ML19253C822

Responds to NRC 791010 Ltr Re Violations Noted in IE Insp Repts 50-329/79-19 & 50-330/79-19.Corrective Actions: Training Records for Const QC Personnel Updated to Accurately Reflect Actual Training

ML19253C822
Person / Time
Site:	Midland
Issue date:	11/26/1979
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19253C820	List: ML19253C822
References
NUDOCS 7912120180
Download: ML19253C822 (8)

Text

{{#Wiki_filter:. t COIISumBIS power Stephen H. Howell Senior Vice Presuient General Offices: 1945 West Parnall Road, Jackson, Michigan 49201 e (517) 7P8 0453 October 31,157T9 Hove-285-79

                                                                                       )DDR OR G NAL Mr J G Eeppler, Regional Director Office of Inspection and Enforcement US Nuclear Regulatory Cosnaission Region III 799 Roosevelt Road Glen Ellyn, IL 6013T MIDLAND NUCLEAR PIANT -

INSPECTION REPORT NO 50-329/79-19ANDNO50-330/79-19

      'this letter with Enclosures "A" and "B", is a response to your letter of October 10, 1979 which transmitted the subject Inspection Report, and also requested our written statements in reply to certain items of noncompliance.
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Enclosures:

A - Constaners Power Company's Response to Inspection Report Itp No 50-329/79-19-01 am! No 50-330/79-19-01 B - Consumers Power Company's Response to Inspection Report Item No 50-329/79-19-02aniNo50-330/79-19-02 1539 304 [;;V 51979 79121 20 I /[

Enclosure A to Hove-285-79 CONS 3ERS POM COMPANY RESPONSE ' TO THE NOTICE OF VIOIATION ' uUn Q Ug&ggy l y DESCRIBED IN NRC DEPECTION REPORT NO.50-329/79-19-01ANDNO.50-330/79-19-01 A. QUALIFICATIONS OF INSPECTION PERSONNEL PERFMING MEASURINGS, TESTS, AND EXAMINATIONS OF COIiTAIMENT PRESTRESSING SYSTEM. (329/79-19-01; 330/79-19-01) Description of Noncompliance Appendix A of Report No. 50-329/79-19and50-330/79-19 provides the following:

        "10 CFR 50, Appendix B, Criterion II requires, in part, that the quality assurance program provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

CPCO Quality Assurance Program Policy No. 2 couplies with the requirements of Regulatory Guide 158 and ANSI R45 2.6, 'Quali-ficatior,of Inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants' . In addition, the licensce's contractor, Bechtel Power Corporation, procedure G-8.1, section 5 2, requires specific education and experience requirements to be satisfied to be considered for certification as a Level I inspector. Those requirements include: Two years related experience or high school graduate plus one year related experience or college level work leading to associates degree in related discipline plus six months of related experience in equivalent testing, exa aination or inspection activities associated with power plants, heavy industrial facilitics or other similar facilities. Contrary to the above, five QC inspection personnel perfoming measurings, tests and examination of the contain=ent prostressing system vere not qualified in accodance with the above prerequisites in that they had no prior related education nor prior related work experience in equivalent testing or inspection activities." CPCo Pesponse The Bechtel Program for the certification of Construction Quality Control Personnel (SF/ PSP G-8.1) meets the requirements of ANSI N45 2.6 and Regulatory Guide 1 58. There is a qualifier to the specified education and experience requirements in the ANSI StendoM and Reg Guide and in the Bechtel Procedure. Paragraph 51.2ofSF/PSPG-8.1 states: 1539 305

2 Enclosure A to Hove-285-79 "The education and experience requirements specified belov shall not be treated as absolute. These requirements may be altered when other factors provide reasonable assurance to the supervisor responsible for certifying a lower level candidate that the person can coa:petently perfom a particular task. These other factors shall be demonstrated by capability in a given job and/or through docuwnted evidence of previous satisfactory perfomance, and completion of the proficiency evaluation requirements specified in 6.0 below." The certifications for the incpectors in question came after sufficient training was conducted for them in the limited area for which they have inspection responsibility. Their training records have been updated to accurately reflect their actual training. Contrary to the 182 Inspection Report which indicates that there vere five inspectors doing inspection whose qualifications are in question, only four inspectors were certified. The fifth individual, who was not certified, performed no inspections. The results of an extensive reincpection by other Bechtel Civil QC personnel assigned to post tensioning, and overinspection by CPCo, substantiate the effectiveness and competency of the QC inspectors in question. The agreements reached in the October 25, 1979 meeting in Glen Ellyn, and documented by the attached letter, should provide final resolution of this subject. l [ 1539 306 .

Attachment 1 to Enclesure A Hove-285-79 J 7. Bechtel Power Corporation 777 East Eisenhower Pa0M 9 4 7 L Ann Arbor Michigan Med Amts: P.O. Box 1000 Ann Arbor. Michgan 48106 y # r, , V..,......,..v-October 26, 1979 BLC- 8361 Mr. G. S. Keeley Project Manager ) ' Consu=crs Power Company , j 1945 Weut Parnall Road Jackson, Michigan 49201 Midland Units 1 and 2 Consumers Power Company Bechtel Job 7220 TENDON INSPECTORS File 0629

Dear Mr. Keeley:

Attached are action items resulting as part of resolution achieved between Bechtel, Consumers Power and NRC Region III during the October 25 discussion of Midland Project Post-Tensioning Tendon Inspectors. As a part of the resolution NRC Region III agrees that the tendon operation will continue with the current inspectors in place. D. R. Johnson will be on site commencing Wednesday, October 31, 1979, to prepare the test required as part of agreement point 1. Lecar Brown is presently on site acting in the capacity of the experienced individual called for as part of agreement point 2. D. R. Johnson advises me that the correlation of specific tendons to individual inspectors will be completed in order for the NRC to cocnence their selection and inspection activities as early as Thursday, November 1, 1979. Accordingly, I would appreciate it if Consumers advises the NRC of the November 1 date ir.: mediately. Please direct any questions regarding follow-up action relevant to this matter either to te or L. E. Davis. U "*

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7 John A. Rutger Project Mana r JAR /kb Attachment i539 307 cc: B. W. Marguglio (CPCo-Jackson) ' L. E. Davis (B-Site)

NRC REGION III MEETING OCTOBER 25, 1979 001947 ACTION ITEMS AGREEMENT POINT 1 Retesting of Inspection Personnel:

a. Bechtel will retest all three Level II and seven Level I Inspectors involved in tendon inspection .

b. Bechtel will submit the test to the NRC for approval prior to it's administration.

c. The test will include a combination of written and hands-on aspects.

d. Predetermined acceptance criteria vill be established and applied.

e. The test will be administered and results will be evaluated by a Bechtel person with prior post-tensioning experience.*

AGREEMINT POINT 2 Commencing immediately and until satisfactory conclusion of the Retesting Period:

a. Bechtel will have a person on site with prior post-tensioning experience.*

b. This person will be assigned to the QC organization and will have no other responsibility than to be actively involved in the managecent of the post-tensioning inspection process.

c. The individual may cover operations on both the first and the second shift on a " split shift" basis.

AGREDUUU POINT 3 In order to improve confidence in previously completed tendon work:

a. The NRC vill select for re-inspection tendons whose characteristics have been inspected by cach of the four Level I inspectors whose qualifications orginally came into question (not to exceed a total of four tendons).

• Further clarification-A person who would qualify as Level II in accordance ANSI N45.2.6-1973.

b. Bechte3 will de ..rcss the selected tendons and the NRC will .

reinspect those characteristics which can be observed without removing the tendons from the sheaths or cutting @i @ 4 [

c. If possibic the NRC will select tendons which, at the time the selection is made, have not been greased. If this is not possible or acceptabic by the NRC, then Bechtel requests that horizontal rather than verticle tendons be selected.

The points of agreement are made without specific schedule cocmitment, however we suggested that itees 1 and 3 proceed independently with item 3 perforced as soon as possibic and ite.m one accomplished within the next 3 weeks. NRC agreed there will be no undue delay in providing inspection personnel for their involvement. ATTENDEES NRC REGION III CONSUMERS POWER CO. BECHTEL CASTON FIORELLI, STEVE HOWELL, HOWARD UAHL, Chief, Reactor Eng. Senior Vice President. Vice President

      & Support Branch.         GIL KEELEY,                    JOIDI RUTGERS, DEE HAYES,                     Project Manager                Project Manager Chief Eng. Support        BD: MARGUGLIO,                 TED J01CIS0",

Section. Director, Quality Chief Civil Engineer RICHARD 10:0P, Assurance, PE&C. DON J01D; SON, Chief, Conct. Projects Chief Conse:uctim. OC Section. Engineer, San Francisco EUGENE GALLACHER, Power Division. Inspector RON COOK, Resident Inspector T0h VANDELL DARL HOOD, Project Manager, NRR WALT HAAS, 53o/ JV/(no QA Branch-NRR JOIDI GILARY, QA Branch-NRR JAR /kb

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Enelosure B to UUn i ., Hove-285-79 coNSIMERS PoVER CoMPNiY RESPoHSE To THE NOTICE OF VIOLATIoH DESonIPan In NRc INSPrcrIon nueonT No. 50-329/79-19-02 AND Ho. 50-330/79-19-02 B. ICE OF LEAN CoHCRLTE AS A SUBSTITUTE IVR SAFEIT REIATED STRUTURAL BACKFILL. (329/79-19-02; 330/79-19-o2) Description of Honco=plicnce Appendix A of Report No 50-329/79-19 and 50-330/79-19 provides the following:

            "lo CFR 50, Appendix B, Criterion III requires, in part, that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.

CPCo Quality Assurance Program Policy no. 3 states, in part, that 'the assigned lend design group or organization assures that the design and material are suitable and that they comply with design criteria and regulatory requirements. ' Contrary to the above, Specification C-211, sections 8.1.2 and 8.2.!+ permits the use of lecn concrete as a substitute of safety-related structurcl backfill and compacted scnd material while stating that 'lenn concrete shall be made of non-Q material and workranchip.' This permits the use and instal-lation of non-Q (non-cafety related) mcterial in safety-relcted areas without benefit of the licensee's quality assurcnce program. Non-Q (non-quality) locn concrete has been used in various areas of the plant fill including observed areas in the safety-related tank farm arca." CPCo Response It is our evaluation that lenn concrete used as structural backfill has been batched using Q materials except for one instance where another source was utilized. Concrete cylinder tests wre teken which substantiated the quality of the concrete. In many instances, concrete used in lieu of structural backfill materials is in fact excess Q concrete residual to other pours. When lean backfill concrete materials, the is specifically(batched materials ccment, sandfor anduse in lieu of are aggregate) structural Q materials. As indicated in Specification C-211, lean concrete is batched and controlled in acconlance with Specification C-230. 1539 510

Enclocure B to 2

                            )                    ,

Hove-285-79 Lean concrete is used in lieu of structural backfill materials when approved by the onsite geotechnical soils engineer. The use of lean concrete provides a strength approximately 100 times greater than compacted structural backfill material. The minimum strength of lean concrete is 2000 PSI, (288 KSF) as compared to compceted structural backfill material which has a strength of approximately 3 KSF. Pincing and tecting of lean concrete has been under the direction of concrete field engineers. It is our opinion that any further controls would not add to the quality of the end product as can readily be seen from the above. The stren6th of the lean concrete backfill could not possibly be less than compacted fill. 1539 3l1

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