ML19250C410
| ML19250C410 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/16/1979 |
| From: | Hood D Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7911230369 | |
| Download: ML19250C410 (31) | |
Text
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ja arow.
O, UNITED STATES E',sy3 i NUCLEAR REGULATORY COMMISSION
,.p j-p WASHINGTON, D. C. 20555 k..... /
OCT 16 673 Docket Nos. 50-329 and 50-330 APPLICANT: Consumers Power Company FACILITY:
Midland Plant, Units 1 & 2
SUBJECT:
SU? NARY OF SEPTEMBER 5,1979 MEETING ON QUALITY ASSURANCE ASPECTS OF STAFF'S 10 CFR 50.54(f) REQUEST ON SOIL SETTLEMENT DEFICIENCY On September 5,1979 the NRC staff met in Bethesda, Maryland with Consumers Power Company (the applicant) and Bechtel to discuss quality assurance responses regarding the abnomal soils settlement at the site for Midland Plant, Units 1 & 2.
Attendees are listed in Enclosure 1, which reflects a change in the position of Bechtel Project Manager. The meeting agenda was based upon supple-mental staff request 23, for which a draft version (Enclosure 2 hereto) was used as a staff handout. The request asks for further detail regarding question 1 of the staff's March 21, 1979 letter, "10 CFr. 50.54 Request Regarding Plant Fill."
The applicant summarized (1) its internal review conducted for the original FSAR preparation and early amendment efforts, and (2) the FSAR re-review program described in response to Question lb of the March 21, 1979 letter. This pre-sentation used the handouts of Enclosure 3.
The FSAR re-review program will include all soils-related text and about 55% of Chapters 1 through 12. The applicant's criteria for selecting areas for re-review are listed on page 3 of.
Staff discussions of this presentation included the following s0ggestions:
1.
Clarifying material should be added to the response (e.g., the terms " active" and " inactive" and the degree for which procedures and specifications related to these categories will be re-evaluated).
2.
The use of terms such as "as necessary" in describing the re-review program is unacceptable. Specific criteria for such conditions are required for staff review.
3.
The staff stressed the special significance of FSAR Chapter 15 in establishing the safety of the plant. The staff suggested that Chapter 15 be re-reviewed by both the re-review team and the Midland Nuclear Safety Task Force described in S. Howell's letter of July 26, 1979. The staff also considers participation by B&W to be significant in this regard.
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. OCT is 'S79 4.
The response should identify the specific safety related and non-safety related FSAR subsections to be reviewed.
5.
The staff questioned the adequacy of the applicant's PSAR commitment list.
The applicant should re-review the list against the PSAR, ER, SER, FES, CP, hearing record and other documents issued prior to the FSAR for which commitments or requirements may have been indicated.
6.
The applicant should evaluate earlier design review procedures considering factors such as depth of review, qualifications of reviewers and extent of documentation of results.
7.
Identify and discuss the procedures to accomplish the re-review.
8.
Specify how the group supervisor and review team are conducting the re-review relative to such factors as depth (e.g., what is the extent of verification by discipline?).
9.
Clarify presentation charts.
- 10. The staff cited recent experience with operating plants comparing the installed condition of piping supports to final as-built drawings as an example for which special attention should be directed. The staff suggested the applicant discuss how the re-review relates to percent completion for plant construction and how the corrections resulting from re-review are implemented so as to reflect as-built conditions of the plant (i.e., how and as-built conditions of the plant?) program assure that the FSAR reflects the to what extent does the re-review
- 11. The staff felt that additional infomation regarding re-review by B&W is needed in the response.
- 12. The staff requested more detail regarding the. instructions provided the reviewers during FSAR preparation. The staff questioned the depth of the peer review of the FSAR sections during preparation, and suggested that this be considered when detemining the root causes of the deficiencies.
The applicant stated that FSAR review audits are scheduled for October 26, 1979 and February 1, 1980.
A Bechtel representative provided further detail of the 13 deficiencies identified in response to question la. The presentation used Enclosure 4 as a handout.
Specific comments during this presentation follow:
1389 M2
. OCT 161979 1.
The lack of specificity in the SAR text should also be considered when determining the root causes of deficiencies.
2.
The applicant should address whether past Resident Engineer Memos, letters, etc. were reviewed for the need to incorporate them as Specification Change Notices.
3.
Only minimum clearance requirements were reflected on the civil drawings used to construct the electrical duct banks located under the Diesel Generator Building. The applicant's review of this approach for generic implications shows that other drawings may have failed to recognize the need for both an upper and lower tolerance on dimensions. The applicant will evaluate the effect on the seismic analysis of duct dimensions in excess of nominal dimensions.
4.
The applicant will consider whether poor selection of compaction equipment was a root cause of the deficiency.
5.
The applicant will review several recent Non-conformance Reports to evaluate whether inadequate technical direction was a contributing factor.
6.
The applicant will consider whether lack of criteria for deploying technical engineers may have been a root cause for the deficiencies.
7.
One root cause was given as inadequate inspection callouts for soils placement.
The applicant will conduct a review to determine if specifications are suf-ficiently detailed in this regard. tabulates the process corrective actions completed and on-going by the applicant and indicates whether these actions are limited to soils areas or have broader (generic) scope. The staff suggested that Enclosure 5 would be more meaningful if the start date and completion date of each activity were included.
The staff stated that the draft questions of Enclosure 2 would be finalized and issued within one week.
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Darl S. Hood, Pro'ect Manager j
Light Water Reactors Branch No. 4 Division of Project Management
Enclosures:
As stated cc: See next page 1389
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Consumers Power Company J
ccs:
Michael I. Miller, Esq.
Mr. S. H. Howell Isham, Lincoln & Beale Vice President Suite 4200 Consumers Power Company One First National Plaza 212 West Michigan Avenue Chicago, Illinois 60603 Jackson, Michigan 49201 Judd L. Bacon, Esq.
Consuners Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Mr. Paul A. Perry Secretary Consumers Pour Company 212 W. Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esq.
One IBM Plaza Chicago, Illinois 60611 Mary Sinclair 5711 Summerset Drive Midland, Michigan 48640 Frank J. Kell ey, Es q.
Attorney General State of Michigan Environmental Pr otection Division 720 Law Building Lansing, Michigan 48913 Mr. Wendell Fbrshall Route 10 Midland, Michigan 48640 Grant J. Merritt, Esq.
Thompson, Nielsen, Klaverkanp & James 4444 IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402 Mr. Don van Farowe, Chief Division of Radiological Health Department of Public Health b> ( )bk P. O. Box 33035 Lansing, Michigan 48909
ENCLOSURE 1 Attendees September 5, 1979 Consumers Power Comoany J. J. Zabritski, Project Licensing Eng.
B. W. Marguglio, Director of QA D. E. Horn, Group Supervisor (Civil)
Bechtel J. A. Rutgers, Project Manager L. A. Dreisbach, Project QAE J. A. Clements, Licensing Engineer G. L. Richardson, QA NRC D. S. Hood L. S. Rubenstein
., c. O D. J. Skovholt l30/
)65 W. P. Haass J. G. Spraul J. W. Gilray R. J. Cook R. C. Knop G. W. Reinmuth R. E. Shewmaker W. Belke
[n c } e.t we A D:W~i SUPPLEMENTAL REQUEST FOR ADDITIONAL SOILS SETTLEMENT INFORMATION:
PART I
- 23. We have reviewed your response to question 1 of our March 21, 1979 letter, "10 CFR 50.54 Request Regarding Plant Fill", including related amendments or supplements in your letters dated May 31, July 9 and August 10, 1979. We find that the information provided is not sufficient for completion of our review.
Accordingly, provide the following additional information:
(1) "our response to question la does not provide sufficient information relative to the root causes of the 13 deficiencies.
In order to determine the acceptability of the corrective actions for the 13 deficiencies consider-ing the possibility that these deficiencies are of a generic nature that could affect other areas of the facility, a more complete understanding of the root cause of each deficiency is necessary. Accordingly, provide a clearer description of the root causes of each of the 13 deficiencies, including a detailed discussion of the conditions that existed to allow these deficiencies and the changes that have been made to preclude the recurrence of such deficiencies.
(2) Regarding your response to question lb:
a.
The first seven paragraphs do not provide sufficient information to assure that contradictions do not continue to exist in the PSAR, FSAR, design documents, implementing procedures, and as-built condi-tions since the controls described in these seven paragraphs were in effect prior to the I&E findings reported in J. Keppler's letter of March 15, 1979. Modify your response to clearly cescribe the control revisions you have instituted to preclude design contradictions.
b.
Items 1, 2, and 3 of the eighth paragraph describe the review and update of the PSAR commitment list. the review of the inactive sections of the FSAR, and the review of procedure EDP 4.22, " Preparation and Control of Safety Analysis Reports," without describing the extent of the review process or the qualifications of personnel involved in the review.
Accordingly, describe what each of these reviews entails, including the extent to which these reviews are verified, approved, and documented.
Identify the organizational unit that is, or will be, involved in these reviews and the qualifications of the involved personnel.
c.
Item 2 of the eighth paragraph states that a review of the remaining sections of the FSAR is not necessary,"... because of the ongoing review process described above." Describe your rationale for not reviewing these remaining sections of the FSAR when it appears that the original review of the FSAR was performed prior to issuance of the March 15, 1979 letter providing the I&E findings a~nd prior to any corrective actions resulting therefrom.
d.
Describe the extent of the audit to which ynu ;1 ave cormitted in item 4 of the eighth paragraph.
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(3)
Question Ic requestcu chat other activities be investigated to determine whether programmatic +Jality assurance deficiencies exist in view of the apparent breakdown of certain quality assurance controls, and that the activities investigated and the results be identified.
Your response addressed certain specifications and instructions that received a review of 1977; providing for more in-depth verification; increasing management audits from one to two per year; increasing the staff of Bechtel's QA engineers at the site from five to eight; instituting an overinspection program on certain Q-listed construction activities; assigning resident engineers at the site to aid in the interpretation of drawings and increas-ing their number from one to twenty-two; and initiating a trend analysis
- program, a.
According to your response, most of these actions were initiated in 1977.
Describe your rationale for assuming that these actions provide confidence that quality assurance defit.iencies do not exist in other areas.
In order to determine if other areas have deficiencies, work already accomplished in these areas should be investigated.
This includes the review of completed documentation, including inspection results, to verify consistency with design and SAR requirements.
Also, representative sample inspections of completed work would seem appropriate to determine the acceptability of this work. Accordingly, describe a program in detail to accomplish the above or provide rationale as to why it is not necessary, b.
Your use of generalized statements such as "the reivew of", "i creased i
audits," "overinspection," " identifying trends," and "increau of staff" does not provide sufficient specificity regarding the detail and extent these actions will take place and the effect they will have in assuring other areas are not deficient.
Accordingly, in each of these areas provide a clearer description of these actions relative to the full impact they will have in assuring an effective QA program ano in sufficient detail to assure that other areas are not deficient.
In those cases where credit is taken for actions already accomplished (such as reviews, inspactions, and audits), provide a summary of the results of these actions such that the success or failure of the actions can be determined.
(4) Considering the results of your investigation recuesteu in our question ic, question ld asked that you describe your position as to the overall effectiveness of the QA program for the Midland Plant. Your overall assessment of the effectiveness of your program should be based on your revised response to our question ic.
(see above question 23(3)). The results of this assessment, including a description of the scope and extent of the assessment effort and the identification and qualifications of the individuals involved in this assessment, should be reported to us.
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HISTORY --
-- I!# T # f,_
TIHE ACTIVITY RESPONSIBLE ORCANIZAT' ION 1969-1977 PSAR DISCIPLINES APPROX.150 CIIANGE NOTICES 1976-AUGUST, 1977 FSAR DEVELOPED AND SUBMITTED FSAR OitGANIZATION AUGUST, 1977 AUGUST, 1977 TO FSAR DISCIPLINES PRESENT 1600 CllANGE NOTICES ADDITIONS PTR NRC QUESTIONS (900)
DESIGN CNANGES DESIGN CLARIFICATIONS CLERICAL CORRECTIONS 6% TECl! CORRECTIONS 6/79-1/80 RE-REVIEW DISCIPLINES O
e O
6 CO W
v CO l
D**D 5
- l FSAR e
SOILS OTIIER AREAS ORIGINATION
- PREPARED BY GEO/TECl!
- PREPARED BY FSAR ORGANIZATION
- REVIEWED PRIOR TO SUBiITTAL
- REVIEWED PRIOR '10 SUstITfAL BY DISCIPLINES BY DISCIPLINE
- (NOT ALL SPECS AVAILABLS)
REVIEW
- INACTIVE
- ACTIVE k ' * ' * '
- N0 NRC QUESTIONS
- 1600 CllANGO IK/fICES
- NO CIIANGE NOTICES
- REVIEWED BY DISCIPLINES
- METIIOD:
- EDP 6.23 "5A /f Ch Cd d 1
- ELDEITf REVIEW
- DEGREE OF REVIEU BASED ON DEGREE OF ACf1VITY RE-REVIMI
- SPECIAL PROCEDURE
- SPECIAL PROCEDUilE t.
- SYSTE!4/SUBSYSTH4 RE-IlEVIEW
- SYSTE!4/SUIVlYSIi21 lie-REVIEW
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- RE-REVIEW BY DISCIPLINE & GE0/TECl!
- RE-REVIDI BY DISCIPLINES e
- TOTAL RE-REVIDI
- I 55% OF CIIAPTERS 1-12 v
I c
- ADDITIONAL RE-REVIIM AS NECESSARY N,
-I3 E.-REVEW CRITERIA
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? UICIIONS WICH WEEE EIAC. TIVE S.E. CE T.EIR O.R.I.G.U. AL -I.N..C.O.E.F. O. A. "' ION ETO
? pECTIOIG -FCR WICH TERE HAVE BEEN MAJOB DyIGN CHRiGES t SECI'IOIG FOR UHICH ETCOIGISTINCIES MAY F.E' ST JASp ON g 70LIGTING
.COI6DZ%TIONS:
I SECTICIE WIIH MTJLTIP.LE CROGS Aeracucrid
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? SECTIO?E WITH h%"'IPLE E"IERFACES 4..,
? SECTICITS WITE MULTIPLE CEGANIZI. TION,EiFisTS
? S.EC. _T. IONS WITH PREVIOUSLY ID_Eh.Le.u. u IIiC. G..IG..I..S.I_E.UCI..ES
? CalTTER 15 TO Eb A!DE3 SED SEFARATE FRG4 THIS PECGEld
? I@N: SAFETY ELATED SECTICIiS EXCLUDED FECM EE-Ey/IEW
? CHAPTEES 13,14 MiD 17 NOT DESIGN RELATED MID EXCLUDED FRG4 THIS RE-EVIEW
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.B.U,..I. AE _BEING R..E7E. ' vied S..EPARATEITf BT.CPC. O CHAPTE.R 16 BEEG pIGNIFICETI'LY Rum, D MID WILL EE,Ep yED LATER
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RE-REVIEW If E T 11 O 7 I.
IDENTIFY ORIGINAL PSAR COMMITTilDIT.
2.
COMPARE PSAR COMIIITnfENTS WITil FSAR COMilITDIENTS FOR CONSISTDiCY.
3.
CO!! PARE FSAR COM!!ITT!!ENTS WII11 SPECS, DRAWINGS AND OTIIER DESIGN DOCUMENTS FOR CONSISTENCY.
4.
IDENTIFY DISCIPLINE I!4TERFACES AND REPEAT STEPS ABOVE AS APPROPRIATE.
5.
IDDITIFY AND DETERl!IllE NEED TO DISPOSITION CONSULTANT RECOMMDIDATIONS.
6.
RESOLVE O!!ISSIONS AND INCONSISTENCIES AND PROVIDE DISPOSITION.
7.
a.
VERIFICATION BY DISCIPLINE GROUP SUPERVISOR b.
OVERALL MANAGDIENT AND ACCOUNTABILITY BY LICENSING.
c.
AUDITS BY QUALITY ASSURANCE.
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Midland Plant Units 1 a 2 FSAR RE-REVIEW FLOW CHART consumers Power company BeChtel job 7220 BecMel
- 'E Interface / Review Final Project nsing Comp / Disc Approval Administration Co p/
c gp REVIEWS FSAR REVIEW PACKAGE PREPARES FSAR AGAirJST DESIGN REVIEW PACKAGE DOCUMENTS. IN-DI A EQUIRED 4-t Til PSAR DESIGNATES RE-COMMITMENT LIST OulF.ED INTERFACE AND NRC QUESTIONS.
REVIEW.
COPIES FSAR 9
-y REVIEW PACKAGE.
Q DISTRIBUTES EACil g
TO DESIGNATED INTERFACE REVIEW g
COMP./ DISC.
k REVIEWS FSAR
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REVIEW PACKAGE H
p------> gggyggip,N g
p DICATES REQUIRED O
CHANGES.
SENDS ORIGINAL
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PACKAGE AND CD I
INTFRFACE REVIEW 4
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l>- COPIES TO PRIMARY COMP / DISC FOR I
v RESOLUTION OF IN-y g
TERFACE COMMENTS.
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FINAL REVIEW /
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APPROVAL BY CPCo.
1 B&W (IF REQUIRED)
PREPARES SAR AND BECHTEL
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RESOLVES CHANGE NOTICES IN PROJECT ENGINEER.
It4TERFACE
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COMMENTS AND DI 3
O A t1S TYPING u::
t S lE E 1 AL AP RO L C IJ l JG T
U F>f TO LICENSING INPUT FOR FSAR p
REVISION.
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FSAR REVIEW DOCUT.1ENTATION FORM d
MIDLAND PROJECT JOB 7220
- 1. REVIEW LOG NO.
3
- 2. COMPANY:
- 3. PRIMARY REVIEW DISC:PLINE:
O CPCo O BECHTEL O B&W
- 4. FSAR SUBSECTION:
- 5. NRC QUESTIONS:
- 6. PSAR CCMMITMENT UST ITEMS:
- 8. PHASE 1: DESIGN DOCUMENT REVIEW
- 7. RETURN TO BECHTEL UCENSING BY:
DESIGN DOCUMENT CONFLICT RESOLUTION YES / NO YES / NO YES / NO YES / NO YES / NO YES / NO YES 'l NO YES / NO YES / NO YES / NO YES / NO JM
- 9. INITIAL REVIEW APPROVAL (INDICATE REQUIRED INTERFACE REVIEW IN BLOCK 11.)
(PRIMARY REVIEWER)
(OATE)
(SUPERVISOR)
(DATE)
- 11. PHASE 11: INTERFACE REVIEW
- 10. RETURN TO BECHTEL LICENSING BY:
O BECHTEL BECHTEL DISCIPUNE INTERFACE REVIEW:
INTERFACING STAFF REVIEW:
C ARCH O PLANT CSN O ARCH O M & CS OCML O PCAE OCML O MECH I I CONTROL SYS
'l1 STRESS M CONTROL SYSTEM l'1 NUCLEAR _..
O ELEC O OTHER O ELEC O PLANTCSN O MECH / NUCLEAR O GEOTECH O :,7, RESS O CPCo OB&W
- 13. PHASE 111: RESOLUT!CN OF CCMMENTS
- 12. RETURN TO EECHTEL Ll CENSING SY:
FSAR CHANGE REQUIRED YES / NO All Interface Ccmments Resolved. Ucensing Grcup is Authen:ed To Initiate A FSAR Change Wheut Additional Interface Review.
(PRIMARY REVIEWERI (OATE)
(SUPERVISCR)
(OATE) i389 173
FSAR/ SOILS ROOT CAUSE CORRECTIVE ACTION
- SPLIT RESPONSIBILITY FOR PREPARATION.
- SINGLE RESPONSIBILITY FOR PREPARATION AND REVIEW
- SttALL AHOUNT OF REVIEW BECAUSE OF INACTIVITY.
'SOMC MINOR SPECIFICATION CIIANCES WIT 110UT F S A R
- ALL SPECIFICATION CIIANGE NOTICES SUBJECT TO REVIDl.
REVIEW FOR COMPATABILITY WITil F S A R
- MULTIPLE DISPLAY OF TECllNICAL INFORMATION IN
- RE-REVIEW Y S A R.
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FSAR REVIEW AUDIT SCllEDULED FOR OCTOBER 26, 1979, AND FEBRUARY 1, 1980 dECllTEL AND CONSUfERS POWER COMPANY TO PARTICIPATE KEY AUDIT POINTS PROCEDURAL COMPLIANCE EFFECTIVE!!ESS OF DETECTING F S A R OMISSIONS AND INCONSISTENCIES EFFECTIVENESS OF IMPLIMENTI!1G CORRECTIVE ACTION
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CD v
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E nel,sare 4
p.> s Key to Matrix (g.3e.5 2. - 13 he r e c. f-f e D
A Root Cause B
Permitting Factors C
Process Corrective Action for Soils D
Generic applicability and Generic process corrective action E
QA Program Elenents to Identify other similiar Deficencies.
1389 176 e 9
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I-1 Inconsistency between the Specification and Dames and Moore Report 29 A
Did not provide documented disposition to the DGi reco==endations thich project did not implement.
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Did not recognize necessity to provide documented disposition.
C Dei Report reviewed.
- FSAR revised to clearly indicate project con:mittments.
D Potentially generic to FSAR.
Other consultant recou:mendations will be reviewed for lack of disposition.
E FSAR re-review.
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I-2 Lack of Formal Revisions of Specifications to Reflect Clarification of Spec-ification Recuirements A
Did not recognize need to for= ally change specifications for which clar-ifications were provided by RDI's, letters, or telecons.
B No procedural prohibitions existed. No general problems identified at the time.
i I
C Improvements made in soils specification to eliminate need for future interpretations.
l t
D Generically applicable.
l Specification review and specification changes made to minimi=e need for
{
futurh interpretation.
j
- EDPI 4.49.1 Revised to require clarification to be ac.complished with for=al design docu=entation.
b-E Final Inspection and Turnover will. accomplished to final design disclosures.
-QA Audit (1st Quarter 1980) 1389 178 3
I-3 & 4 Inconsistency of Information within the FSAR Relating to DG Building Fill 5'
Material and Settlement.
Inconsistency between Basis for Settlement Calculations for DG Building and Design Basis.
~
A
- Split res ponsibility for preparation.
Small amount of review exposure because of inactivity in these sections.
Some minor specification changes made without review for compatibility with FSAR.
Multiple display of technical information to FSAR.
B Same as A above C *Ccrrected inconsistancies.
- Reviewed soil sections of FSAR.
- Established single point responsibi.ty within disciplines.
D Cenerically applicable to FSAR Re-review
- All specification changes will be subject to review for compatability with FSAR.
E
- Procedure governing review of changes for compatability with SAR Audit of compliance with procedure for change control.
Audit re-review.
1389 079 O 1 e4 e
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I-5 Inadecuate Desien coordination in the Desien of the Duet Bank A
Complete clearance requirements not reflected on the civil drawing used to construct the duct bank.
B Unique circunstance for the particular construction aspect which was not adequately addressed in t:
design process.
C Reviewed all similiar design configurations and found no additional problems.
I D
- Generically applicable to duct bank interfaces.
- Resolved per C above.
E Design interface coordination procedure.
Audit for compliance to procedure.
1
- Inspection and over inspection progra=s.
1 89 180
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II-1 Insufficient Compactive Effort used in Backfill Operation A
Did not adequately qualify equipment for allowable lift thickness.
B. Lack of specificity in specification for this parameter.
Test data misleading (results and methods).
C.Requalifying equipment
. Revised specification
. Revised QCI D.Potentici generic applicability
.All procedures reviewed-No other equipment identified which are not already properly qualified.
E Inspection and test.
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3 l
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\\ 2 Insufficient Technical Direction in the Field e
A Soils Engineers not properly deployed.
~D B
No early indicators of quality problen (test results misleading)
C Specification revised to require that soil engineer be stationed at the site.
Duties more explicitly defined.
l f
D. Potential generic applicability.
.All other procedures (areas) review m-No other areas identified for which technical direction was judged inadequate.
E. Specification / Procedural requirements for engineering coverage in field.
Supervisor control
. Increased QA/QC awareness of the requirements for technical coverage.
. Inspection, test, trending, ect.
1389 182
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III-1 Inadequate QC Inspection of Placement A
Inadequate inspection callouts (extent and documentation).
B
- Misleading test results.
Program allowed surveillance inspection methods:
- characteristics
- accountability
- sampling C
Eliminated surveillance made for final acceptance of characteristics.
D *Through 1977-Surveillance used for final acceptance extensively only in the soils area. Therefore, no generic i= plication.
'Thereaf ter-Eliminated surveillance per C above.
E
- Borings test and repair program.
it
- Revised inspection, test, over-inspection, audit, trend, est.
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III-2 Inadequate Soil Moisture Tests ( Tining )
A. Lacked specification clarity to cause test to be run at required tine,
.Did not evaluate the effect of the various interpretations applied.
.Did not acconplish for=al specification changes.
B Reliance on misleading compaction test results for final acceptance.
C Specification and QCI changes.
D Potential generic applicability
. Reviewed specifications in all disciplines for specificity.
E Any inquiries or requests for interpretation necessitate review of specification for specificity.
Resulting clarifications are made by SCN's.
1389 184 O
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III-3 & 4 \\
Incorrect Soil Test Results and Inadequate Test Procedures.
,;gza 1.
- Did not'At1112e a systematic approach to detect erroneous results.
~5 Lacked adequate procedures.
Misused / overused certain laboratory standards.
(Investigation of testing and test t wsults in progress) a B *Need for procedures to administzatively centrol testing not l
recognized.
No industry standards for administratively controlling testing.
{
I C
- A laboratory standard is being required for every field test.
' Tests are being riotted against zero air void curves.
- Soil and QC Engineers are reviewing test data.
D *Potentially Generic to UST testing activities.
'A technical audit has been conducted which included the review of procedural coverage for all other UST testing activities.
(25-2-7)
E 'QC and QA Inspection and overinspection.
Test program
- Preoperational O 9
- 4 e*
PF
- e
e IV-1 Inadequate Corrective Action for Repetitive Conditions
,f;Gi-I A
- TREND prograd' did not cause recognition of need for process correction action.
I
- The process corrective action required by CPCo, NCR199, was not accomplished in a ti=ely manner.
B
- Program allowed date to be diluted by spreading nonconfor=ances over j
many categories without combining them generically.
- Lack of universal understanding as to who had the responsibility for the schedule aspects of process corrective action.
C
- TREND program revised
- E=phasized QA responsibility for schedule control of process corrective j
action.
(Procedural change in progress)
D
- Generically applicable and resolved per C above.
E ' Application of revised trend program
- Stop work authority.
1389 186 e *
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IV-2.
The Bechtel Audit and Monitor Program did not identify the problems relating to the. settlement.
A
- Lacked sufficient technical auditing in the program.
B
' Technical aspects not e=phasized in the audit process.
C
- Audit and overinspection include the check of quanitative parameters and technical elements.
D ' Generically applicabic - resolved per C abeve.
E Managsment and CPCo review for adherence to audit schedule.
1389 187 h
t e 0 17_.
Assessment of the Effectiveness of the Midisnd OA Program Effective because of:
1.
QA Program self monitaef elements
~
0verinspection
. Internal audits
. External audits Trend programs
.NRC Inspections 2.
Twenty-five corrective actions identified in the 50.54f response, 15 were generic actions.
i 3.
High degree of management involvement.
l 4.
High degree of general ecmpliance with regulatory requirements.
1389 188 N
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