ML19207C512

Responds to NRC 790619 Ltr Re Violations Noted in IE Insp Repts 50-329/79-12 & 50-330/79-12.Corrective Actions:Audit Conducted in May 1979 W/Five Findings Issued & Ref to Paragraph 58 in Welding Procedure M-B-QCP22 Corrected

ML19207C512
Person / Time
Site:	Midland
Issue date:	07/20/1979
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19207C510	List: ML19207C511 ML19207C512
References
HOWE-204-79, NUDOCS 7909120152
Download: ML19207C512 (10)

Text

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, Consumers J POWBf Stephen H. HoweH Senior Vsce Presdent General O f fices. 1945 West Pernall Road, Jackson, Michigan 49201 * (517) 788 0453 July 20, 1979 Hye-204-79 Mr J G Keppler, Regional Director Office of Inspection and Enforcement US Nuclear Regulatory Co= mission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR PLAI(f - NRC ITEMS OF NONCOMPLIANCE INSPECTION REPORT NO 50-329/79-12 AND NO 50-330/79-12 This letter, with Enclosure (1) is in response to your letter of June 19, 1979 which transmitted the results of your May 8-11, 1979 inspection of Midland Project activities and which requested our written statement on the items of nonccepliance.

Enclosure (2) provides additional information on the subject covered in Section II (pages 9 and 10) of the Inspection Report and provides a response to the conclusion drawn by NRC in that Section.

N M 205 JUL23g~e 7909120 *T

t Enclosure 1 to Hove-204-79 CONSUMERS POWER CCMPANY RESPONSE TO THE NnTICE OF VIOLATION DESCRIBED IR NRC IUSPECTIC: REPORT No. 50-329/79-12 AND E0 50-330/79-12 A.. LACK OF CORRECTIVE ACTION RELATIVE TO WORK PRDTI FINDDiGS (329/79-12-01;330/79-12-01)

1. Description of Noncompliarg Item 1 from Appendix A of Report No 50-329/79-12and50-330/79-12 provides the following:

"1. 10 CFR 50, Appendix B, Criterion XVI, requires in part, that significant conditions edverse to quality, shall have measures to assure that the ceuse of the condition is determined and corrective action is taken to preclude repetition.

Consumers Power Company Topical Report CPC-1-A, Policy 16, Rev 7, requires in part that corrective action be taken to correct and preclude recurrence of significant conditions adverse to the quality of ite=s or operations.

Bechtel Topical Report BQ-TOP-1, Rev 1A, Section 4,, requires in part, that procedures will provide for identification and correction of conditions adverse to quality which may require corrective action.

Contrary to the above, on May 8,1979, one of twenty-five (25) drawings which were being utilized as Work Prints was found not to be the most current revision. Also, two of the 25 randomly selected drawings were found not to reference all of the appli-cable FCR's in their ' Outstanding DCU/FSR/FCU Block' nor were all of the applicable FCR's attached to these two drawings.

Similar conditions were identified by Bechtel QA personnel in Bechtel Quality Assurance Finding SA-39 (9-2-6) dated March 13, 1978; SA-39 (9-2-6) was closed on June 7, 1978. Therefore, the corrective action taken for closing Bechtel Quality Assurance Finding SA-39 (9-2-6)has failed to preclude recurrence of adverce conditions." ,

2. CPCo Response As a follow up to corrective action to which Bechtel previously had committd relative to work prints, a Consumers Pouer audit was conducted in May 1979 with five findings issued. As a result of those findings, the Item of Noncompliance referenced above and 9 y ['. 2 lb

2 previous Bechtel and Consumers Power Company findings relative to control of work prints, Manage =ent Corrective Action Report / Request (MCARR) #EJ-l was issued May 31, 1979 In response to that MCARR, Bechtel co=mitted to the following to relieve the overloading, which was a root cause of past problems of the work print control system:

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a. FPD-1.100,"Docu=entControlCenter#2/WorkPrintProgram", vill be changed to reflect that only the types of drawings actually needed for construction vill fall under the work print control system.

b. The Field Assistants have been made responsible solely for document distribution checks to void and withdrav voided drawings. This will be incorporated in FPD-1.100.

c. The auth,ority to request work prints has been restricted to lead superintendents and their designees.

This corrective action vill resolve the MCARR including the item of noncompliance . Corrective action implementation vill be completed by July 31, 1979 .

B. DEFICIENCY IN QUALIFICATION OF WELDING PROCEDURE (50-330/79-12-09)

1. Description of Noncompliance Item 2 from Appendix A of Report No 50-329/79-12 and 50-330/79-12 provides the following:

"2. 10 CFR 50, Appendix B, Criterion IX requires, in part, that measures shall be established to assure that special processes, including velding, are controlled.

' Paragraph 5 2 of procedure 9-1 of the Consumers Power Company Quality Assurance Program Topical Report (CPC QA PTR) CPC-1 states, in part, 'Special processes are accomplished with written process sheets, procedures, dhecklists, or equivalent which describe parameters to be met during the performance of the special process . . . .

Contrary to 'the above, it was determined the various levels of reviews failed to identify that Zack Welding Procedure Specif1-cation M-B-QCP22, Revision 1, dated January 21, 1978, prequalified to American Welding Society Dl.1-75, inaccurately stated that it was qualified to Paragraph 5B (relates to procedures by quali-fication tests) instead of 5A (relates to prequalified procedures)."

2. CPCo Response It is our evaluation that paragraph 131 of zack Welding Procedure M-B-QCP22 was inadvertently worded to refer to Paragraph G4E l;:

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5A instead of Paragraph 5B of American Welding Society Dl-75 The following corrective action has been taken:

Zack has corrected the reference to Paragraph 5B in Welding Procedure M-B-QCP22 which has received a Level I approval by Bechtel Project Engineering. A review of other Zack Welding Procedures indicates that this was an isolated case.

C. NONCONFORMNCE TO RECEIPT INSPECTION REQUIRDE7fS (50-330/79-12-03)

1. Description of Noncompliance Appendix A of Report No 50-329/79-12 and 50-330/79-12 provided the following: ,

"10 CFR 50, Appendix B, Criterion VII, requires measures to be established to assure that purchased material, equipment and services, whether purchased directly or through contractors and subcontractors conform to procurement documents. These measures shall include provisions such as objective evidence of quality furnished by the contractor or subcontractors and examination of products upon delivery.

Paragraph 3.4 of CPC QA Program for Nuclear Power Plants, Volume 1 - Policies, Policy 7, states in part, ' Receipt inspections are made to verify that the items are undamaged, that they conform . . . available. Documented evidence that the items meet r.:quirements . . . use of the items.'

The inspector identified the following examples which are contrary to the above: ..

a. Shop inspections and receipt inspections failed to verify that documentation on the vall thickness measurements, as specified in Paragraph 9.6.1 of Specification M-129B, was included in the Valve Documentation Package supplied by Borg Warner, the vendor.

b. Engineering review and documentation review failed to identify that the seismic analysis was computed assuming the yoke to be ASME SA-105 (forging) material whereas the yoke actually supplied to Midland was fabricated from ASTM A216 (casting).

c. Receipt inspection failed to verify whether accessories such as Flex 1tallic Gasket, 9 studs, and 18 bolts conforming to ASIM A-416, Grade 630 H17 50 specified in Paragraphs 2.14a and c_ of B&W specification 08-1028000006-03 was supplied with the Pressurizer Safety Valve.'

(CPCoNote: Underlined text within quote has been revised to correct typographicalerrors) hij k 2Od

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2. CPCo Response The status of the specific examples listed above is as follows:

a. As stated in the subject NRC report, corrective action was taken as measurements were obtained. A cursory review of other valve

- procurement packages indicates that the discrepancy is an isolated case involving only that specific document package. Bechtel Procurement Supplier Quality has been requested to conduct a more formal documented review to confirm the above,

b. The assembly drawings were revised in September 1976 to indicate cast material. Therefore, the material was received properly.

Borg Warner advises that the stress calculations are not affected by the change from forged to cast material. The material desig-nation in the stress report was changed to correspond to actual material.

To confirm our belief that this is an isolated case, ceveral similar valve packages vill be reviewed by 8/31/79 for this attribute .

c, Items procured by B&W Power Generation Division (Lynchburg),

are initially receipt inspected by Bechtel QC Receiving which is in accordance with agreements between Bechtel and B&W. The Bechtel receipt inspections are done in accordance with Material Receiving Instructions (MRI's) that are unique to the item in '

conjunction with Bechtel Quality Control Instructions for receipt of NSSS equipment. The Bechtel inspection is for documentation, damage from various causes, and any unique characteristics as established in the applicable MRI. The item is also inspected for proper preparation for storage.

B&W Field Construction Procedures (FCP's) are developed for all operations. The FCP's are scoped for specific work activities.

The first step on the FCP's is to receive the required material.

The second step is to receipt inspect the materials in accordance with B&W CC Receipt Inspection Procedure 9-QPP-lO8. This receipt inspection is redundant to some of the characteristics inspected in the Bechtel receipt inspection and is specific in inspection for accountability and any material degradation that may have occurred as a result of storage and handling since the initial receipt inspection.

The storage crates for the Pressurizer Safety Valve vere opened and it was verified that the required ctuds and bolts were with the valves and thut, in fact, the flexitallic gaskets and one of four valve geg plugs were missing.

Bechtel initiated a review of supplier quality verification docu-mentation in February 1978. This activity, entitled " Review of u qA 209

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Supplier quality Verification Documentation," vas procedura11 zed as the attachment to letter BLC-7826. Thic procedure provides guidelines and instructions for review of supplier documentation prior to system turnover. It includes the type of docu=entation to be reviewed, method of selection for review, extent of review, enalysis of findings and disposition of findings and corrections. The activity provides a mechanism to detect the types of nonconformances provided in a and b, above, and thus provides process corrective action.

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Enclosure 2 to Howe-20h-79 CP Co - Midland QA Overview Program The QA-PE&C overview activities started in June 1976 for rebar and in April 1977, for embeds. For all other civil, mechanical, velding, NDE, electrical, and instrumentation and controls, the overview program started at the end of June 1978 and was fully implemented by the end of March 1979 for activities then in progress. The overview program implemented Jetween June 1978 and March 1979 was improved over that which was utilized in 1976 and 1977 The improvement consisted of review of Bechtel drawings, specifications, field procedures and quality centrol instructions for specificity, and of QA-PELC's utilization of specific overinspection plans.

With regard to mechanical activities, from November 1978 to date, Bechtel closed 936 Quality Control Inspection Records (QCIRs), whereas in the same time period QA-PE&C performed LO overinspections. Work in the mechanical aren was well underway when the QA-PE&C cverview program was started.

Mechanical QCIRs had remained open for a long time and QA-PE&C had expressed concern about this because in some cases there were only minor inspections yet to be accomplished and in other cases the scopes of the QCIRs were too large. In response, during late 1978 and early 1979, Bechtel closed a large number of QCIRs for which almost all of the inspection was accomplished much earlier and for which there was little opportunity for a corresponding QA-PE&C overinspection. Thus, there is not a direct correlation between the 936 QCIPs closed from November 1978 to date and the h0 QA-PELC overinspections performed during the same period. Furthermore, the most significant aspects of the mechanical work are the hydrostatic and pneumatic tests. Since October 1977, BWM 7/2/79 r,

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2 all of the hydrostatic and pneumatic tests have been witnessed by QA-PE&C. The majority of this effort is not reflected in the QA-PE&C overinspection figure of 40 because hydrostatic and pneumatic tests are accomplished as a witness point in the Bechtel procedures.

With regard to velding, from November 1978 to date, Bechtel closed 2,690 QCIPs, whereas in the same period QA-PE&C performed 50 overinspections. The discussion about Bechtel QCIR cl,osures, or lack thereof, in the preceding paragraph equally applies to the velding area. Furthermore, for all of Class 1 and Class 2 con-ponent and piping velds, readiographic examination is required with minor excep-tions and the QA-EE&C review of the radiographs has been extensive as indicated below.

From June 1978 to the present, Bechtel originated h,119 field radiographs and QA-PE&C has reviewed 70h. For the sane period, B&W originated slichtly over 700 field radiographs and QA-PE&C has reviewed 700. B&W radiographs for primary systens are reviewed 1005, although not always in the same time frane as they originated. For other than the primar/ system, the QA-PE&C review is on a sampling basis. All 1,560 vendor radiographs received since December 1978 have been reviewed by QA-PE&C.

The electrical area can be further categorized as indicated in the following paragraphs.

For cable tray supports, Bechtel has closed approximately 200 QCIRn, whereas QA-PE&C has performed 13 overinspections.

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. 3 For cable tray installations, Bechtel has closed 201 QCIRs, whereas QA-FE&C has perfor=ed 26 overinspections.

For sonduit, junction boxes and their supports, Bechtel has closed approximately 500 QCIRs, whereac QA-PE&C has performed 26 overinspections.

For electrical penetration assemblies, Bechtel has closed 5 QCIRs, whereas QA-PE&C has perfor=?d 1 overinspection.

For the pulling of power cables, control cables and instrumentation cables, Bechtel has closed 331 QCIRc, whereas QA-PELC has performed 75 corresponding overinspections (includir_g 20 overinspections which vere accomplished as part of audits), Of the 75 QA-PE&C cable pulling overincpections, lh were for instrwmentation cables.

For cable terminations, Bechtel has closed 853 QCIRs, whereas QA-PE&C has performed 63 corresponding overinspections.

The higher QA-PE&C emphacis on cable pulling in comparison to cable termination is attributable to the recognition that the cable essentially become inacceccible after the pulling, whereas the cable terminationc are accessible and any defects are more detectable during checkout and preoperational testing.

For equipment installations, Bechtel has closed 10 QCIRs, whereas QA-PE&C hac performed 15 overinspectionc. The reason for the excess of QA-PE&C over-inspections is that we have performed some in-process overinspections.

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Neither Bechtel QC nor QA-PE&C cover the instrumentation and controls activities utilising a separate group-level organisation. Both mechanical and electrical disciplines are necessary for adequate coverage. Furthermore, Bechtel's responsibility is to install the instrumentation, to run cable and tubing to the instrumentation, to terminate the cable, and to hook up the tubing.

Consumers' personnel vill perform calibration, loop checks, component tests, and system tests as part of our formal checkout and preoperational test program.

These organisational arrangenents are different from those previously experienced by "r Ron Cook which included an I&C group within the inspection organization and the architect-engineer performed all of the precalibration through system testing activities.

Work is just beginning on I&C. For the electrical aspects of I&C, Bechtel has not closed any QCIRs. Nevertheless, QA-PE&C has performed lb overinspections--

the same ll cable pulling overinspections mentioned above. For the mechanical aspects of I&C, none of the Bechtel QCIRs are closed. Nevertheless, QA-PE&C has completed 1 overinspection since the scope of this RA-PE&C overi'nspection plan is different from the scope of the Bechtel QCIR.

Based on the foregoing infornation and on our review of the documentaticn dealing with the CP Co Overview Program, we believe that the Program meets or exceeds that which was described to the NRC during the management meeting of February 7,1979 t !( 5 2