IR 05000329/1982005
| ML20052F220 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/19/1982 |
| From: | Landsman R, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20052F212 | List: |
| References | |
| 50-329-82-05, 50-330-82-05, NUDOCS 8205120244 | |
| Download: ML20052F220 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-329/82-05(DETP); 50-330/82-05(DETP)
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 1 and 2 Inspection At: Midland Site, Midland, MI Inspection Conducted: February 3-5, 17-19, 22-26, March 9-10, 17-19, and 30, 1982 NNN
'b Inspector:
R. B. Landsman i
Appproved By:
C.C. Williams,Cl$
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N Plant Systems Section
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Inspection Summary Inspection on February 3-5, 17-19, 22-26, March 9-10, 17-19, and 30, 1982 (Reports No. 50-329/82-05(DETP); 50-330/82-05(DETP))
Areas Inspected: Verification of QA Program for Civil QA Staffing, Permanent Plant Dewatering Wells, Drawdown - Recharge Test, BWST Surcharge Test, and Auxiliary Building Access Shafts being done as part of the Remedial Soils measures. The inspector also attended three meetings, two in NRC-licadquarters with the licensee and their consultants and one conducted in the Region III office in Glen Ellyn. The inspections involved a total of 86 inspector-hours by one NRC inspector.
Results: Of the areas inspected, one item of noncompliance and one deviation was identified - Severity Level IV, Inadequate Procedures; Deviation from commitment to provide adequate technical QA staff for the Remedial Soils work.
8205120244 820426 DR ADOCK 050003gg PDR
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DETAILS Persons Contacted Consumers Power Company (CPCo)
B. W. Marguglio, MPQAD Director W. R. Bird, MPQAD Manager M. Curland, MPQAD Site Superintendent D. E. Horn, MPQAD Civil Group Supervisor R. Akers, M0QAD Civil QAE Supervisor R. E. Sevo, MPQAD Civil IE and TV Supervisor Bechtel Power Corporation A. Boos, Assistant Project Manager N. Swanberg, Assistant Project Engineer J. Fisher, Remedial Soils Group Manager M. A. Dietrich, Project QA Engineer NRC R. Cook, Resident Inspector Other licensee and contractor personnel were routinely contacted during the course of these inspections.
Functional or Program Areas Inspected 1.
Quality Assurance Staffing (Civil Area)
During this inspection a review of the quality assurance staff for the civil work activities was made to determine that adequate technical, quality assurance depth and personnel availability exist
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for the planned remedial measures to be performed as a result of the
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soil settlement issue.
The onsite QA group is divided into two sections; (1) Quality Assurance Engineering (QAE), and (2) Inspection-Examination and Testing Verifica-i
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tion (IE&TV). The QAE section presently consists of a supervisor (an industrial engineer) and three civil engineers. The IE&TV section l
presently consists of a supervisor (a civil engineer), one civil
engineer, a geologist, and two other individuals, one of which has an associate degree in environmental studies. The following determinations were made:
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The QAE section supervisor does not have the technical experience to implement the MPQAD program for the required remedial measures.
b.
The IE&TV staff has very limited technical depth for the complex i
nature of the remedial actions.
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Staffing problems were previously discussed with the licensee (as described in IE Reports No. 81-01 and No. 81-12).
CPCo committed to provide, prior to the initiation of the complex remedial activities, additional qualified staff to participate in these activities.
It is the assessment of the inspector that the staff is not fully adequate and are judged not to be commensurable with the complexity of the task.
Therefore, it has been determined that CPCo is in deviation from an NRC commitment as described in Appendix B of the report transmittal letter (50-329/82-05-01; 50-330/82 05-01).
Subsequent to the inspection, CPCo informed the Region III office that the civil QA section will be reorganized into a remedial soils group and a structural group. The remedial soils group, will have a qualified civil engineering staff. Additional qualified staff will also be provided. This action will be verified during a subsequent inspection.
2.
Permanent Plant Dewatering Wells The inspection was conducted to verify the implementation of the QA program for the initial 20 wells already installed and for the remaining 40 wells presently being installed.
The inspector reviewed the initial 20 well data sheets which are required by Specification C-88 to document all field data obtained during the well installation. From this review, the inspector determined that one of the important well log parameters, comparing the amount of actual gravel pack / grout used to the calculated amounts, was not reviewed. This was determined because the actual amount of gravel pack used was up to 10 cubic feet less than the calculated amount. The hydrogeologist preparing and approving these well logs failed to identify and correct these adverse conditions. This was because the controlling Specification C-88, did not have appropriate acceptance criteria for determining that important activities have been satisfactorily accomplished.
This is in noncompliance with 10 CFR 50, Appendix B, Criterion V as described in Appendix A-of the report transmittal letter (329/82-05-02C; 330/82-05-02C). The licensee committed to review tne well logs to determine if the dewatering wells
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are acceptable.
The inspector reviewed the following documents controlling the remaining 40 dewatering wells:
a.
Specification C-118, " Subcontract to Install Observation Wells and Permanent Dewatering Wells System," Revision 3, dated December 16, 1981.
b.
PQCI 7220/C-2.02, " Permanent Gravel-Packed Wells," Revision 0, dated January 18, 1981.
c.
Subcontractor Procedure 7220-C118-1-1, " Procedure for Installation of Dewatering and Observation Wells," Revision 0, dated January 11, 1982.
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d.
PIPR 7220-C-20D, " Installation of Gravel-Packed Wells," Revision 0, dated January 13, 1982, e.
Drawing C-2016, Revision 5, dated January 8 1982.
f.
Drawing C-2017, Revision 0, dated October 30, 1981.
g.
Drawing C-2018, Revision 0, dated October 30, 1981.
h.
Drawing C-2019, Revision 0, dated October 30, 1981.
From this review the inspector concluded that the documents appear to be satisfactory to control the installation of the remaining 40 wells. The licensee agreed to revise Section 6.5 of Specification C-118 to incorporate appropriate acceptance criteria for the actual amount of gravel pack / grout used. This item remains open and will be addressed in the previous item of noncompliance.
3.
Drawdown-Recharge Test The inspection was conducted to verify the implementation of the QA program for the recharge test.
It is being done to establish that even if all the wells are lost that the water table will not rise significantly during a certain time period to make the loose sands underlying the plant site liquifiable.
The inspector reviewed the following documents controlling the recharge test:
a.
PQCI 7220/C-2.03, " Drawdown Recharge' Test," Revision 2, dated February 3, 1982.
b.
PIPR 7220/C-20C, " Drawdown / Recharge Test," Revision 1, dated February 3, 1982.
c.
Drawing C-1300, Revision 1, dated February 1, 1982.
d.
Drawing C-1301, Revision 1, dated February 1, 1982.
e.
Drawing C-1302, Revision 2, dated February 1, 1982.
From this review the inspector concluded that the documents appear to be satisfactory to control the recharge test. The licensee took baseline readings on February 3, 1982, and shut the dewatering pumps off on February 4, 1982.
4.
BWST Surcharge Test The inspection was conducted to verif y theimplementation of the QA program for BWST valve pit surcharge. The inspector reviewed the following documents controlling the surcharge:
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a.
Specification C-93, " Surcharging and the Instrumentation and Monitoring during Surcharging, fcer the Borated Water Storage Tank Area," Revision 1, dated Decewbor 3, 1981.
b.
PIPE 7220/D-17B, " Surcharging and Settlement Monitoring of the Borated Water Tank Area," Revision 4, dated November 13, 1981.
c.
Drawing C-1148, Revision 3, dated September 14, 1981.
d.
Drawing C-1152, Revision 4, dated November 18, 1981.
From this review, the following concerns were discussed with the licensee. Overinspection Plan C-17B, Revision 4 has contradictory inspection criteria in Item Nos. 4.3D and 4.4A.
Item No. 4.3D states that an acceptable crack width of 20 mils will be allowed. The refer-ence document given was Specification C-93, Revision D, Section 5.5.4.
The inspector determined that Section 5.5.4 was deleted by SCN 11003.
SCN 11003 also added Section 6.0 to Specification C-93 which stated that an acceptable crack width of 16 mils will be allowed. This is also reflected in the overinspection plan in Item No. 4.4A which contradicts Item No. 4.3D.
Furthermore, while reviewing completed Overinspection Plans C-17B, No. 1 and No. 2, the inspector determined the MPQAD inspectors listed SCN 11003 as one of the documents reviewed while making the inspections.
In fact, in the remarks column under Item No. 4.3D of the overinspec-tion plans, Plan No. 1 stated, "less than 20 mils" and Plan No. 2 stated,
"no deviations noted."
Neither inspection plan identified that Item No. 4.3D was a superceded inspection criteria.
Additionally, the inspector determined that site Procedure E-1M, " Site Inspection Planning and Site Inspection," Revision 1, dated November 13, 1981, the controlling document for preparing and implementing overin-spection plans, was inadequate. There are no instructions for the preparer of the plan to list SCN's that were used in the preparation of the plan. There are also no instructions for the inspectors to list SCN's that were issued after the plan was prepared and were subsequently used by the inspector.
In summary, design criteria outlined in the specification, have not been adequately translated into inspection procedures, in that they provide contradicting acceptance criteria. This appears to be the result of an inadequate department procedure. As a result of this, the inspection reports document erroneous results. This is contrary to 10 CFR 50, Appendix B, Criterion V as described in Appendix A of the report transmittal letter (329/82-05-02D; 330/82-05-02D).
The licensee committed to revise Procedure E-1M to clarify the use of SCNs, FCNs, FCRs and DCNs both in preparation and implementation of the overinspection plans. They also agreed to revise overinspection Plan C-17B to delete the contradictions.
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Additionally, the inspector determined that site Procedure EDPI 4.49.1,
" Specification Change Notice," under Section 3.3, has no time limit set to distribute approved SCNs to the affected specifications on site.
This fallu i have an adequate procedure is another example of non-compliance
'O CFR 50, Appendix B, Criterion V as described in Appendix A report transmittal letter (329/82-05-02B; 330/82-05-Another ci
. sed by the inspector was that QC was using a Field.
Inspection (FIR) in lieu of the usual PQCI's to do their in-spections.
.e Procedure PSPG-1.1 intent was to use the FIR's merely as daily arding documents, i.e.,
similar to a daily report, not repetitive incpections. They were not to be used for preplanned com-prehensive inspections. This appears to be an isolated case.and the licensee has agreed not to use the FIRS in this manner again.
5.
Auxiliary Building Access Shafts The inspection was conducted to verify the implementation of the QA program for the access shaft installations. The inspector determined that the installation of the access shafts was being done without complete QC/QA requirements.
For example, the access shaft by Unit I required seven soldier piles to be installed. From a review of the notes on Q Drawing C-1420, Revision 2, the inspector determined that the drilling of the holes for the piles was non-Q.
The piles them-selves were also non-Q.
However, the concrete and grout used to backfill the holes was Q.
The inspector further determined from a review of Specifications C-196 and C-45, that only one and one-half holes and piles were Q.
Five and one-half were considered non-Q because they were in non-Q soil. This fragmented approach is the result of the shafts being considered as a non. quality related activity.
This is a continuation of the same problem that the inspector has had with trying to inspect the soils borings and the initial 20 permanent dewatering wells. Only portions of each activity were considered Q.
This fragmented approach to quality activities is detrimental to the overall satisfactory completion of the remedial soils work.
Af ter numerous discussions with site QA personnel, the issue could not be resolved and it was decided to have a meeting between CPCo, Bechtel, NRR and IE to finally address the inspector's concerns in this area. See Section 6.b of this report.
Furthermore, the inspector determined that site controlled Field Procedure FPC-1.00 for installing the soldier piles for the access shaft was not reviewed and approved by the contractor prior to the initiation of work on Q-piles as required by Site Procedure FPG-1.000.
i The inspector determined that this was the result of CPCo allowing Mergentine Corp. to proceed without having an approved procedure to
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prepare procedures. This failure to follow procedures, is another example of the licensee's noncompliance with 10 CFR 50, Appendix B,
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Criterion V as discussed in Appendix A of the report transmittal letter (50-329/82-05-02A; 50-330/82-05-02A).
6.
Meetings with CPCo, Bechtel, and NRR a.
The inspector attended meetings held on February 22-26, 1981, in NRC Headquarters regarding the remedial measures to be taken for the soils deficiencies.
In particular, the following items were discussed:
(1) Recharge Test (2) Dewatering Concerns (3) BWST Surcharge Program (4) SWPS Soils Issues (5) SWPS Structural Issues (6) SWPS Remedial Construction Issues (7) DG Soils Issues (8) DG Structural Issues (9) DG Cracking Concerns
(10) Auxiliary Building Remedial Work Monitoring Program (11) Auxiliary Building Spring Constants b.
The inspector also attended a meeting held on March 9-10, 1982, in NRC Headquarters regarding the quality assurance program for the remedial soil work activities.
The purpose of the meeting was to discuss concerns raised by IE-RIII over the amount of limited involvement that MPQAD has with the remedial soils work.
Following discussions, the meeting ended with the licensee verbally committing to the following:
(1) All remaining remedial work will be Q-listed except on very specific items which can be shown to justify non-Q treatment. NRR/IE concurrence in this justification must be obtained prior to conducting any work outside of the QA program.
(2) Continue the access shafts down to EL.609 as non-Q, but from there on, Q.
(3) Continue the freeze-wall and dewatering wells as non-Q.
c.
The inspector also attended a meeting held on March 30, 1982, in Region III offices. The meeting was initiated by Region III to discuss:
(1) the issues raised from the inspection of the auxiliary building remedial soils instrumentation; (2) the specifics on how our inspection program for the remedial soils work will be handled; and, (3) the licensee's QA program for the remedial soils work. Those in attendance were:
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CPCo J. Cook, Vice President B. W. Marguglio, MPQAD Director W. R. Bird, MPQAD Manager J. A._Mooney, Projects J. Brunner, Lawyer NRC C. E. Norelius, Director, Division of Engineering and Technical Programs W. S. Little, Chief, Engineering Inspection Branch R. C. Knop, Chief, Projects Branch 1 E. G. Adensam, Chief, NRR Licensing Branch No. 4 C. C. Williams, Chief, Plant Systems Section D. C. Boyd, Chief, Reactor Projects Section 1A D. S. Hood, NRR Project Manager Midland J. Gilray, NRR QA Branch R. Gardner, Inspector R. Cook, SRI Midland M. Blume, ELD Lawyer A summary of the items discussed is as follows:
(1) The auxiliary building remedial instrumentation was specifically identified as Q on the licensee's January 7, 1982, submittal to the NRC. As such, a Confirmation of Action Letter was discussed with the licensee and it was decided, at the licensee's rcs..s t, that they would submit a confirmatory action letter to the NRC.
(2) The licensee was informed that one inspector has been dedicated to the Midland Soils Area; and, inspections will be conducted in accordance with our standard inspection program.
They were requested to provide the NRC with upcoming weekly construction schedules, including any abnormalities that occurred during the prior week. They were also requested to provide a principal point of contact for the remedial soils work.
(3) The agreements reached during the March 10, 1982, meeting were reconfirmed. That is, the remaining remedial soils work will all fall under the "Q" classification. Exceptions on very specific items will require NRC concurrence prior to conducting any work outside of the Quality Assurance Program.
Exit Meetings The inspector met with the licensee and contractor representatives at the conclusion of the inspections on February 5, 9 and March 17, 1982, and summarized the inspection scope and findings. The licensee acknowledged the findings reported herein. However, as a result of the findings iden-tified, the inspector again informed the licensee that more emphasis must
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be placed on the attention to detail in the preparation, review and imple-mentation of documents. The enforcement history in this area-indicates a continued lack of attention to detail. As a result of these findings, it is clear that upper management is not playing an active role in conveying the principles of Quality _ Assurance to the working staff to assure QA principles are being properly carried out.
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