable Item (329/81-08-EE; e. l 330/81-08-EE): Excessive AC motor starter control voltage drop l l caused by excessive length circuits may have prevented motor starters for Class 1E equipment to pick up under anticipated plant conditions. An evaluation reported in Bechtel Management Correc-i tive Action Report 53 established a list of 40 circuits which. could potentially experience excessive voltage drop. A Safety Analysis Change Notice, DCAR-477 was issued February 2, 1982. l The licensee has not reviewed the corrective actions taken on the i 40 circuits involved. i 4. IE Bulletin Followup i '! ~ For the IE Bulletins listed below the inspector verified that the written response was within the time period stated in the bulletin, that the written response included the information required to be l reported, that the written response included adequate corrective '~ action commitments based on information presentation in the bulletin. and the licensee's response, that licensee management forwarded copies of the written response to the appropriate onsite management repre-sentatives, that information discussed in'the licenses a written response was accurate, and that corrective act'.an taken by the licensee was as described in the written response or if not completed, j. had been added to the site Commitment List. I e e ey n i 15 7I i a - 'h
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(Closed) Bulletin No. 77-04, transmitted to CPCo on November 4, i a. 1 1977 Re: Controlling pH of Containment Sump Water Following a + LOCA. This problem was addressed by revising Paragraphs 6.2.2.1.3 and 6.5.2 of the FSAR. b. (Closed) Bulletin No. 80-09, transmitted to CPCo April 17, 1980 Re: Hydamoter Activator Deficiencies. Twenty-eight units from I three vendors were identified at Midland. Tko were returned to l the supplier for testing and spring replacement; the rest were accepted by reducing design requirements. Revisions to the pre-i operational testing program to include functional testing of } these units are carried on the Site Commitment List. c. (Closed) Bulletin No. 81-02 and Supplement 1, transmitted to CPCo on April 9 and August 18, 1981 Re: Failure of Gate Type Valves to Close Against Differential Pressure. The licensee reported that 30 Westinghouse-Electro-Mechanical Division motor-operated gate valves had been purchased. Tkenty were used in safety-related systems and 10 were spares. A survey of the 20 valves indicated 12 were required to close against i a differential pressure. An evaluation of the 12 installed l valves confirmed that no problems existed with their closure, eval d diff r ta pesuead r he m x num para saible differential pressures to be placed on the valves. j d. (Closed) Bulletin No. 79-07, Transmitted to CPCo on April 14, 1979 Re: Seismic Stress Analysis of Safety-Related Piping. Reviews of submitted seismic computar codes were assigned to i 3, IE HQ and NRR for review and, if required, inclusion in FSAR questions. i 5. IE Circular Followup For the IE Circulars listed below, the inspector verified that the Circular was received by the licensee management, that a review for 4 applicability was performed, and that if the circular were applicable to the facility, appropriate corrective actions were taken or were scheduled to be taken. (Closed) 8 -03 Inoperable Seismic Monitoring Instrumentation 1 (Closed) 81-01 Design Problems Involving Indicating Pushbutton Switches Manufactured by Honeywell, Inc. (Closed) 80-23 Potential Defects in Beloit Power Systems Emergency Generators (Closed) 80-15 Loss of Reactor Coolant Pump Cooling and Natural Circulation Cooldown (Closed) 80-14 Radioactive Contamination of Plant Domineralized Water System and Resultant Internal Contamination of Personnel l 16 I' 1 '. + n-. At .f g 4[.
i l \\ (Closed) 80-13 Grid Strap Damage in Vestinghouse Fuel Assemblies (Closed) 80-12 Valve-Shsft-To-Actuator Key May Fall Out of Place When F.ovnted Below Horizontal Axis (Closed) 80-11 Emergency Diesel Generatcr Lube Oil Cooler Failures (Closed) 80-09 Problems With Plant. Internal Communications Systems (Closed) 80-07 Problems with HPCI Turbinc 011 System (Closed) 80-04 Securing of Threaded Lecking Devices on Safety-Related Equipment (Closed) 80-02 Nuclear Power Plant Staff Work Hours (Closed) 80-01 I Service Advice for GE Induction Disc Relays (Closed) 79-25 Shock Arrestor Strut Assembly Interference I (C1csed) 79-22 Stroke Times for Power Operated Relief Valves (Closed) 79-21 Prevention of Unplanned Role tset, of Radioactivity (Closed) 79-20 Failure of GTE Sylvania Relay Type PM Bulletin No. 7305, Catalog SU12-11-AC with a 12V AC Coil (Closed) 79-19 Loose Locking Devices en Ingersoll-Rand Pumps (Closed) 79-18 Proper Installation of Target Rock Safety-Relief (Closed) 79-17 Contact Problem in SB-12 Switches on General Electric Company Met 41 clad Circuit Breakers (Closed) 79-13 Replacement of Diesel Fire Pump Starting Contractors (Closed) 79-04 Looso Locking Nut on Limitorque Valve Operators (Closed) 79-10 Pipafittings Manufactured from Unacceptable Material (Closed) 78-19 Manual Override (By Pass) of Safety Actuation Signals (Closed) 78-00 Environmental Qualifiestion of Safety Related Equipment at Nuclear Power Plants (Closed) 78-07 Desaged Componenes of a Bergen Paterson Series 25000 Hydraulic Test Stand (Closed) 78-04 Installation Error That Could Prevent Closing of Fire Doors (Closed) 78-03 Packaging Greater Thu Type A Quantities of Low Specific Activity Radioactive Material for Transport f 17 f
.t = (Closed) 77-16 Emergency Diesel Generator Electrical Trip Lock-out Features., (Closed) 77-15 Degradation of Fuel Oil Flow to the Emergency Diesel Generator. i (Closed) 77-14 Separation of Contaminated Vater Systems from l Uncontaminated Plant Systems (Closed) 77-13 Reactor Safety Signals'Nescted During Testing (Closed) 76-03 Radiation Exposures in Reactor Cavities a 6. IE Information Notices i For the IE Information Notices listed below the inspector verified that the Notice had been received and appropriate reviews made. 81-03 Check list for Licensee's Making Notifications of Significant Events } 80-44 Actuation of ECCS in the Recirculation Mode While in Hot Shutdown 80-43 Failures of the Continuous Water Level Monitor for The Scras Discharge Volume at Dresden Unit No. 2 is 80-42 Effect of' Radiation on Hydraulic Snubber Fluid l 80-41 Failure of Swing Check Valve in the Decay Heat Removal System at Davis-Besse Unit No. 1 30-40 Excessive Nitrogen Supply Pressure Actuates Safety-Relief Valve Operation to Cause Reactor Depressurization 40-39 Malfnnctions of Solenoid Valves Manufactured By Valcor Engineering Corporation 80-38 Cracking in Charging Pump Casing Cladding 80-36 Failure of Steam Generator Support Bolting 80-34 Boron Dilution of Reactor Coolant During Steam Generator Decontamination 80-32 Clarification of Certain Requirements for Exclusive - Use Shipments of Radioactive Materials 80-31 Maloperation of Gould-Brown Boveri Type 480 Volt Type K-6005 and K-DON 6005 Circuit Breakers b[ 80-21 \\ Anchorage and Support of Safety-Related Electrical Equipment 9 i g e le 4 s I h1 J' ,-..n! ,i * )
l [ I 80-19 NIOSH Recall of Recirculating-Mods (Closed-Circuit) Self-l Centained Breathing, Apparatus '(Rebreathers) f' l 80-16 Shnft Seal Packing Causes Bin',iing in Main Steam Swing Check. l and Isolation Valves i; 80-15 - Axial,(Longitudinal) Oriented Cracking in Piping s I 80-14 Safety Suggestions from Empleyees ~ j { 80-12 Instrument Failure Causes Opening of PORV and Block Val'Je i 80-11 General Probless'with ASCO Valvss, in Nuclear application j In-luding Fire Protection Systems 80-10 Partial Loss af Non-Nuclear Iratrument System Power Supply Dering Oparation t } 80-08 The States Company Sliding Link Electrical Terminal Block 80-07 h' ump Shaft Fatigua Cracking 80-05 Chloride Contanination of Safety Relate'd Pipias ~ 80-03 Main Turbine Electro-liydraulic Control Syhtem 8K8R W'ter Rod 1-ower End Plug Wear 80-02 a l 80-01 Fuel Handling Events w -- 1 79-36 Computer Code Defect in Stress Analysis of Piping Elbow l 79-34 Inadequate Design of Safety-Related Heat Exchangers - i (. .E 79-31' Use of Incorrect Amplified ResponzesSpectra (AFS) 79-27 . Sterun Generator Tube Ruptures At Two PWK Facilities + 79-26 Rfsach of Containment Integrity 79-25 Reactor Trips ot, Turkey' Point Unies 3 arul 4 79-54 0verpressurization of Containment of a PWR Plant After a Main Steam Line Break 79;23 Emergency Diesel Generator Lube Oil Coolers ' : C 79-10 Nonconforming Pipe Support Struts 7 Degradation c f Engineered' Safety [f[atures 79-04 79-03 LimitorqueValveGearedLikitSwltchLubriEant h. y [.y } a . a .a
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79-02 Attempted Extortion - Low Enriched Uranium t 79-01 Bergen-Paterson Hydraulic Shock and Sway Arrestor I 7. Exit Interview 1 The inspector met with licensee representatives (denoted in Paragraph 1) I at the conclusion of the inspection on July 9, 1982, and summarized the I scope and findings of the inspection activities. t i 1 i i h I l l 1 1 e u l ,I ' l 20 1! Ti.*
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..e n : e (.(' PAGE 1 REGION III TRACKING SYSTEM M10LANO ='OPEN ITEMS LIST 06/16/83 REPORT NUM8ERS 80-10 AND 80-11 L' COMPLETE LISTING / ITEM RESOLUTION ) ITEM NO./ INSPECTOR / ITEM TYPE / FACILITY NANC LICEh5EE INTERIM INSPECTOR CLosE0UT j' ~ RESPONSE 00E-NODULE NO. BRIEF DESCRIPTION DESIGNATED NO. INSFECTION AS$1GNED REPORT NO. f .329/80-10-01 WEIL ITEM WITHORAWN MIDLANO 1 JONES SEE NOTE t ! ~(z 1 - PROCUREMENT DOCUMENT CONTROL - CRITERIA IV NOTE: THIS ITEM WITMORAWN SY RIII C i 329/80-10-02 WEIL ITEM OF NONCOMPLIANCE MIDLANO 1 JONES 82=15 '( 2A - INSTRUCTION PROCEDURES ANO DRW95 - CRITERIA V ( 329/80-10-03 WEIL ITEM OF NONCOMPLIANCE MIOLANO l' JONES 82-15 ( fat 33-WELDERS IO NOT RECORDF0 DN TRAVELERS - CRITN V ( 4 329/80-10-04 WEIL ITEM OF NONCOMPLIANCE MIDLANO 1, JONES 82-15 5 i .28-UNAPPROVEO MARKING MATERIAL - CRITERIA V ( -329/80-10-05 WEIL ITEM OF NONCOMPLIANCE MIDLANO 1 JONES 92-15 5 (, 3-CONTROL OF PURCHASED MATRL EQUIP ANO SERVICES - CRITERIA VII ( 329/80-10-06 WEIL ITEM OF NONCOMPLIANCE NIDLANO 1 JONES 82-15 s A-IDENT AND CONTROL OF MATRL PARTS AND COM*0NENT,5-CRITERIA'VIII .( l S 2 329/80-10-07 WEIL ITEM OF NONCOMPLJANCE MIDLAND 1 JONES 82-15 f., 5A-CONTROL OF SPECIAL PROCESS - CRITERIA IX 329/80-10-08 . EIL ITEM OF h0NCOMPLIANCE, MIDLAND 1 i JONES 82-15 W '58-WELD FILLER MATRL PROCEDURES NOT FOLLOWED-CRITERIA IX s. y .9 b O. s 4g
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PAGE 2 REGION !!! TRACKING SYSTEM 06/16/83 M10LANO
- OPEN ITEMS LIST REPORT NU48ERS 80-10 AND 80-11 I
COMPLETE LISTING I( ITEM RESOLUTION -^ C ITEM No./ INSPECTOR / ITEM TYPE / FACILITY NAME LICENSEE INTERIM INSPECTOR CLOSE0UT C RESPONSE DUE MODULE NO. BRIEF DESCRIPTION DESIGNATED NO. INSPECTION ASSIGNED REPORT NO. ( 329/80-10-09 WEIL ITEM OF NONCOMPLIANCE MIDLAND 1 JONES 82-15 ( 5C-WELDING'NOT PREFORMED IN ACCORD WITH PROEDRE-CRITERIA IX C. 329/80-10-10. WEIL ITEM OF NONCOMPLIANCE MIDLAND 1 JONES 82-1S il SD-WELDING NOT IDENTIFIED BY WELDERS I.D. NO.-CRITERIA IX- { C 329/80-10-11 WEIL ITEM OF NONCOMPLIANCE MIDLAND 1 JONES 82-15 5E-2 WELDER ASSI8MED SAME WELD STAMP-CRITERIA IX ( Q 329/80-10-12 WEIL ITEM OF NOE OMPLIANCE MIDLAND,1 JONES 82-15 (. 6A-NO PROG FOR FINAL INSPECT OF FIELD FAB ITEMS - CRITERIA X d '( 329/80-10-13 'WEIL ITEM OF NONCOMPLIANCE MIDLAND 1 JONES 82-15. ) 68-#R06 RAM FOR INSPECT WAS NOT ADEQUATE - CRITERIA X '( Q 329/80-10-14 WEIL ITEM.0F NONCOMPLIANCE MIDLA'ND 1 JONES 82-15 ( Q TA-NO MEASURES TC PREVENT USE OF NONCONFORMIN8 MATERI AL. - CRITERIA XV L WEIL ITEM OF NONCOMPLIANCE MIDLAND 1 JONES 82-15 329/80-10-15 T8-NONCONFORMANCE REPORT TABS DID NOT IDENTIFY FIRE DANPER-CRITERIA XV , l' u 320/80-10-16 WEIL ITEM OF NONCOMPLIANCE, MIDLAND 1 JONES 82-15 L .) 84-NONCONFORMANCE REPORT NOT CORRECTED PROMPTLY-CRITERIA XVI v
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.C PAGE 3 REGION III TRACKING SYSTEM 06/16/83 MIDLANO - OPEN ITEMS LIST f REPORT NU4BERS 80-10 AND 80-11 COMPLETE LISTING l O ITEM RESOLUTION 1 (i ITEM No./ INSPECTOR / ITEM TYPE / FACILITY NAME LICENSEE INTERIM INSPECT 04 CLOSE0UT 3 RESPONSE OUE MODULE NO. BRIEF DESCRIPTION DESISMATED NO. INSPECTION ASSISMED REPORT NO. '{ 329/80-10-17 WEIL ITEM OF NONCOMPLIANCE MIDLANO 1 JONES 82-15 ( 88-CONDITIONS ADVERSE TO QUALITY NOT IDENTIFIED-CRITER,IA XVI ~ @s C 329/80-10-14 WEIL ITEM OF NONCOMPLIANCE MIDS J40 1 JONES 82-15 G 9-MAINTAINING OUALITY INSPECTION RECORDS-CRITERIA XVII * ( Q .329/80-10-19 WEIL ITEM WITMORAWN MIDLANO 1 JONES SEE NOTE ( 0 10-AUDITS CONOUCTED SY INAPPROPRIATE PERSONNEL NOTE 8 TMIS ITEM WAS WITHORAWN SY RI!!- ( t 0 330/80-11-01 WEIL ITEM WITHORAWN ' MIDLANO 2 JONES SEE NOTE 1
- PROCUREMENT l>0CUMENT CONTROL - CRITERIA IV NOTE: THIS ITEM iITHORAWN SY RIII.
(~ ) 330/80-11-02 WEIL ITEM OF NONCOMPLIANCE MIDLANO 2 JONES 82-15 2A - INSTRUCTION PROCEDURES ANO DRWe$ = CRITERIA V 1 9 330/80-11-03 WEIL ITEM OF NONCOMPLI A MCE ' MIOLAND 2 JONES 82-15 2A(31-WELDERS ID WOT RECORDEO ON TRAVELERS - CRITN V dl L 330/80-11-04 WEIL ITEM OF NONCOMPLI A KE MIDLANO 2 JONES 82-15 )! 28-UNAPPROVED MARKING MATERIAL - CRITERIA V .) ' 330/80-11-05 WEIL ~ ITEM OF NONCOMPLIAWCE MIDLAND 2 JONES 82-15 gl 3-CONTROL OF PURC1ASED MATRL EQUIP AND SERVICES - CRITERIA VII l e vi
.e. s.4. ? ~ ~m 2,, ( '( 0 PC6E 4 REGION III TRACKING SYSTEM 06/16/83 MIDLANO - OPEN ITEMS LIST REPORT NUMBERS 80-10 AND 80-11 C' COMPLETE LISTING 'N C ITEM RESOLUTION 1 ( ITEM NO./ INSPECTOR / ITEM TYPE / FACILITY NAME LICENSEE INTERIM ' INSPECTOR CLOSEOUT 9 RESPONSE DUE MODULE NO, BRIEF DESCRIPTION DESIGNATED NO. INSPECTION ASSIGNED REPORT NO. ( 0 330/80-11-06 WEIL ITEM OF NONCOMPLIANCE MIDLANO 2 JONES 82-15 ( 4-IDENT AND CONTHOL OF MATRL PARTS AND COMPONENTS-CRITERIA VIII O (' '330/80-11-07 WEIL ITEM OF NONCOMPLIANCE MIDLAND 2 JONES 82-15 O g 5A-CONTROL OF SPECIAL' PROCESS'- CRITERIA'IX 330/80-11-08 WEIL ITEM 0F NONCOMPLIANCE. MIDLANO 2 JONES 82-15 ( 0 58-WELD FILLER MATRL PROCEDURES NOT FOLLOWED-CRITERIA IX, ~ ~ l Q 330/80-11-09 WEIL ITEM OF HONCOMPLIANCE MIDL#NO 2 JONES 82-15 1 5C-WELDING NOT PREFORMED IN ACCORD WITM'PROCORE-CRITERIA IX. 3 1 330/80-11-10 WEIL ITEM OF NONCOMPLIANCE MIDLAND 2 J3NES 82-15 3 e SD-WELDING NOT IDENTIFIED BY WELDERS !.D. NO.-CRITERIA IX 330/80-11-11 WEIL ITEM OF NONCOMPLIANCE MIDLANO 2 ^ ~ JONES 82-15 1-. O SE-2 wet. DER ASSIGNED SAME WELD STAMP-CRITERI A IX p .) 330/80-11-12 WEIL ITEM OF NONCOMPLIANCE MIDLAND 2 JONES 82-15 [ 6A-NO PR06 FOR FINAL INSPECT OF FIELD FAB ITEMS - CRITERIA X d L 330/80-11-13 WEIL ITEM OF NONCOMPLIANCE MIDLAND 2 JONES 82-15 -) 68-PROGRAM FOR INSPECT WAS NOT ADEQUATE - CRITERIA X L s a e . g l 1
s PAGE 5 REGION III TRACKING SYSTEM 06/16/83 MIDLAND - OPEN ITEMS LIST REPORT NUMBERS 80-10 AND 80-11 COMPLETE LISTING ^' I ITEN RESOLUTION O: 1 [ ITEM NO./ INSPECTOR / ITEM TYPE / FACILITY NAME LICENSEE INTERIM INSPECTOR CLOSEOUT-RESPONSE-DUE MODULE NO. BRIEF DESCRIPTION DESIGNATED NO.. INSPECTION ASSIGNED REPORT NO. s. 330/80-11-14 WEIL ITEM OF. NONCOMPLIANCE MIDLAND 2 JONES 82-15 TA-NO MEASURES TO PREVENT-USE OF NONCONFORMING MATERIAL - .) 5 -CRITERIA XV 330/80-11-15 WEIL ITEM OF NONCOMPLIANCE MIDLAND 2, ~ J'NES 82-15 O T8-NONCONFORMANCE REPORT'.TA85 DID NOT IDENTIFY FIRE DAMPERa 1 CRITERIA XV 330/80-11-16 WEIL ITEM 0F NONCOMPLIANCE
- MIDLANO 2 JONES 82-15 8A-NONCONFORMANCE REPORT NOT. CORRECTED.PROMPTLY-CRITERIA XVI;
) (; 330/80-11-1T ~WEIL ITEM 0F NONCOMPLIANCE MIOLANO'2 JONES 82-15 ,T 88-CONOITIONS. ADVERSE TO QUALITY NOT IDENTIFIED-CRITERIA XVI . ) 338/80-11-18 WEIL ITEM OF. NONCOMPLIANCE MIDLANO 2 JONES 82-15 O 9-MAINTAINING OUALITY INSPECTION RECORDS-CRITERIA XVII. ) .WEIL ITEM WITHDRAWN MIDLANO.2 JONES SEE NOTE 330/80-11-19 10-AUDITS CONDUCTED BY INAPPROPRIATE PERSONNEL' NOTE THIS ITEM WAS WITHDRAWN BY RIII 6 4 p y g J.
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"APR 0 7 563 i Docket No. 50-329 Ddeket No. 50-330 gg CInsumers Power Company ATTN: Mr. James W. Cook h $ Vice President / Midland Project h @,p 1945 West Parnall Road Jackson, MI 49201 Centlemen: 10 s This refers to the routine safety inspections conducted by Messrs. B. L. Burgess, R. J. Cook, R. N. Cardner, R. B. Landsman, and W. D. Shafer of this office on January 22 - February 20, 1983 of activities at Midland Nuclear 3 Power Plant, Units 1 end 2, authorized by NRC Construction Permits No. CPPR-81 and No. CPPR-82 and to the discussion of our findings with Mr. R. A. Wells and others at the conclusion of the inspection. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel. During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix. A written response is required. Regarding examples B and C of the item of noncompliance relating to the 0 Forms which were used to document nonconformances instead o using the required corrective action forms, the staff considers that these violations are similar to the previous In Process Inspection Notice violation for which escalated enforcement action was taken. We have decided not to pursue escalated enforcement in this matter because these violations occurred within the same time frame as those for which the escalated enforcement was taken on February 8, 1983. However, you are requested to review your quality program and ensure that no other informal i documents are being used to identify nonconforming conditions that are not being included in your corrective action system. Please provide a sworn statement attesting to your review effort and the findings made therein. Im-accordance with 10 CIlt 2.790(a), a copy of this letter and the enclosure (s) will be placed in the NRC Public Document Room unless you notify this office, l by telephone, within ten days of ther date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. quirements of 2.790(b)(1).Such application must be consistent with the re-t If we do not hear from you in this regard within j j the specified periods noted above, a copy of this letter, the enclosure (s), and i your response to this letter will be placed in the Public Document Room. t ~ ppv* ~ t
I en 3 i Consumers Power Company 2 APR07FM j W will gladly discuss any questient you have concerning this inspectic Sincerely, Criginal ct: nod by Jacm; G. Ikp,.I;r James G. Keppler ~ ~ Regional Administrator
Enclosures:
1. Appendiz, Notice i of Violation i 2. Inspection Report No. 30-329/S3-03(OSC) and No. 50-330/83-03(OSC) ~~~ cc w/encls: DMB/ Document Control Desk (RIDS) Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, AS*B The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB l William Paton, ELD Michael Miller i Ronald Callen, Michigan i Public Service Commission Myron M. Cherry Barbara Stamiris Mary Sinclair Wendell Marshall Colonel Steve J. Gadler (P.E.) Howard Levin (TERA) l I l \\ Leu.wered En Ly .TE a"4(ema9ed [.Kidg[es) RIII R I RI RIII RIII RI I RIII I 6% 20 wvs G&rdner/np 1 man ger Warnick Schultz vis b levis K lt 8 g 03/30/83 4+% 1/C 'l 4 "t, e = b b 9
6 i The licensee was using ACI 336 as his basis for not vibrating. The j inspector informed the licensee that this publication was intended for circular drilled piers, better known as caissons. In fact, the l publication stated that this document was not to be used for* rectangular piers. + t . The licensee continued to insist on not vibrating because they planned _ to use a superplasticizer. The inspector contacted various consultants including the Corp of Engineers and PCA. The overwhelming consensus was that using a superplasticizer was not a substitute for good concreting Practices. The licensee, after considerable discussion finally agreed to vibrate all underpinning concrete in accordance with good engineering practice. I i Another concern raised by the inspector was that they were going to allow a free fall of concrete of ten feet. With the high slump caused by the superplasticizer, this would almost surely have resulted in segregation of the concrete. Subsequently, the licensee decided not to use a super-Plasticizer. The inspector informed the licensee that previously accepted site concrete specifications and procedures only allowed for a free fall of five feet. The licensee agreed to limit the height of fall to an industry standard of five feet. 7. Remedial Soils Work Activities The inspectors reviewed and authorized the following work activities during the report period: Proofload jacking of the East and West FIVP. a. b. Shallow probing to locate electrical ductbanks at BWST's #1 and #2. Conversion of seven existing water wells used to repair the 72" lake c. fill line to support SWPS devatering. d. Release feedwater pipe hanger on East FIVP and install additional dial gauges during proofload jacking. The licensee completed concreting of piers 12W and 12E during the report period. 8. Alleaations I An inspection was conducted to address allegations concerning the Midland Plant cottained in an affidavit received by NRC RIII. The inspectors contacted the alleger by telephone on February 17, 1982, and interviewed the alleger at his residence later the same day. The followi)g allegations were addressed: Allegation No. 1: He has personally seen circumstances that suggest heavy alcohol consumption by workers on the job. Plant workers are purchasing alcoholic beverages at Owens Party Store while on their way to work. -I i 6 l 6 f
yl-l / Review: There were no specific details the alleger could { or would provide which related to poor workmanship or which resulted in damage to equipment due to j onsite' alcohol censumption. The NRC resident inspectors continually tour the site and have not observed any onsite consumption of alcohol. The licensee has the responsibility to prevent the onsite consumption of alcohol.
== Conclusion:== Due to the lack of specific information provided by the alleger during the interview and in his affidavit and the absence of objective evidence found during the NRC review, there was insuf-1 ficient basis for continued NRC investigation l into this allegstion. (Closed 329/82f01-01; 330/82701-01) b. Allegation No. 2: Plant worker informed me that some truckers, for fifty dollars, will pick up anything in the j plant they can carry - piping, tools, weld rod, material, etc. - and deliver to purchasers residence. He says this is common knawledge. Rev.ew: The alleger would not provide the NRC with the names of any individuals who.llegedly had specific information in regards to this matter, nor could the alleger furnish such specific information.
== Conclusion:== There was insufficient information for con-tinued NRC investigation. (Closed 329/82901-02; 330/82901-02) h Allegation No. 3: Other employees told me that Midland workers manufacture pipes and belt buckles out of nuclear material wh'le they are idle on the i job. I have personally seen such around town. Review: The alleger could not provide the NRC with information indicating that the installation of nuclear grade material or equipment had been jeopardized by the manufacture of pipes and belt buckles onsite. Misuse of material used in manufacture of buckles and pipe is a licensee concern - not an NRC regulatory concern.
== Conclusion:== As stated in the review, misuse of daterial to manufacture pipes and belt buckles is not a NRC concern. In addition, there was insufficient l informatior. to justify continued NRC invest-l igation. (Closed 329/82f01-03; 330/82f01-03) l i t l l i 3 7 i-t 3 i t 1 g
7 d. Allegation No. 4: A security suard told me that a panel was l missing from the back of the control room. I Employees enter freely. This may explain some of the vandalism in the control room, which has been plagued with ripped out wires. tut cables and splattered paint. Review: The alleger would not prcvide the NRC with the names of any individuals who supplied or could i supply additional information. The instance of i vandalism which the alleger had general knowl-edge of dealt with an incident which occurred i approutsately two-and one-half years ago. The licensee has recently established a security watch for the control room which precludes the uncontrolled access to the control roca.
== Conclusion:== Lack of specific information rega. ding in-l stances of onsite vandalism involving safety l related systems and components negates further NRC investigation of this matter. (Closed 329/82#01-04; 330/82#01-04) e. Allegation No. 5: Gambling is widespread, involving general fore-men who run pools of up to one hundred dollars per member on games such as sportscore. He has heard that general foremen receive a cut of the operation. Me is fearful that good workers will be retaliated against because of a bad debt causing conflicts with plant construction quality. Review: The alleger would not provide the NRC with the names of any individuals who could provide specific information in regards to this alle-gation. The alleger's references to gambling related to sporting events such as football pools. The alleger had'no personal knowledge of any instances in which construction quality was affected by onsite gambling.
== Conclusion:== There is insufficient information which would facilitate the continued NRC investigation into this matter. (Closed 329/82P01-05; 330/82#01-05) f. Allegation No. 6: A Bechtel inspector who was a relative of a neighbor made internal challenges to plant construction and was rebuffed. The -individual left Bechtel, and upon his return several years later, stated that construction was still stymied by the same defects that had been present two years earlier. 8 yl I l i + [ ?
a r Review: The alleger would not provide the NRC with I, the names of any individuals who could provide specific information in regards to this alle-gation. The alleger did not have personal knowledge of any construction defects alluded to in the allegation.
== Conclusion:== The NRC has insufficient information which would facilitate the continued investigation into this i matter. (Closed 329/82#01-06; 330/82#01-06) g. Allegation No. 7: Consumers Power Company is rushing completion of the plant and is making repairs prematurely f before obtaining NRC approval. Review: The alleger stated that the issue of premature repairs pertained to the work on items for which design changes were made due to NRC required changes. The alleger stated that the costly repairs were also due to poor icitial workmanship which was caused by poor licensee management controls. The alleger could not identify any specific component quality concerns.
== Conclusion:== The allegation dealt exclusively with monetary 4 I concerns and not with component quality concerns. Due to the lack of specific quality concerns there was insufficient information for cor.tinued NRC investigation. (Closed 329/82#01-07; 330/82f01-07) h. Allegation No. 8: An electrician said that he has to do the same work over and over. Wrong sized conduits have been installed that had to be ripped out and S replaced with larger conduits. Review: The alleger would not pr' ovide the NRC with the name of the source of this allegation or with the names of any individuals who Tould provide specific information in regards to this allega-tion. The alleger stated that there was no known instance in which wrong sized conduits were installed and not subsequently replaced with the proper sized conduit. The alleger stated that the allegation pertained to excessive financial waste and not to quality concerns.
== Conclusion:== The allegation dealt with menetary oncerns and not with component quality concerns Monetary issues are not within the purview of the NRC. (Closed 329/82#01-0S; 330/82#01-08) i t i 9 ') t l A j ,'9
I [' i. j Allegation No. 9: Many workers shove their garbage in pipes and then later close the pipes up with the garbage still.there. i i Review: The alleger would not provide the NRC with the names of any individuals who supplied or who could supply additional information in regards to this issae. The preoparational testing program will flush and conduct performance demonstrations of each safety related system. Flushing procedures of safety related systems require both a visual inspection of strainers to determine the amount and extent of contam-inants within the system and a chemical check performed by a qualified chemist to ensure system water chemintre A uithin specifications. L.ombined, these tests would detect the presence of contaminants such as' garbage, etc. I
== Conclusion:== At this time, the NRC has not been given sufficient information which would facilitate the continued investigation into this matter. (Closed 329/82#01-09; 330/82f01-09) j. Allegation No. 10: Another consequence of excessive haste is gross financial waste. Review: The alleger acknowledged that this allegation dealt with financial waste and not with plant quality concerns, i
== Conclusion:== The allegation dealt with cost concerns and i not with component quality concerns. Monetary concerns are not within the NRC purview. (Closed - this issue was not included in the RIII tracking system) 9. Quality control Inspector Training and Recertification Activities } During this inspection period the following balance of plant Quality l Control (QC) training and certification activities were reviewed: I The written eram bank of questior_s pertaining to Project Quality a. l i Control Instructions (PQCI) E-4.0, Cable Installations, and E-5.0, l Cable Terminations, were reviewed. The questions were relevant and t pertinent to the respective PQCI's. b. A performance demonstration was observed during which a prospective { QC inspector attempted to demonstrate his knowledge of the electri-cal cable installation requirements. The prospective QC inspector failed to demonstrate acceptable knowled e of cable installation 2 a requirements. MPQAD personnel informed the prospective QC inspector L L 10 b W 4 I l
s: 3 p% tn Gy D h, UNITED STATES .,g%, NUCLEAR REGULATORY COMMISSION i REGION lli 3 ( 4Qf 70s noosevett noAo f,, g *%a j attn ettyN. lLLINOIS 6ou? - l JUN 3 0 993 v Docket No. 50-329 .g,/y Docket No. 50-330 9 l Consumers Power Company t ATTN: Mr. James U. Cook ' l Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 Gentlemen: i This refers to the routine safety inspection conducted by Messrs. B. Burgess, l j R. Cook, R. Gardner, R. Landsman and J. Harrison of this office on March 21 through May 20, 1983, of activities at Midland Nuclear Power Plant, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-81 and No. CPPR-82 and to the discussion of our findings with Mr. J. Cook and others at the i conclusion of the inspection. N The enclosed copy of our inspection report identifies' areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel. During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix. A written response is required. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s), will be placed in the NRC Public Document Room un'less you notify this office, by telephone, within ten days of the.date of this letter and submit written application to withhold information contained therein within thirty days of-the date of this letter.. Such application must be consistent with the re-quirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosure (s), and your response to this letter will be placed in the Public Document Room. k L I l 4 1 .I I f t 3 M/ i e
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\\ Consumers Power Company 2 t j ~' ~ We will gladly discuss any questions you have concerning this inspection. Sincerely, hl5])L0b.M)ltlll { q. f-kl t Locch ~ l R. F. Warnick, Director .t j Office of Special Cases
Enclosures:
l 1. Appendix, Notice i of Violation i 2. Inspection Reports No. 50-329/83-10(OSC) and No. 50-330/83-10(OSC) cc w/encls: DMB/ Document Control Desk (RIDS) Resident Inspector, RIII TheHonorableCharlesBechhoefer,ASLb The Honorable Jerry Harbour, ASLB ~ - The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB William Paton, ELD Michael Miller Ronald Callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris Mary Sinclair Wendell Marshall Colonel Steve J. Cadler (P.E.)- Howard Levin (TERA) Billie P. Carde, Government Accountability Project Lynne Bernabei, Government Accountability Project j ? l RIII RII RII RII I' W h Ha}tison f*v Cardner/sv Lin n W .ick 06/29/83 gl3o/63 g/g)g J -{ -'j .? ,4 1 m 'f w.,
8 tim Appendix /' NOTICE OF VIOLATION Consumers Power Company Docket No. 50-32 l l Docket _No. 50-330 ? As a result of the inspection conducted on Narch 21 through May 20, 1983, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violation was identified: 1 10 CFR 50, Appendix B, Criterion XV states, in part, " Measures shall be i established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or in-stallation. These measures shall include, as appropriate, procedures for l identification, documentction, segregation, disposition, and notification I en arr.,c.a nrge.,4. 4-- Contrary to the above, the licensee did not have measures to control I heating, ventilation and air conditioning (HVAC) components stored in the Poseyville Road laydown area which would prevent the inadvertent use of nonconforming items. Procedures did not exist whic.h required identification, documentation and segregation for HVAC items of que'Attonable quality stored in proximity to acceptable safety related items at the laydown area. This is a Severity Level IV violation (Supplement II). Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written state-ment or explanation in reply, including for each item of noncompliancei (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full com-pIfance will be achieved. Consideration may be given to extending your' response time for good cause shovn. Date R. F. Karnick, Director Office of Special Cases ~ gl- ) 5 R e
U.S. NUCLEAR REGULATORY COMMISSION [ REGION III Reports No. 50-329/83-10(OSC); 50-330/83-10(OSC) Docket Nos. 50-329; 50-330 Licenses No. CPPR-81; CPPR-82 i Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 l Facility Name: Midland Nuclear Power Plant Units 1 and 2 Inspection At: Midland Site, Midland, MI Inspection Conduct.ed: March 21 through May 20, 1983 h b Inspectors: B. L. Burgess (c 50/9,3 Dated h O'h N30 h 3 R. J. Cook Dated Qg l R. N. Gardner b. Dated i LV .yA [ 5c -83 R. ..andsman 4 g Dated Approved By: J. J. Harrison, Chief So /@ 3 Section 2. Midland Dated Inspection Suunary Inspection on March 21 through May 20, 1983 (Reports No. 50-329/83-10(OSC); 50-330/83-10(OSC)) Areas Inspected: Training and certification of MPQAD personnel, Bechtel-secrecy agreement, Atomic Safety and Licensing Board (ASLB) hearing, meeting to discuss.the Construction Completion Frogram (CCP), meeting of Caseload Forecast Panel, resident inspector investigation of allegations, heating, ventilation, and air conditioning (HVAC) welding, HVAC laydown area storage, core internal inspection, remedial soils work activities, and plant tour. This inspection involved a total of 405 inspector-hours onsite by five NRC j inspectors including 57 inspector-hours during off-shifts. 'l '~ { [ /..- l 1 C{T f. ~ ,__a w
Results: Of the eleven areas inspected, no items of noncompliance or ( deviations were identified in ten areas; one item of noncompliance was identified in the remaining area (inadequate storage facilities for HVAC - ~~ components - Paragraph 9). 1 W 9 .s. ] 9 l r... ? i I i 1 4 .u. 2
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[ i DETAILS I l i ' '( 1. Persons Contacted l l 1 l Consumers Power Company (CPCo) ~ ' ' " ' i g J. W. Cook, Vice President R. Wells, MPQAD, Executive Manager ~ D. Miller Site Manager J. Mooney, Executive Manager M. Curland, MPQAD Site QA Superintendent L. Botimer, MPQAD, Training Records Supervisor i l C. Evert, MPQAD, Training Manager E. Jones, MPQAD, QA Engineer J. Meisenheimer, MPQAD, Soils QA Superintendent B. Peck, Construction Superintendent R. Wheeler, Technical Section Head F * ' ?:- :r Ce. yei e Gun ~ M. Dietrich, PQAE J. Rutgers, Project Manager i D. O' Dell, Personnel Manager 2. 1 Training and Certification of MPQAD Pers nnel 4 On May 18, 1983, the inspector observed the review session of the i licensee's Quality Control (QC) recertification training to Project I Quality Control Instruction (PQCI) E-2.1. This PQCI deals with the inspection requirements for cable tray supports. During the reviev j session the inspector solicited comments from the trainees in regards to the adequacy of the QC training program. Comments received by the inspector indicated the following: i the training was such that the trainees' vere obtaining adequate a. knowledge of inspection requirements, b. questions raised during the training sessions were being answered prior to inspector certification, c. the QC trainees were allowed to postpone a recertification i examination if they felt additional training was needed. d. In one instance the trainees were not given sufficient time in which to read handouts and course materials prior to initiation of training to a PQCI. Subsequent to this review session, the inspector discussed the QC trainee's commente with Mr. R. Wells, the QA Manager. ( O 3 Y. ~ e-, } g I 4
~ The inspectors reviewed the qualifications and certifications of 36 NPQAD personnel performing quality assurance, quality control, and i auditing functions. The documents reviewed included resumes, training g i records, specific, general, and performance demonstration exams. exam s. answer sheets, physical and eye exam results, background checks, and qualification listings. These individuals were evaluated for assigned., responsibilities verses actual education and experience. Selected OC i ) inspectors, QA engineers, and QA/QC supervisory personnel were contacted ~ j and interviewed to f acilitate this evaluation. i No items of noncompliance or deviations were identified. 3. Bechtel's Secrecy Agreement The Covernment Accountability Project (CAP) questioned the use of Bechtel's secrecy agreement in letters to the NRC dated September 6, 1982 and March 29, 1983. The NRC previously responded to the CAP y concern on October 12, 1982. The inspectors reviewed the Bechtel Form 3002, "Bechtel Employee Inventions and Secrecy Agreements," as to the intent and use of the form and understanding by employees. This form is viewed by the NRC as a standard form used by companies to protect a company's proprietary i information and inventions. Ther inspectors interviewed eleven Bechtel ) employees asking each two questions: (1) 1f they were aware of what the intent of form 3002 was; basic answer, a standard company form to afford protection on secrets and patents; (2) if the) thought this form ~ prevented them from talking to the NRC; the answer was no. The inspec-tors could find no evidence that this form had ever been used as a basis for firing anyone. The inspectors also noted during this inspection that the licensee had properly posted NRC form 3 (revised 6-82), " Notice to Employees" as required by 10 CFR 50.7. This notice was the correct revision and was prominently posted in sufficient locations to afford workers an opportunity to observe the notice during their way to or from their place of employment. No items of noncompliance or deviations were identified. 4 Atomic Safety and Licensing Board (ASLB) Hearings On April 27-30 and May 4-6, 1983,- Messrs. R. Cook, R. Cardner, R. Landsman and W. Shafer of the Midland Section presented testimony. in regards to issues before the Board in the Midland ASLB Hearings. The hearings are scheduled to reconvene on June 1, 1983. -[' 5. Meeting to Discuss the Construction completion Program (CCP) on May 17, 1983, members of the Midland Section met with Mr. D. Miller -E and others of the licensee's staff to discuss the licensee's April 6 and April 22, 1983 responses to NRC questions concerning the CCP. f. ( kl 4 ~
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,e 6. Meeting of Caseload Forecast Panel to Evaluate the Midland Construction Completion Schedules f (N. -- Midland Plant to evaluate construction completion schedules. The On April 19-21, 1983, the NRC Caseload Forecast Panel visited the t' meeting discussed in detail the basis for Consumers' revised estimates of October 1984 (Unit 2) and.Tebruary.1985 (Unit 1). The Panel conducted an extensive tour of both units to observe construction progress. On April 21, 1983, the Panel informed the licensee that the Panel's position in regards to the construction completion schedule would be issued at a later date. j 7. Resident Inspectors Investigation of Allegations l 1 The inspectors toured the Midland Site with an alleger and a licensee representative on May 7, 1983. The purpose of the site tour was to i l provide the alleger the opportunity to point out specific problem 9 and to clarify allegations addressed in his affidavit. Plant areas toured l included the control room, elevations 634, 614, 599, and 584 of the auxiliary building, the number 42A battery room, and the cable cut shop. During the tour, a list was provided to the NRC and.the licensee con-taining hanger numbers, hanger types, and hanger deficiencies. Of 41 hangers on the list, 26 were observed directly by the alleger, the NRC, and the licensee representative. The 15 remaining hangers will be inspected, in addition to the 26' observed, by the licensee and the NRC during allegation investigations conducte.d. independently by both organizations. Based on the above tour and an interview conducted on March 15, 1983, the following allegations were addressed: a. Allegation No. 1: During installation of the switchgear in the battery rooms on the 614 elevation, we were unable to obtain minimum anchor bolt imbed =ent because of reinforcement rod interference. The standard procedure to deceive QC was to add threads to an ancho.r bolt, cut it off, and dress-it up with a grinder. This instance was not unique. Review: The alleger identified the specific room, battery charger and inverter that allegedly had i. been installed using the modified anchor bolts. A NRC Region III NDE specialist ultrasonically examined (UT) the accessible anchor bolts in all four battery rooms (Inspection Report 50-329/82-16 (DE); 50-330/82-16 (DE)). In addition, the licensee has also ultrasonically examined (UT) the battery switchgear anchor bolts. i 1 l 5 i. l+ 7.. i-.
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== Conclusion:== This allegation has not been substantiated based on a comparison of the licensee and [ Region Ill UT results. (Closed 329/82#04-01; 4 330/82#04-01) b. Allegation No. 2: I have seen workers and supervisors throw..., peanut shells, orange peals, banana peels, or waxed paper into 2 inch and smaller pipes. Review: The alleger did point out a 'non-safety related -} system that allegedly contained garbage. He was ,i not aware of any safety eysters that contained-
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i trash or garbage. The preoperational testing program will flush and conduct performance demonstrations of each safety related system. Flushing procedures of safety systems require i both a visual inspection of strainers to determine amount and extent of contaminants within a system and a chemical check performed by a qualified chemist to ensure system water chemistry is within specifications. Combined, these tests would detect the presence of i contaminants or biodegradeables. r
== Conclusion:== At this time, the NRC has not been given ~ sufficient informatiortthat would facilitate the continued investigatlorrinto this matter. ~ (Closed 329/82#04-02;-330/82#04-02) { c. Allegation No. 3: It is my belief that the actual control room is j simply not large enough to provide adequate work ~ space for a full control room crew. j Review: The alleger toured the control room and could not provide any additional information as to the need for a larger control room. NUREG-0737.. Item I.A.1.3, Shift Manning delineates the requirements as to the minimum number of on-shift personnel for a single control room, two unit plant. i
== Conclusion:== There is inadequate justification for continued investigation into the matter at this time. I The requirements of NUREG 0737 and control room habitability were explained to the alleger i during the onsite tour. (Closed 329/82#04-03; 330/82#04-03) l-8. Heating, Ventilation, and Air Conditioning (HVAC) Welding During the reporting period, the Resident Inspector was informed by the licensee that five of the welding procedures which would allow l j limited production for fabrication and installation of safety related s 6 't ! '.~ l ~ _ _. -... , +. .._.......-n ,.w.' .;n. a+. .s _Q s ,- Q Q~ ~, a)
s HVAC components had been procedurally qualified and that some velders were certified to these procedures. The Resident Inspector reviewed l 6 these procedures and examined some of the procedure qualification ( I coupons. The Resident Inspector asked for a welding demonstration by ? four certified welders using the equipment located in the fabrication ahop. The demonstration required using the gas metal are welding _(G, MAW), I process. Using the parameters required by the velding procedures and .1 i the equipment located in the fabrication shop, the licensee could not I perform satisfactory weld samples using some aspects of one of the prohedures (WPS-1-3-1) requested by the Resident Inspector. The licensee also had some apparent equipment difficulties welding to the . { extremes of another procedure (WPS-1-3-3) for which the Resident Inspector requested a demonstration. 4 Based on the inability of the Ifeensee to produce satisfactory welds ~ under actual shop conditions for each weld condition specified in the 4 procedures, the Resident Inspector /NRC has denied the licensee a i resumption of HVAC safety related welding. 1 j The licensee has since identified additional deficiencies which prevent ^ resumption cf production safety related HVAC welding and to date has not requested another review of this matter by the NRC. No items of noncompliance or devi,ations were identified. 9. Heating, Ventilations and Air Conditionfhi (RVAC) Lavdown Area Storage During the reporting period, the Resident Inspectors examined the storage conditions for HVAC components stored at the Poseyville Road laydown area. The Resident Inspectors noted that some itecs were off the dunnage. The inspectors were informed that these items were awaiting transfer to a salvage area. The inspectors were informed that items slated for reuseable stock were marked by a yellev asterisk if the items was originally safety related and marked with a red cross or asterisk if the item was originally non-safety related. The inspectors noted that these items marked with an asterisk were stored in proximity to acceptable safety related (Q) items. The inspectors also noted that obviously discarded items (duct pieces and other random debris) were also placed adjacent to safety related duct pieces without an exclusion area being designated. The licensee also informed the inspectos that items slated for a " reusable stock" designation could, in actuality, be items of questionable quality. No procedure existed that clearly delineated marking the HVAC components in a sanner just I described. Therefore, it appears that the licensee has not established 1 ,y appropriate controls to prevent the inadvertent use or installation of nonconforming HVAC components stored in the Poseyville Road laydown Failure to establish measures to control nonconforming materials, area. h parts, or components is considered an item of noncompliance with 10 CFR-Appendix B, Criterion XV as described in the Appendix of the report f transmittal letter. (50-329/83-10-01; 50-330/83-10-01) e b ~\\ i.,, 7 0 1: .E = 4
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- 10. Core Internals Inspection
-r' Inspection of 30 of approximately 750 Unit 1 baffle plate hold down \\,, bolt dowel pin welds was performed by the inspector on March 10, 1983. The inspection was conducted to determine if the cracking identified in the dowel pin welds at Bellefonte was present at Midland. The~ ] inspector could not identify' cracking in any of the welds observed ~ .i during the inspection. The licensee performed a 100% inspection of Unit I and Unit 2 baffle plate hold down bolt dovel pin welds and identified only one dowel l pin veld that did not meet visual inspection requirements. A non-l conformance report (NCR) was issued and preparations are in progress to reveld the nonconforming devel pin veld. No items of noncompliance or deviations were identified.
- 11. Plant Tours l
At periodic intervals during the report period, tours of metacrad e i e s-arEIs were perrormea.- These tours were conducted to assess the clean-liness of site areau, storage conditions of equipment and piping being used in site construction, the potential for fire or other hazards which might have a deleterious effect on personnel and equipment; and J to witness construction activities in progress. Noitemsofnoncomplianceordeviationswerei)en'tified. 12. Remedial Soils Work Activities t The inspectors reviewed and authorized the following work activities during the report period. I a. SWPS deep-seated bench-marks b. BWST's electrical ductbanks c. Piers 8E and 8W d. Modifications of beam connections at el'evations 646, 659, and 704 Diesel fuel lines exploratory excavations e. f. Dutch cone testing near OBS-4 3 Core drill SWPS and CWIS slabs h. SWPS monitoring instruments 1. UAT platform J. Repair SWPS du tbank k. Foundation fot Acid-Caustic station 1. Piers 10E and IDW n m. Piers KC2 and KC11 n. Piers KC3 and KC10 o. 3WST foundation work p. Pier 11W load test' q. Pier 11W load test remedial measures 8 f i-g %=, =.u&c. % 9 g up g Whme rm-+ h9 a' g - G, ,m. E p 3 , + - ~~ r' ,., d....:.
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- 13. Exit Interviev
[ The inspectors met with licensee representatives at the conclusion of the inspection. The inspectors summarized the scope and findings of t. the inspection. The licensee acknowledged the information. Attachments: Stone and Webster. Engineering C9rporation Weekly Reports 26-34 ~ ~ t' t i - l 1 / .g I l t 5 1 .i 1 (e? h 1 9 'i '1 ;
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