IR 05000329/1976004
| ML19329F325 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/02/1976 |
| From: | Hayes D, Jablonski F, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19329F317 | List: |
| References | |
| 50-329-76-04, 50-329-76-4, 50-330-76-04, 50-330-76-4, NUDOCS 8006250413 | |
| Download: ML19329F325 (25) | |
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UNITED STATES NUCLEAR REGULATORY CO.411SSION OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III
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Report of Construction Inspection IE Inspection Report No. 050-329/76-04 IE Inspection Report No. 050-330/76-04 Licensee:
Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 Midland Plant License No. CPPR-81 Units 1 and 2 License No. CPPR-82 Midland, Michigan Category:
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Type of Liceasee:
PWR (B&W), Unit 1 - 650 MWe Unit 2 - 818 MWe Type of Inspection:
Announced, Special Dates of Inspection:
April 19-21, May 3, 6-7, 13-14, and 20, and
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June 7-8, 1976
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Principalknspector:
1. T. Yin
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(Da(e)
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Accompanying Inspectors:
F.
blonski 7/8/7[
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G dFMW C. C. Williams d
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(Da'te)
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Other Accompanying Personnel:
J. G. Keppler D. M. Hunnicutt C. E. Norelius J. C. LeDoux
D. W. Hayes G. A. Phillip
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Projects Section (D' ate)
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SUMMARY OF FINDINGS
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J Inspectiod Summary
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Inspections on April 19-21, May 3, 6-7, and 13-14, 1976, (Unit 1, 76-04) and (Unit 2, 76-04):
Perform in-depth QA inspection to identify the underlying causes of weakness in the Midland QA program implementa-tion, primarily recent problems in reinforcement steel placement. As a result of the inspection, five items of noncompliance relative to inadequate quality inspection, corrective actions, work procedures, and documentation were identified.
Two deviation items were also identified in regard to QA audits and design engineers QA training.
Management meetings on May 20 and on June 7 and 8, 1976:
Reviewed cor-rective action planned by the licensee relative to the inspection findings.
Enforcement Items Items of Noncompliance A.
Violations None.
B.
Infractions (Units 1 and 2)
1.
Contrary to Criterion V, documented instructions were not available for the drilling and placement of reinforcement l
steel dowels.
(Paragraph 4.a. (1), Report Details)
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2.
Contrary to Criterion V, Nonconformance Reports concerning reinforcement steel deficiencies were not adequately evalu-ated to determine need for corrective action to prevent
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recurrence as required by the Bechtel Power Corporation Field Inspection Procedure G-3, Paragraphs 4.10.1 and 4.10.3.
(Paragraph 4.d, Report Details)
3.
Contrary to Criterion X, reinforcement steel installations in some instances were not adequately inspected to verify con-formance to applicable drawings.
(Paragraph 4.c.(5), Report
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Details)
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Contrary to Criterion XVI, a meaningful evaluation was
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not performed relative to the significance of the
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gg deficiency documented on Bechtel Power Corporation Non-
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.to the requirements of 10 CFR 50, Paragraph 50.55(c).
-l conformance Report No. 260 and its reportability. pursuant (Paragraph 1.d., Report Details)
5.
Contrary to Criterion XVII, results of reviews, interim inspections, and monitoring of reinforcement steel installations were not documented and available for review.
(Paragrapn 4.c.(1), Report Details)
C.
Deficiencies None.
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Licensee Action on Previously Identified Enforcement Items
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Licensee action and/or resolution of previously identified enforcement itens were not reviewed during this inspection.
Other Significant Items A.
Systems and Components
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1.
Unresolved Matter:
Based on the results of the safety analyses on the cumulative effects on the Auxiliary Building due to rebar omission and reworks.
Bechtel concluded that th,e missing rebar, even if not replaced, will not affect-s'
the integrity of the structure. This position was accepted
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by the licensee's engineering department.
IE:Ill requested an
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independent technical evaluation through IE:HQ to verify the finding.
Subsequently, this evaluation was conducted by the IE HO rechnical personnel [~and no'pfoblem areas were identified.
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The result's of the IE:HO structural review will be documented in a future IE III inspection report. 'This item remains open
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pending issuance of this report.
2.
Unresolved Matter:
Following the licensee's interim 50.55(e)
report on missing rebar dated April 21, 1976, other possible discrepancies involving placement of rebar were identified by CP.
These discrepancies are documented in NCR QF-95,
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No. QF-96 and No. QF-100 and will be reviewed during a future inspection.
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3.
Unrosolved Matter:
Bechtel QA Trend analysis reports, not identified to the IL inspector until completion of the i.sspection on May 14, 1976, will be reviewed at the site during a future inspection.
(Paragraph 4.d, Report Details)
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4.
Unresolved Matter: A monthly Civil / Structural Drawing Chan~ge O.
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Notice (DCN) control log is transmitted to site document control g~roup.
Because of the size of these transmittals (several hundred pages) and the fact that the latest changes are not highlighted, the value of this lugging system in identifying DCN updates was questioned.
Further review is planned during a future inspection.
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B.
Facility Items (Plans and Procedures)
1.
Unresolved Matter: The adequacy of document control procedures relative to filing Field Change Notices by the licensee's project office could not be determined.
Further review of this matter is planned for a subsequent inspection.
2.
Unresolved Matter: The use of department standards such
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as No. 501 and No. 502 by the Bechtel civil design engineering group to replace or supplement the Ennineerinn Denartment jProcedures (EDP) and PSAR was questionable.
Subsequent to the inspection Bechtel indicated that they will abandon the use of these standards.
(Paragraph 4.b.(2), Report Details)
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3.
Unresolved Matter: The use of NCRs to document engineering changes which affect completed work does not appear t.o be in consistence with requirements.
Subsequent to the inspection the licensee stated that this practice would be discontinued.
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(Paragraph 4.c.(3), Report Details)
4.
Unresolved Matter: The current Bechtel QC inspection practice of having the QC Engineer submit inspection plans directly to
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the Field Coordinator, does not appear to be consistent with paragraph 3.1 of the Bechtel Project Special Provision No. 16 Revision 0, dated October 2, 1974.
Followup review is planned.
5.
Unresolved Matter:
The wording of some Bechtel nonconformance reports is unclear or sufficient detail is not provided such that the exact nature of the discrepancy fu apparent. These reports are to be revised and followup review is planned during a future inspection.
C.
Managerial Items
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None.
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Noncompliance Identified and Corrected by Licensee None.
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Deviations
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1.
Contrary to the licensee ASLB hearing commitments, licensee"
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control of A-E's safety-related work activities has'not been
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effective, and some of the audits had not been performed in s
accordance with approved audit schedules.
2.
Contrary to the licensee commitment.during the ASLB hearing that CP QA policy was to be implemented not only by CP, but by the NSS supplier and the A-E, the Bechtel design engine.xs QA training was not in compliance with CP ' policy..
F.
Status of Previously Unresolved Items The resolution of previously unresolved items was not reviewed during this inspection.
Management Interview A.
An informal information exchange type meeting was held at the site with Eechtel and CP management personnel on May 14, 1976, at the conclusion of the inspection.
Those present were informed that this meeting was not the formal management exit meeting but that the formal meeting would be held with CP corporate personnel on May
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20, 1976.
1.
Attendees:
Consumers Power Company (CP)
F. M. Southworth, Director, Project QA Servicee H. W. Slager, Midland QA Administrator
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J. L. Corley, Midland QA Superintendent R. E. Whitaker, QA Engineer T. C. Cooke, Midland Project Superintendent
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B. H. Peck, Field Supervisor Bechtel Power Corporation (Bechtel)
P. A. Martinez, Project Manager D. R. Johnson, Chief QC Engineer J. F. Newgen, Project Superintendent J. Milandin, QA Manager T. C. Valenzano, Project Field Engineer A. J. Boos, Assistant Project Field Engineer C. L. Richardson, Lead QA Engineer W. F. Holub, Project QA Engineer J. P. Connolly, Project Field QC Engineer
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Bechtel Associates Prc'=ssional Corporation (BAPC)
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E. A. Runbaugh, Engineering Manager
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H. liermeston, Construction Manager R. L. Castleberry, Project Engineer J. L. Iturley, Assistant Project Engineer.
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2.
The inspectors discussed the results of the inspection and apparent underlying causes contributing to repetitive reinforcement steel (rebar) deficiencies that have occurred at the Midland site. The underlying causes discussed included:
a.
Lack of QA training for the working level design engineers.
b.
Lnproper use of Nonconformance Reports (NCR) for documenting design changes.
c.
Inadequate review of fabrication drawings by Field Engineers.
d.
Lack of clarity of problem description in NCRs.
e.
Insufficient field alertness to design drawing revisions, and other changes affecting their activities.
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f.
Failure of Field Engineers and Quality Assurance Engineers
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(QAE) to review NCRs for generic problems and to take cor-recti'e actions.
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Failure of QAE to detect improper or inadequate QC activities.
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h.
Failure of Quality Control Engineers (QCE) to determine interim inspection or surveillance results.
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Incomplete or inadequate preparation of QC inspection plans.
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QC inspection made against fabrication drawings instead of using these drawings only as reference with work
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acceptance against the design drawings.
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Apparent lack of adequate or effective training for Field
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Engineers, QA Engineers and QC Engineers.
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The inspectors acknowledged the corrective items that had been
initiated by CP and Bechtel relative to the rebar l
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problems.
(These items are listed below)
It was also acknowledged
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that some of these corrective actions are on an interim basis pe~nd-
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\\s-ing further review and development of needed policy and procedure changes to affect long term resolutions.
a.
Modify preplacement rebar inspection plan to include specific requirements as to ' review of design drawings and extra verifi-cation at locations where changes in direction or interruptions oCCure b.
Provide documented instructions to the field engineers to use design drawings as primary documents for rebar checkout and to improve interpretation of design drawings.
c.
Improve fabrication drawing preparation and control.
d.
Provide specific instructions to craft supervisors, field engineers, and quality control engineers relative to rebar deficiencies.
e.
Provide documented instructions to QC engineers to use design drawing for rebar inspection and to use fabrication and detail drawings only as references.
f.
Bechtel Project Field QC Engineer or Lead Civil QC Engineer to review the inspection criteria and the rebar placement for 'a ()
minimum of twenty (20) concrete placements.
CPQAkngineerstoinspectandverifyproper'rebarplacement g.
for all safety related pours prior to their release for concrete placement.
h.
CP Civil Engineering Section to' investigate rebar problems to determine underlying causes and to recommend measurec to
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preclude repetition.
1.
One additional CP Civil QA Engineer temporarily assigned to the site to strengthen the QA work force.
j.
Provide more intensified training for Bechtel QC Engineers on the rebar problems.
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Bechtel QA to develop detailed trend analyses on the rebar deficiencies and other related problems.
1.
Bechtel QA to develop more visibility on QA trend analyses, based on NCR's audit findings, supplier audits, etc.
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M,anagement Corrective Action Report (MCAR-12) issued by
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f-~g Bechtel on April 1, 1976, to identify the rebar deficiencie,s
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and the causes of the' problem.
MCAR-12 not to be closed until
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resolution has been satisfactorily achieved, n.
Bechtel to evaluate the working technique of QC inspectors.
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Bechtel QA to review the results of the review of 20 concrete placements (see Item No. f) and to assess the QA inspection effectiveness.
B.
A formal management exit interview was held on May 20, 1976 at CP's Corporate Offices.
1.
Attendees:
Consumers Power Co. (CP)
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J. D. Selby, President S. H. Howell, Vice President G. S. Keeley, Project Manager
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F. $outhworth, Director, Project QA Services Department H. W. Slager, Midland QA Administrator USNRC J. G. Keppler, Regional Director
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O D. M. Hunnicutt, Chief, Reactor Construction and Engineering Support Branch
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C. E. Norelius, Assistant to the Director -
J. C. LeDoux, Chief, Engineering Support Section
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D. W. Hayes, Chief, ProjectsSection I,. T. Yin, React,or Inspector, Proj ects
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2.
Matters discussed and comments on the.part of management l,
perronnel were as follows:
l a.
A presentation of inspection findings were given by NRC IE:III Chief, Projects Section. The following is the essence of the presentation:
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(1)
The primary concern relative to the inspection findings is the apparent breakdown in the effective-ness of CP's QA/QC systems in that both failed to recognize and deal effectively with repetitive rebar l
problems.
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(2) The conduct of the inspection concentrated on two
areas:
(a) verify that commitments made by CP and
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rebar problems are being implemented, and (b) identify underlying causes leading to repeated omissions of rebars.
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(3) The status of CP and Bechtel adherence to previous commitments was discussed.
(4) Rebar omission problems including inspection dates and apparent causes were summarized and discussed.
(5)
Regarding underlying causes, IE:III inspectors examined four areas:
(a) Design, (b) Field Acti-vities, (c) Quality Control, and (d) Quality Assurance.
Results of the inspection did not identify any generic causes concerning the rebar deficiencies.
However, it was concluded that the field QA/QC groups had not fully carried out their responsi-bilities.
If each of the groups involved had followed
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established procedures, it is likely that these
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problems would not have occurred.
(6) The underlying causes observed by IE:III inspectors were presented. This presentation was similar to that given earlier at the Midland site (see Para-()
graph A.2., Management Interview). Two additional items were also discussed that may have contributed tolthe rebar omission problems. They were:
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(a) The lead time between completion of design and
start of construction.
"(b)
Some simplification of design drawings and.
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elimination of multiple references may be possible.
(7) The noncompliance items identified as a result of this inspection were also discussed.
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In conjunction with the inspection findings, the NRC b.
IE:III Regional Director indicated that the licensee
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should take effective and acceptable corrective actions to include:
(1) A program to correct identified problems and to provide a high degree of assurance they will not i
recur.
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(2). A program to verify that similar QA/QC weaknesses do
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s identified, that appropriate corrective action is, taken.
(3) A program to estcblish confidence that reinforcement steel in.other areas has been properly installed and to provide reasonabic assurance that no other omissions of reinforcement steel has remained undetected.
c.
At the conclusion of the meeting, the President of Consumers Power Company expressed CP's general concurrence with the inspection findings.
CP will increase their QA/QC efforts at the Midland site, and will reexamine the fundamental issues involving architect-engineer (A-E)
design review and group interfaces.
CP will develop a formel plan of action in response to the NRC concerns and will be prepared to review these plans with.NRC Region III personnel in the very near future.
C.
A followup management meeting was held cxt June 7 and 8, 1976 at CP Corporate Offices.
1.
Attendees:
Consumers Power Company ()
S. H. Howell, Vice President G. S.' Keeley, Proj ect Manager F. Southworth, Director, Project QA Services Department H. W. Slager, Midland QA Administrator
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J. G. Keppler, Regional Director (June 8,1976, only)
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D. M. Hunnicutt, Chief, Reactor Construction and Engineering Support Branch D. W. Hayes, Chief, Project Section J. C. LeDoux, Chief, Engineering Support Section 2.
Matters discussed:
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l The licensee discussed the results of their review and analysis of the findings identified during the IE:III inspections in April and May 1976.
Each finding (issue) was discussed individually along with CP's proposed plan for corrective action.
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'~ T CP's analysis of the issues was considered to be thorough and
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the corrective action plans responsive to NRC concerns.
However, some action items and/or dates for accomplishment remain to be defined.
During the meeting on June 8, 1976, CP notified 'S:III of two
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more ommissions of reinforcement steel and'that a stop work order had been issued by the licensee and the contractor for all concrete placement involving safety-related structures.
Subsequent discussions centered on those corrective action plans that should be completed and implemented before concrete placement activities are resumed. The licensee agreed to expedite final development and schedules for implementation of these plans. The licensee also agreed to provide Region III an opportunity to review the results prior to lif ting the stop work order.
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REPORT DETAILS
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Persons Contacted In addition to the individuals listed under the Management Interview section of this report, the following persons were contacted:
Consumers Power Company (CP)
R. E. Whitaker, Field QA Engineer D. E. Horn, Field QA Engineer C. E. Hunt, Executive Engineer R. W. Rogness, Senior Engineer Bechtel Power Corporation 2. G. Tucker, QC Supervisor
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Bechtel Associates Professional Corporation P. R. Cassidy, Vice President and Area Manager M. F. Daubenheyer, Senior Construction Engineer M. G. O'Mara, Quality Engineer Supervisor J. R. McBride, Project Quality Engineer J. C. Arora, Group Leader, Auxiliary Building V. J. Venna, Senior Civil Engineer
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J. N. Pasrija, Civil / Structural Engineer s_/
M. Jumra, Civil /. Structural Engineer
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Results of Inspection
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Recent Licensee Report on Rebar Placement Problems
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a.
On March 22, 1976, the inspector was informed by the licensee, that subsequent to concrete placement'CP discovered that certain
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rebars in the auxiliary building had been omitted.
As a result of this discovery, a stop work order for all safety related concrete placement activities was issued by the licensee's site QA representative.
The problems were identified as follows:
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"A" Line Rebars As described in Bechtel NCR No. 396, groups of six No. 8
' vertical rebars, 23'6" long, starting from EL.614'-0",
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were not pinced in the shear wall columns at the inter-
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sectionn of line "A" and line "S.6", and line "A" and -
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line "7.4".
A total of 12 No. 8 rebars had been omitted.
(2)
"7.8" Line Rebars As described in Bechtel NCR No. 378, sets of five No. 11 horizontal right angle bent rebars, at 2'3" 0.C. vettcally from EL.614'-0", had not been placed in line "7.8" concrete wall at four locations, on each face of,line "J", and line "K" walls. A total of 20 No. 11 rebars had been
omitted.
b.
During the management exit interview following the routine site inspection of March 16-18 and 24-26, 1976, the inspector requested CP to inform him when the stop work order was to be lifted and the status of the following items of concern:
(1) The cause of'the problem.
(2) The corrective methods, or interim fix, approved by Bechtel and accepted by CP.
(3)
If additional reinforcement of the structure is required because of the omitted rebars, the analyses, the corrective work requirements, and approval and acceptance of work procedures prior to their use.
(4)
1f'no additional reinforcement is necessary, the docu-mented evaluation and analyses supporting this decision.
(5) Management immediate action, and plans to prevent occurrence
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of future similar problems.
(6) Training sessions conducted for engineers, QA/QC personnel, and rebar placement crews.
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Subsequent to the site inspection, on March 31, 1976, the licensee informed the inspector that the stop work was being lifted, and addressed the concerned items.
The licensee also indicated that detailed investigation and evaluation of the problem was underway and that the results would be reported
pursuant to requirements of 10 CFR 50, Paragraph 50.55(e).
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d.
Also, during the March 16-18 and 24-26, 1976 inspection, a.
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number of NCRs submitted as required by ALAB 106, Condition 4
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requirements were reviewed for proper resolution. One of the
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scJocted NCRs was Bechtel NCR No. 260, issued on December 23, 1974, and resolved on November 3, 1975. This NCR concerned m-omission of reinforcement steel in several wall areas within the Auxiliary Building.
During further review of this NCR in
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the IE:III office and based on the probicm as documented, the inspector determined that thc. licensee has not performed a meaningful evaluation as to the significance of the problem and reportability pursuant to 10 CFR 50.
Paragraph 50.55(e)
requirements.
Such findings were based on the following occurrences:
(1) During March 16-18, and 24-26, 1976, IE:III site inspection, neither Bechtel Assistant Project Field Engineer, nor Bechtel Lead Civil Quality Control Engineer knew exactly how many dowels were omitted
from rebar placement.
From reading NCR 260, it appeared to b,e that 96 #8 horizontal rebars (walls No. 27 through No. 32) and 12 #8 vertical rebars (wall No. 31) were omitted.
Subsequent to the inspection, licensee reported that a total of 77 #8 rebars were omitted, and a revision of NCR 260 was to be written.
(2) During April 19-21, 1976, IE:III site inspection, Bechtel Project Field Engineer and licensee QA (T Engineer reported that no rebars were omitted in walls
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No. 27 and No. 28, but_52 #8 horizontal rebars were omitted in walls No. 29 through No. 32, and 12 #8 -
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vertical rebars were omitted in wall No. 31.
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(3) Reviewing licensee 50.55(e) letters, dated April 21, 1976, and May 21, 1976, and the attached Bechtel
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safety evaluation, titled " Investigation of Missing
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Horizontal Reinforcing Steel for Midland Auxiliary Building Walls 29, 31 and 30, 32 at Walls 7.4 and 5.6, Respectively (NCR 260)" addressed the 52 #8 omitted l
horizontal rebars in walls No. 29 through No. 32.
The omitted 12 #8 vertical rebars reported in NCR 260, and during April 19-21, 1976, IE:III site inspection, had apparently not been taken into consideration.
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Similar Rebar Problems In The Past
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Several rebar placement problems were identified and reported to IE:III since late 1974. The events were as follows:
a.
On December 5, 1974, the licensee reported that, as a result of an audit performed on December 5,1974, by the CP QA Engineer, rebar spacing was found to be out of specification in about 50 locations within the Unit 2 Containment Building-Lift No. 6.
The deficiencies were reported to NRC per 10 CFR 50, Paragraph 50.55(c) requirements. The details of the problem and resolutions are documented in CP NCR QF-36, and reported in IE:III Inspection Reports No. 050-330/75-01, No.
050-330/75-02, and No. 050-330/75-03.
b.
On March 5 and 10, 1975, the IE:III inspector was informed by the licensee that deficiencies were found in the auxiliary building concrete rebar placements. The deficiency areas included:
(1).50% of the required #6 rebars (56 in nu=ber)
were not placed in a horizontal concrete beam, (2) four #6 bars had not been placed in the wall near the' opening, and (3)
two #6 rebars were placed into the floor slab where three No.
18 rebars are required.
The details of-the problem and resolutions were documented in Bechtel NCR No. 295, and reported in IE:III Inspection Reports
N No. 050-329/75-03 and No. 050-330/75-03.
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A manage =ent meeting was conducted by IE:III personnel at Consumers Power Company Corporate offices on March 12, 1975.
The purpose of this meeting was to discuss reinforcement steel
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placement problems. The meeting is documented in a IE:1II letter to Consumers Power Company dated April 16, 1975.
d.
On August 21, 1975, the licensee reported, that a number of tiebars had been left out during auxiliary building concrete pours.
Bechtel Nonconformance Report NCR-326 identifies that the missing 42 sets of tiebars are located in the "Hk" line wall, between columa lines 7.8 and 8.6.
The approximate dimensions of the v211 are 15' x 13' x 3.5',
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with an 8' dicmeter pipe tunnel opening. - The original design l
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called for 23 sets of double #6 tics for the horizontal concrete l
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beam and 19 sets of double #6 rchar tics for the vertical ~
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beam, above and on one side of the pipe tunnel.
Instead, only single #6 rebar ties had been placed during the pours.
The IE:III inspection of the reported deficiency and the resolution of the problem is documented in IE:III Inspection Report No 050-329/75-07, and No. 050-330/75-07.
3.
Review of All Past NCRs Relative To Rebar Placements As a result of problems identified in Bechtel NCR 260, the past and recent rebar omission problems, described above in paragraphs 1 and 2, the inspector reviewed all NCRs dating back to 1970 and made a chronological listing of the omissions and other rebar problems documented in these reports. The purpose was to identify the extent of the problems concerning rebar placement and any possibility of cumulative affects on structural safety.
The review of findings are summarized as follows:
NCR NO.
NCR DATE PROBLEM DISPOSITIO
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C-18 10/23/73 7 - # 11 bars missing.
Improper Repair spacing.
(Pour placed 10/22/70)
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135 7/15/74 Excessive cover.
As Is 143 7/30/74 Placed in wrong location.
Repair 158 8/20/74 12 - #8 bars missing.
Rework 42 - #6 bars missing.
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(Pour placed 7/17/74.)
168 9/5/74
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Placed in wrong location.
Rework
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(Pour placed 7/5/74.)
172 9/12/74 35 -~#11 bars missing.
(Pour Rework
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placed 6/13/74.)
l QF-36 12/5/74 Improper spacing (Containment As Is
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254 12/18/74 Excessive cover.
As Is
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256 12/19/74 1 - #6 rebar was inadvertently Rework
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NCR NO.
NCR DATE PROBLEM DISPOSITIO:
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260 12/23/74 52 to 64 #8 bars missing.
" Rework
(Pour placed 10/73 and 11/8/74.)
- 276 1/28/75
. Containment Unit 2 8-#11 bundled As Is
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haurch bars were cut off to make room for penetration.
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290 2/21/75 8 - #11 bars missing.
(Pour Rework placed 11/8/74.)
295 2/28/75 116 - #6 ties omitted.
(Pour As Is placed 12/23/74.) Also, 2 - #8 bars and 4 - #6 bars omitted.
296 3/3/75 1 - #8 bar omitted.
(Pour Rework placed 8/30/74.)
298 3/10/75 3 - #9 rebar with incorrect As Is embedment length.
326 8/11/75 42 - #6 ties omitted.
(Pour As Is placed 11/14/74.)
396 3/22/76 1 - #8 bar om'itted.
(Pour As Is
placed 2/9/76.)
398
~3/23/76 20 - #11 bars omitted.
(Pour Rework placed 3/3/76.)
399 3/23/76 Same as NCR 398, except for
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opposite wall. Omission detected before pour completed.
Note: NCRs listed above concern omission or improper placement of reinforcement steel, and except for NCRs No. 276 and QF-36, all occurred in the Auxiliary Building.
4.
In-depth QA Inspection
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In view of the repeated rebar nonconformances reported subsequent
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l co concrete placement and the past and the recent QA/QC deficiencies, I
an in-depth QA inspection was conducted.
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The purpose of the inspection was two-fold:
(1) to evaluate
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organizations, management policies and QA/QC provisions and
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practices relative to design, construction and inspection to
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identify underlying causes of continuing evidence of weakness in the Midland QA program impicmentation and (2) to verify that corrective action and other commitments made.in the past by both CP and Bechtel have been implemented.
The results of the inspection are documented below,
a.
Rework of Omitted Rebars Most of the rebar omissions occurred in the Auxiliary Building, which is about 20% structurally completed.
Total safety related rebar installed in the Auxiliary Building to date is approximately 2767 tons.
An estimated 5.7 tons of rebar was omitted, but most have been replaced by corrective action.
The rework on the concrete structure to replace omitted rebar includes (1) drill dowel holes (the embedment by this shall be in accordance with the approved table) (2) set dowels, and (3) fill holes with non-shrink grout (Embeco 636).
In reviewing the NCRs and QC inspection records relative to rework the inspector identified the followings:
(1)
No documented dowel drilling procedure was available, i.e.,
type of drill, type of bit, method of cleaning N
hole, precautions such as damage to other embedments, s_,/
reinforcement steel or surrounding concrete, verification of hole diameter and depth, nor was there quality control involvement to verify any of the above.
(As of April, 1976, instructions were made available for having dowel holes s
drilled, however, no actual drilling procedure had been
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established.)
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(2)
Specification C230 and C231 refer to grout and provide a list of acceptable grouting materials.
In no case was specification C230 or C231 referenced on the NCR, however, an acceptable grout was ref erenced.
(3) A manufacturer's suggested grouting procedure is provided in each bag of "Embeco 636" grout and includes instructions for preparation, forming, temperature control, working i
time, recommended mixes, mixing, placing and curing.
No checklists or other documents were available te show that all or any of the above instructions performed had been adhered to.
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b.
Design Control and Safety Evaluation of Rebar Omissions
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T Inspection was performed on May 3,1976, at the BAPC office,
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Ann Arbor, Michigan to examine the A-E's design control of rebar placement and the results of their evaluation of the rebar included (1) review of Engineering Department Procedure (EDP) No. 4.61, titled, "Nonconformance Reports (NCRs)."
Revision 1, dated June 20, 1974, (2) review of EDP-4.47,
" Drawing Change Notice," Revision 1, dated February 4, 1975, (3) interviews with civil engineers and their group leaders relative to handling of Design Change Notices, Field Change Requests, engineering evaluations of NCRs, and QA training received in the past, (4) review of work interfaces and communication between design office and field engineering staff, and (5) discussions on safety evaluations concerning cumulative effects on Auxiliary Building due to rebar omissions. The inspection findings were as.follows:
(1)
It appears that only engineering group leaders receive formal QA training.
Followup of this matter is planned.
(2) The use of condensed design criteria such as Midland Civil Group Standards No. 7220-C-501 and No. -502 by the design engineers to replace or supplement for EDP and PSAR was questionable.
Subsequently, Bechtel indicated that they will abandon the use of these stan-dards.
Further review of this matter is planned.
(3)
In the case of Bechtel NCR 260, the drawing was revised after *he concrete placement had been completed, and in other cases last minute drawing revisions may have con-
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tributed to rebar omissions.
Improvement of design
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and field communication and drawing revision control is needed.
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(4) The Bechtel management and the licensee representative were informed by the inspector that the IE:HQ technical group has been requested by IE:III to review the safety evaluations concerning the rebar omissions and placement problems..The primary concern is possible cumulative effects on the structural integrity of the Auxiliary Building.
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c.
Deficiencies In QC Inspection of Rebar Placements The causes of the rebar omission and related placement problems
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involved different design and construction organizations.
It is considered a serious problem at the site, when the QCEs, whose main job function is to inspect to assure correct
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installations, continue to fail to identify rebar deficiencies
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prior to concrete placement. The IE:III inspection efforts i
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(1) interviews with the Project Field QC Engineer,
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Lead Civil QC Engineer, and Civil QC Engineer, (2) review of NCRs for causes of the rebar deficiencies, (3) review of
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Field Inspection Procedures (FIPs) for adequacy and imple-
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mentation, and (4) review of QC personnel qualifications and training ie;ords. The inspection findings are as follows:
(1) Where NCR disposition calls for rework, the work result is to be verified by a QCE, a written statement on the NCR such as "wo'rk completed to Inspection Plan C-231-244B, Revision 2" is signed and dated by the QCE.
In the case of both~ Quality control Inspection Plans and Nonconformance Reports, no documented dowel embedment measurements or any adverse observations were included.
All inspection
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requirements are listed in a standard format and verified correct by evidence of the inspector's signature.
(2) No documentation was available to show that provisions of
' Section 4.10 of FIP G-3 had been implemented.
Section 4.10 provides that the organization responsible for control of the activity which apparently caused the NCR:
(a) evaluate the information provided by the NCR, and (b) initiate whatever corrective action may be warranted to prevent recurrence.
(3) FIP G-3, Processing of Nonconforming Items, Section 4.1.3
stated:
" Engineering changes which affect completed work shall require the initiation of an NCR."
The use
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of NCRs to record design change, field change request,
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the work completion appears to be inconsistent with
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requirements.
Subsequent to the. inspection, the licensee stated.that this practice would be discontinued and that Bechtel would revise FIP G-3.
This is considered an unresolved matter pending future inspection resolution.
-(4) The inspector reviewed the QCE qualification records based on FIP G-8 requirements.
The review included personnel certificate, indoctrination, training, and
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physical examination.
No deficiencies were identified.
Training in the areas of rebar placement inspection has been stepped up.
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(5)
In regard to the review of NCRs for QC's contribution
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to the causes of rebar deficiencies, the following
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items were identified:
(a)
In some cases all applicable referencing drawings wer'e not listed on the inspection plan.
(b)
In some cases the QCE failed to identify rebar requirements listed in the drawings.
(c)
In some cases applicable Design Change Notices had not been included on the inspection plan.
(d) Use of incorrect field sketche.: for rebar inspection occurred in some cases.
(e) The QCE sometimes failed to use the latest design drawings for inspections.
(f)
In some cases incorrect rebar fabrication drawing instead of design drawings were used for inspection.
(g) Misinterpretation of drawing or specification requirements occurred on occasion.
(h)
In one case failure to follow the inspection through A
by different QCEs occurred.
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d.
Absence of QA Trend Analysis on Rebar Placement Problems It is stated in Bechtel FIP G-3, Processing of Nonconforming
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Items, Revision 6, dated May 17, 1974, Section 4.10.1, and 4.10.3, that, "The PFQCE (Project Field Quality Control Engineer) shall notify the site QAE of any nonconformances which may be reportable in accordance with article SG.55(e)
of 10 CFR Part 50 or are of such magnitude or quantity that an MCAR may be required," and "The PFQCE shall also route a copy of the completed NCR to the site QAE for his evaluation and use in determining the need for corrtetive action to prevent recurrence."
In the case of Bechtel NCR 260 both the site QAE and the QCE failed
to determine the significance of the problem based on 50.55(e)
requirements.
In the case of MCAR-10, which was generated because of the tiebar omission problems identified in Bechtel
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actions and measure to prevent future recurrence.
Subsequently, additional rebar omission problems occurred as identified in Bechtel NCRs 396, 398, and 399. Upon reviewing all the NCRs related to rebar omission and placement deficiencies, the inspector determined that (1)
construction audits were not effective in detecting unsatis-factory QC rebar inspection performance, and (2) trend analysis relative to rebar prob 1 cms had not been performed and corrective measures taken to preclude recurrence.
In response to the inspector's inquiry on May 3, 1975, at the Bechtel Ann Arbor office, as to the existence of trend analyses performed in other areas of work activities, the Bechtel PQAE presented to the inspector two trend analyses written in 1975.
However, the inspector was told that no formal criteria and procedural requirement had been established until recent months after the significance of the rebar omission problem had been identified by the NRC.
During the NRC site inspe-ction on May 6-7, and 13-14, 1974, similar question on the existence of trend analyses performed by QAE in other areas was raised by a different group of inspectors but no QAE appeared to have any knowledge of trend analyses.
Subsequent to the management information exchange meeting, a list of trend analysis reports were presented to the inspectors.
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A followup review of these reports is planned for a future
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inspection.
e.
Field Engineering Control of Rebar Placements In the past, the rebar fabrication drawings made by Inland-Ryerson (Inryco) were reviewed by the Field Engineers and Project Engineers.
This review responsibility was formally
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transfered to the field engineers at the site through a memo from the Project Engineer to the site Project Superintendent, dated May 6, 1975, subject:
" Engineering Review of Rebar Detail Drawings." The memo stated, in part, that, " Engineering has checked adequate numbers of such drawings in appropriate critical areas of the plant to be assumed that continuation of such checking is not necessary.
We are confident that the intents of our structural designs are being properly interpreted
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by Field Engineers both in the preparation and review of
(N drawings they generate and in review of I-R drawings."
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J At present, the field engineering control of the documentation and review of Inryco rebar drawings are as follows:
(1)
Inryco makes fabrication drawings based on the design drawings.
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(2)
Inryco forwards detail drawings to site Document Control.
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Site document control logs them and sends the Inryeo drawings to Field Engineer for review and approval. The Field Engineer also maintains a copy of Inryco up-to-date drawings.
(4) The Field Engineer returns the Inryco' drawing to Document Control after review.
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(a)
If approved, drawings are to be distributed to work areas for canstruction.
(b)
If further details are required, and not approved drawings are to be returned to Inryco.
(c) A copy of Inryco drawing is forwarded to Ann Arbor for information only.
(5)
F'or checking the rebar placements before the concrete pour, the Field Engineer is to use design drawings with the fabrication drawings and approved field sketches used i
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only as references.
In regard to review of NCRs for Field Engineer's (FE) con-tribution to the causes of the rebar deficiencies, the following items were identified:
(1)
In checking rebar placement, FEs in some cases failed to review all applicable references drawings.
(2) Checkout based on detail drawings rather than design drawings sometimes occurred.
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In some cases misinterpretation of design drawings or specifications occurred.
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In some cases checkout was based on outdated documents.
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Impicmentation of Li'censee Commitments Significant CP commitments relative to Quality Assurance, rebar placement, enforcement, 50.55(e) reports, and corre-spondences were reviewed for implementation ~during this inspection.
The effectiveness of impicmentation was also assessed. The documentation records included:
(1) Memorandum and Order (ALAB-106), dated March 26, 1973, issued by Atomic Safety and Licensing Appeal Board
(ASLAB).
(2)
Prepared testimony by S. H. Howell, dated July 17, 1974, presented to ASLAB.
(3) Consumers Power Company (CP), Bechtel Power Corporation, and Bechtel Associates Professional Corporation (BAPC)
Proposed Findings of Facts and Conclusions of Law, issued by CP and Bechtel attorneys on August 13, 1974, before the Atomic Safety and Licensing Board (ASLB).
(4) CP 50.55(e) Report on Unit No. 2 Containment Rebar Spacing Deviation - report forwarded to IE:HQ, dated January 28, 1975.
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(5)
IE:III Regional Director's letter to CP, dated April 16, 1975, regarding rebar spacing problem.
(6)
CP'50.55(e) Interim Report on Auxiliary Building rebars omissions - Report forwarded to IE:HQ, dated April 21, 1976.
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CP's response letter to IE:III, dated March 5, 1976, on Items of Noncompliance Identified in IE:III Inspection Report No. 76-01.
(8) CP former Director of Project QA Services Department (PQASD), Mr. G. S. Keeley, prepared testimony before ASLB, dated July 17, 1974.
- Implementation of licensee commitments has been and will continue to be examined during each inspection.
The results of the in-depth review during the current inspection indicate that, with the exception of the items identified in the Summary of Findings section of this report (under Enforcement
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Items and Deviations) commitments in the areas reviewed are
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being satisfactorily impicmented.
Licensee corrective action in regard to the items identified will be exami.ned during subsequent inspections.
g.
Personnel Interview
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As a part of the in-depth QA inspection effort to identify the underlying causes of continuing evidence of weakness in the Midland QA program implementation, various levels of CP and Bechtel QA/QC and Bechtel field engineers were interviewed by IE:III inspectors and an IE:1II investigator. The responses of the personnel interviewed were considered informative and cooperative and helped verify the report findings and resolutions.
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