ML19262C543

Responds to NRC 791212 Ltr Re Violations Noted in IE Insp Repts 50-329/79-27 & 50-330/79-27.Corrective Actions: Conducted Training Session on Adherence to Hold Tag Requirements & QC Hold Tags Issued

ML19262C543
Person / Time
Site:	Midland
Issue date:	01/11/1980
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19262C542	List: ML19262C543
References
HOWE-3-80, NUDOCS 8002140381
Download: ML19262C543 (3)

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Consumers

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Power Stephen H. Howell Sensor Vue 1+tssdent General Offices: 1945 West Parnell Road, Jackson, Michigen 49201 e (617) 7884453 J anuary 11, 1980 Hove-3-80 Mr J G Keppler, Recional Director Office of Inspection and Enforcement US I;uclear Regulatory Connission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLidiD I;UCLEAR PLA?;T - !iRC ITB: OF Iio:iCOMPLI/dlCE I:iSPFCTIO:: REPORT I;0 50-329/79-27 /J;D I;0 50-330/79-27 This letter, with its enclosure, is in response to your letter of Decenter 12, 1979 which trancritted the results of your inspection of the Midland conctruction site on October 1-31, 1979 and which requected our written statement on the iten of noncompliance.

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WRE/lr Enclosure J AN 161980 8'

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CONSUMERS POWER COMPANY RESPONSE

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TO THE ITD4 0F NONCOMPLIANCE DESCRIBED IN NRC INSPECTION REPORT NO 50-329/79-27 AND NO 50-330/79-27

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A. , Descriptions of Noncompliance Appendix A, and page 2 of Details in Report .No 50-329/79-27 and No 50-330/79-27 provide the following: *

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" Based on the results of an NRC inspection conducted on Oct'ober 1-31, ~

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1979, 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, Criteria V, states, in part, that , ' Activities affecting qual.ty shall be prescribed by documented instructions, procedures, . . . and shall be acco=plished in accordance with these instructions, procedures, ...'. Field Instruction Procedure FIG-1.5000, Quality Control Hold Tags states, in part , that , 'No work shall be accomplished on an item other than that work specifically authorized by the NCR or as specified by the QC Engineer.'

Contrary to the above, the Resident Inspector determined that QC Hold Tags were violated on March 20, June 20, September 7, September 29 and October 9,1979 in that work was perfonced on equipment with hold tags without prior authorization."

"(Open) Unresolved Matter (329/79-09-01; 330/79-09-01): This unresolved matter is escalated to an item of noncampliance as follows: Field Instruction Procedure FIG-1.5000, Quality Control Hold Ta6s, states that work shal.L not be perfomed on equipment with a nonconforming condition without prior authorization. It was noted in NRC Inspection Reports 30-329/T9-09; 50-330/79-09 that violations of QC Hold Tags had occurred and work had been perfonsed on electrical equipment without prior authorizaticn to violate the QC Hold Tag. At this time, the licensee had identified

• violations to QC Hold Tags and was taking action to rectify this situation. However, since that reporting period, QC Hold Tags had been violated five additional times. These violations of QC Hold Tags are addressed in Nonconformance Reports No 1980, 2313, 2523, 2578, 2607, dated March 20,1979, June 29,1979, September 7, 1979, Septenber 29,19"9, and October 9,1979 respectively. These violations of QC Hold Tags have been primarily associated with the electrical construction activities.

Failure to comply with the pr'ovisions of Field Instruction Procedure FIG-1.5000, Quality Control Hold Tags, is considered an item of nonecxnpliance with 10 CFR 50, Appendix B, Criteria V."

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B. Consumers Power Cecipany Response Prior to the issuance of this infraction, Censumers and Bechtel Quality ptrsonnel had identified and reported each case .of hold tag violations on NCRs. Bechtel QA issued a Quality Action Request (QAR) to cause corrective act$ 3 for this problem.

An investigation of this situation revealed that the circumstances in each case were different, but the number of instances indicated that training of Bechtel Construction personnel was needed. Bechtel took the following actions to resolve the problem:

a. On October 2h,1979, the Bechtel Midland Project Superintendent of Construction conducted a homin'ute training session with -

Construction Supervisors r.nd Field Enr.incers on the subject of '

0' adherence to hold tag req 'rements. Bechtel Quality Assurance and Quality Control personnel were also in attendance. The correct actions for obtaining an expedient disposition of a hold tag and for obtaining the proper removal of the hold tag vere stressed in det ail. Construction Supervisors and Lead Field Engineers were instructed to ecnmunicate this information to individual employees,

b. Field Instruction FIG 1 500, Rev 1, " Quality Control Hold Tags,"

was issued on October 22, 1979 to reinforce the basic instruction.

This Field Instruction applies to both Bechtel and CPCo hold tags.

No hold tag violations have been reported since the training.

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