ML19256E812

Forwards Revision 4 to 790424 Response to NRC 10CFR50.54(f) Request.Revision Provides Complete Response to Question 23 of NRC 790911 Request for Addl QA Info

ML19256E812
Person / Time
Site:	Midland
Issue date:	11/13/1979
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Harold Denton Office of Nuclear Reactor Regulation
References
HOWE-293-79, NUDOCS 7911150284
Download: ML19256E812 (100)

Text

. ~

=

~

Stephen H. Howell Senior Ysce President General offices: 1945 West Pernail Road, Jackson, Michigan 49201 e (517) 7884453 Hove-293-79 November 13, 1979 US Nuclear Regulatory Co= mission ATT: Mr. Harold R. Denton Office of Nuclear Reactor Regulation Washington, DC 20555 MIDLAND PROJECT-DOCGT NO. 50-329 and 50-330 RECPONSE TO 10 CFR 50.5h REQUEST ON PLANT FILL -

FILE: Ok85.16 UFI 71*01 SERIAL: 7914 Enclosed are ten (10) copies of Revision 4 to Consumers Power Company's response to April 24, 1979 to your 10 CFR 50 5h(f) request dated March 21, 1979 Revision h provides a complete response to question 23 transmitted by Mr. L. S. Rubenstein's Request for Additional Quality Assurance Information dated September 11, 1979 This response includes much of the same informa-tion that was presented to the NRC staff on September 5, 1979 except that additional information has been added to be responsive to staff requests made by the NRC during that meeting.

The two additional Quality Assurance Branch questions transmitted b;-

Mr. L. S. Rubenstein's letter of September 11, 1979 are being handled as part of the normal operating license review and vill be provided in the next planned FSAR revision in January 1980.

Consumers Power Company By b StephbsdH. Howell, Sr Vice President Sworn and subscribed to before me on this 10th day of November 1979 Lb/d NotaryPublfe,JacksonCountp, Michigan My commission expires September 21, 1982 CC: JGKeppler (w/h att)

NRC, Region III WLawhead (w/att)

Corps of Engineers ')

h~

, 7911150 i

RESPONSES TO THE NRC 10 CFR 50.54(f) REQUEST REGARDING PLANT FILL FOR MIDLAND PLANT UNITS 1 AND 2 CONSUMERS POWER COMPANY DOCKET NUMBERS 50-329 AND 50-330 Consisting of:

1. Preface

2. Completion Status of Each Response

3. Responses to '; e 23 Questions Report Date : April 24, 1979 Revision 1: May 31, 1979 Revision 2: July 9, 1979 Revision 3: September 13, 1979 Revision 4: November 13, 1979 1338 289

SUMMARY

OF REVISIONS TO THE 10 CFR 50.54(f) RESPONSE PREPARED ON SEPTEMBER 13, 1979 The following revisions have been incorporated into the responses previously submitted on April 24, May 31, July 9, and September 13, 1979:

1. Cover sheet: Added date of revision.

2. Preface: Added paragraph to second page.

3. Completion status page: Added Question 23.

1338 290 Revision 4 11/79

COMPLETION STATUS Date to Complete Response Question Question Status (If Applicable) Actions and/or Remarks 1 Complete Corrective actions are currently in process.

2 Complete 3 Complete 4 Interim December 1979 Provide acceptance criteria.

5 Complete 6 Complete 7 Complete 8 Complete 9 Complete 10 Complete 11 Complete 12 Complete Complete response submitted in Revision 1.

13 Complete 14 Interim December 1979 Provide analysis and evaluation.

15 Complete Complete response submitted in Revision 3.

16 Complete 17 Complete Complete response submitted in Revision 2.

18 Complete 19 Complete 20 Complete Complete response submitted in Revision 2.

21 Complete 22 Complete 23 Complete 1338 29i Revision 4 11/79

i Preface (continued) have now been modified. To eliminate any liquefaction potential of the sands, the use of a permanent dewatering system in lieu of chemical grouting is now planned. This solution was recommended by the soil consultants, Dr. R.B.

Peck and Dr. A.J. Hendron, Jr. The response to Question 12 has been revised to incorporate areal dewatering as the remedial measure for eliminating the liquefaction potential.

Responses to any remaining questions which refer to chemical grouting will be reviewed and revised as required by August 1979 to eliminate conflicting remedial methods.

Revision 4 provides a complete response to Question 23 transmitted by Mr. L.S. Rubenstein's Request for Additional Quality Assurance Information dated September 11, 1979.

This response includes much of the same information that was presented to the NRC staff on September 3, 1979, except that additional information has been added to be respons27e to staff requests made by the NRC during that meeting.

1338 292 Revision 4 11/79

9 RESPONSE TO QUESTION 23 1338 293 i Revision 4 11/79

RESPONSE TO NRC QUESTION 23 [50.54(f)]

TAFLE OF CONTENTS Section RESPONSE TO OUESTION 23, PART (1) Page 1.0 NRC QUESTION 1

2.0 INTRODUCTION

2 2.1 General 2 2.2 Definitions 4 3.0 DISCUSSION AND EVALUATION 6 3.1 Category I, Item 1 6 3.2 Category I, Item 2 8 3.3 Category I, Item 3 10 3.4 Category I, Item 4 12 3.5 Category I, Item 5 14

, 3.6 Category II, Item 1 17 3.7 Category II, Item 2 19 3.8 Category III, Item 1 21 3.9 Category III, Item 2 23 3.10 Category III, Item 3 26 3.11 Category III, Item 4 29 3.12 Category IV, Item 1 32 3.13 Category IV, Item 2 34 RESPONSE TO QUESTION 23, PART (2) 1.0 NRC QUESTION 36 2.0 RESPONSE TO PART (2)a 37 3.0 RESPONSE TO PART (2)b 39 3.1 Review of the PSAR Commitment List 39 3.1 Rereview of the FSAR 41 3.2.1 Organization 41 3.2.2 Rercview Procedure 42 3.2.3 Processing Resulting Changes 45 3.3 Review of Engineering Department 46 Procedure 4.22 4.0 RESPONSE TO PART (2)c 47 5.0 RESPONSE TO PART (2)d 48 1338 294 ii Revision 4 11/79

Table of Contents (continued)

Section Page 3-1 FSAR - SOILS VERSUS OTHER AREAS 3-2 FSAR REVIEW FLOWCHART 3-3 FSAR REVIEW DOCUMENTATION FORM, MIDLAMD PROJECT, AND EXPLANATION OF FORM RESPONSE TO QUESTION 23, PART (3) 1.0 NRC QUESTION 49

2.0 INTRODUCTION

50 3.0 DIFFERENCES BETWEEN SOILS WOPK AND 51 OTHER WORK 4.0 QUALITY ASSURANCE PROGRAM IMPECVEMENTS 52 4.1 Listing and Chronology of Improve- 52 ments in General 4.2 Specifics of Selected Improvements 57 4.2.1 Review of Specifications 4.2.2 Bechtel QC and CPCo QA Review of 59 Quality Control Instructions 4.2.3 CPCo QA Review and Approval of 60 Bect.tel QC Administrative Procedures 4.2.4 Bechtel Resider t Engineers 61 4.2.5 Bechtel Monitcting Program 63 Improvements 4.2.6 Qualit.: Assurance Engineering 64 Stafting Levels 4.2.7 Bechtel Quality Assurance 65 Management Audits 4.2.8 Bechtel Quality Trend Program 66 Supplementary Guidelines 4.2.9 Bechtel Topical Report, BQ-TOP-1A 67 4.2.10 CPCo QA Inspection of Stored 70 Materials 4.2.11 CPCo Biennial QA Audits 71 4.2.12 CPCo QA Overview 72 1338 295 iii Rev* 7n 4 11/79

g Table of Contents (continued)

Sec'clon S.0 ACTION brtM FOLLtM-UP 75 RESPONSE TO QUESTION 23, PART (4) 1.0 NRC QUESTION 91 2.0 ASSESSMENT 92 iv nevision 4 11/79 1338 296

RESPONSE TO QUESTION 23, PART (1) 1338 297 Revision 4 11/79

RESPNSE 'IO CUESTICN 23, PART (1) [50.54(f)]

ErrTIN 1.0, NBC CUESTIm SUPPLH4ENIAL iwgutsr EUR ADDITIGAL SOIIS SETIIR4ENT INEDEMATICN

23. We have reviewed your response to questicn 1 of our March 21, 1979 letter, "10 CFR 50.54 Request Regarding Plant Fill," including related anendments or supplanents in your letters dated May 31, July 9, and August 10, 1979. We find that the infonnaticn provided is not sufficient for asupleticn of our review. Accordingly, provide the following naaitional infonnaticn:

(1) Your respnse to questicn la does not provide sufficient informaticn relative to the root causes of the 13 deficiencies. In crder to determine the acceptability of corrective actions for the 13 deficiencies considering the possibility that these deficiencies are of a generic nature that could affect other areas of the facility, a more canplete aiderstanding of the root cause of each deficiency is naca=cary.

Accordingly, provide a clearer descripticn of the root causes of each of the 13 deficiencies, inchiding a detailed discusrun of the conditicns that existal to allow these deficiencies and the chmges that have been made to preclude the recurrence of such deficiencies. In this regard, if ccntributing causes are mMaquate procedures, inspections, specifi-caticn call outs, design review, niidits, and/or technical direction, a clear and detailed descripticn is necessary as to what allowed these ecoditions to exist and why.

1338 298 Revision 4 23-1 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

SECTION 2.0, INTRODUCTION 2.1 General Subsections 3.1 through 3.13 of this Response to Question 23, Part (1) provide information supplementing our Responses to the NRC 10 CFR 50.54(f) Request Regarding Plant Fill for Midland Plant Units 1 and 2, Consumers Power Company Docket Numbers 50-329 and 50-330, transmitted from CPCo (S.H. Howell) to the NRR (H.R. Denton) on April 24, 1979 and our presentation to the Staff given on July 18, 1979, in Bethesda, Maryland, and documented via our transmittal from CPCo (S.H. Howell) to I&E (J.G. Keppler) on August 10, 1979. This introduction provides the rationale for determining the root cause of each of the 13 deficiencies identified through the investigations by the NRC, CPCo, and Bechtel; comments concerning the significance of the 13 deficiencies; and an explanation of the format used in addressing each deficiency.

In arriving at the root cause, the following factors were considered.

a. The purpose of the quality assurance program is to provide confidence that quality-related activities are performed in a controlled manner such that the product conforms to the FSAR and design require-ments.

b. The control measures applicable to the performance of the quality-related tasks are to provide sufficient direction and methodology to supplement the capability of the assigned personnel.

c. Personnel assigned the responsibility of performing the quality-related tasks are to have the required capability, knowledge, and skill (when supplemented by specifications, drawings, procedures, instructions, and the prescribed control measures) to satisfactorily perform their assigned responsibilities.

i338 299 23-2 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1)' [50.54(f)]

d. As the quality assurance program develops and is implemented, revisions or corrections will be necessary to:

1. Achieve the optimum balance or relationship between personnel capabilities and the prescribed control measures

2. Accommodate unique or unplanned events

3. Incorporate related experience and state-of-the-art improvements

~

The 13 deficiencies identified through investigations by Bechtel, CPCo, and the NRC are each addressed with the same intensive effort, irrespective of their contribution to the cause of the settlement. The relative contribution that each deficiency made to the settlement can be qualitatively derived from Sections 7.0 (Cause Investigation) and 8.0 (Quality Assurance and Quality Control Aspects) of the documentation transmitted on August 10, 1979.

Essentially, this documentation pointed out that the most probable causes of the settlement were as follows:

a. In some cases, lift thickness exceed the capability of the equipment being used. This was shown by the lift thickness /compactive effort tests conducted to qualify compaction equipment prior to resuming soils work. This indicates that the equipment was not adequately qualified.

b. Reliance on soil test results, or on the evaluatiori.

of the test results, provided a common mode failure mechanism because:

1. Construction relied on test results, or on the evaluation of the test results, from inprogress placements for qualification of equipment during the work.

2. Quality Control depended on the results, or on the evaluation of the results, of in-place soils tests for acceptance of the work. Associated with this principal reliance, surveillance type inspection procedures were applied to other soils work activity in the power block at least part of the time.

Therefore, deficiencies most closely associated with these two probable causes would bear the most significant contribution to settlement. ,

1338 300 23-3 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

2.2 Definitions The following information is provided to achieve a common understanding of the terms used and information included in Part (1) of this Response to Question 23.

Title:

This identifies the information as being in

' response to the applicable part of Question 23 under 10 CFR 50.54(f), transmitted from the NRR ( L. S. Rubenstein) to CPCo (S.H. Howell) on September 11, 1979.

Deficiency

Description:

This provides a restatement of the reported deficiency as originally stated in the CPCo response referenced below.

I&E Report Re ference: This identifies the pages of Inspection Report 78-20 which bear upon the reported deficiency.

CPCo Response

Reference:

This identifies the portion of the CPCo (S.H. Howell) letter to the NRR (H.R. Denton),

Serial Howe-121-79, Appendix I, dated April 24, 1979, which provided the original response.

Discussion: This provides background information relative to the reported deficiency as it relates to the implementation of the Quality Assurance Program.

Quality Assurance Program Criterion: This identifies, by title, the Quality Assurance Program criterion, listed in Appendix B to 10 CFR 50, which is applicable to the reported deficiency and the identified root cause.

Program Element: This identifies the program element, governed by the criterion, which is applicable to the reported deficiency and the identified root cause.

Q uality Assurance Program Policy: This identifies the Nuclear Quality Assurance Manual, Job 7220 section and numbcr which define the related Quality Assurance Program Policy. The Manual identifies requirements and assigns responsibility for developing and implementing control measures for performing related qutlity assurance activities.

Control Document: This identifies the current control document developed and implemented by the organizations assigned the responsibility for performing the quality assurance activities under their cognizance.

1338 s701 23-4 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50. 54 (f) ]

Instructions, Procedures, and Drawings: This identifies the instructions, procedures, and drawings which are prepared to supplement the control documents when it is necessary to provide more specific direction and methodology.

This information is provided only when this level of subtier document is pertinent to the deficiency being discussed.

Root Cause: This identifies the root cause, for the reported deficiency described under " Discussion."

Remedial Action (Soils) : This describes the actions taken or to be taken as a result of the reported deficiency which are needed to assure that prior and future soil placements conforms to the quality require-ments defined in the FSAR and design documents.

Corrective Action (Programmatic) : This describes the actions taken or to be taken to correct the root cause in the policies, procedures, and instructions in order to prevent recurrence of a similar type of deficiency.

Corrective Action (Generic) : This describes the actions taken or to be taken when root causes are potentially generic to work other than soils work. The actions are to assure that the same deficiencies do not exist or, if found to exist on completed work, are investigated to the extent necessary to assure that the work conforms to quality requirements defined in the FSAR and design documents and that the work quality is evidenced in the quality records.

In view of your comments during our presentation to the NRC Staff on September 5, 1979 in Bethesda, Maryland, during which we presented some of this information, please note the added emphasis that we have placed on communicating both the programmatic and generic corrective actions.

1338 302 23-5 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54 (f) ]

SECTION 3.0, DISCUSSION AND EVALUATION 3.1 Category I, Item 1 Deficiency

Description:

Inconsistency between specifi-cations and the Dames & Moore Report I&E Report

Reference:

Pages 9, 10, 16, and 17 CPCo Response

Reference:

Category I, Item 1 Discussion: A number of consultant reports were added to the PSAR as appendixes. The reports contained considerable and sometimes conflicting information.

The information contained in the consultant reports was subject to being misconstrued as commitments. The personnel who reviewed and provided input for the PSAR did not provide documented disposition of the Dames &

Moore Report recommendations to identify those recommen-dations which 4're PSAR commitments and those which were not.

Quality Assurance Program Criterion: Design control Program Element: Design input Quality Assurance Program Policy: Nuclear Quality Assurance Manual,Section II, Number 2, " Design Control Procedure" (April 1978) ; and Section II, Number 4,

" Design Criteria" (March 1974)

Control Document: Engineering Department Procedure 4.22, Revision 1, " Preparation and Control of SAR" (June 1974)

Root Cause: During the preparation and early revisions of the PSAR there were no procedural requirements or methods for documenting the disposition of consultant recommendations in the PSAR.

Remedial Action (Soils) : The Dames & Moore Report was reviewed and recomCendations were identified and dispo-sitioned. Dames & Moore recommendations which were included in the FSAR were unaffected by this review and no revisions to the FSAR were necessary as a result of this review. However, as a result of other activities, changes were made in design and construction documents which relate to soma subjects covered in the Dames &

Moore Report.

1338 303 23-6 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54 (f) ]

Corrective Action (Programmatic) : Engineering will revise Engineering Department Procedure 4.22 by December 1, 1979, to clarify that Engineering personnel preparing the FSAR will follow the requirements of Regulatory Guide 1.70, Revision 2, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants" (September 1975) . Specifically, Regulatory Guide 1.70 (Pages iv and v of the Introduction) requires that such consultant reports only be referenced with the applicable commitments and supporting information included in the text (third paragraph, Page v). Such a requirement would preclude repetition of this circumstance.

Corrective Action (Generic): Consultant reports other than Dames & Moore were considered in accordance with the guidelines provided in NRC Regulatory Guide 1.70, Revision 2. Consultant reports were not attached to the FSAR, but portions of consultant reports were extracted and incorporated into the FSAR text itself.

Those portions incorporated into the FSAR become commit-ments. Therefore, disposition of recommendations in consulting reports has been adequately eccounted for in the preparation of the FSAR.

Verification that those portions of consultant reports determined to be commitments and incorporated into the FSAR have been adequately reflected in project design documents is being accomplished via the FSAR rereview program described in the response to Question 23, Part (2).

The two Bechtel QA audit findings reported in our April 24, 1979, response (Paragraph D.1, Page I-8) have been closed out. The results of this audit are being utilized in the FSAR control system study committed to in Subsection 3.3 of this response to Part (1).

1338 304 23-7 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50. 54 (f) ]

3.2 Category I, Item 2 Deficiency

Description:

Lack of formal revisions of specifications to reflect clarification of specifi-cation requirements I&E Report

Reference:

Pages 9 through 14 CPCo Response

Reference:

Category I, Item 2 Discussion: Interoffice memorands, memoranda, telexes, TWXs, etc were often used to clarify the intent of the specifications. It is possible that in some situations the clarifications provided through these methods were interpreted by the user as modifying the specification without formally changing the wording of the specifi-cation.

Quality Assurance Program Criterion: Design control Program Element: Design change control Quality Assurance Program Policy: Nuclear Quality Assurance Manual,Section II, Number 5, " Design Process and Change Control" (June 1977)

Control Document: Engineering Department Project Instruction 4.49.1, Revision 3, " Specification Change Notice" (May 1979)

Root Cause: Prior to Revision 2 (May 4, 1979), Engineering Department Project Instruction 4.49.1 did not address the use of interoffice memoranda, memoranda, telexes, TWXs, etc which might be interprcced by the user as modifying the requirements of the specification.

Remedial Action (Soils): Applicable Specifications 7220-C-210 and 7220-C-211 were revised to incorporate interpreta-tions that affected specification requirements. The acceptability of the completed work was independently determined by a subsequent subsurface investigation program.

Corrective Actions (Programmatic):

1. 1338 305 On April 3, 1979, Midland Project Engineering Group Supervisors in all disciplines were reinstructed that the only procedurally correct methods of unplementing specification ch'anges are through the use of specification revisions or Specification Change Notices. This was followed by an interoffice memorandum from the Project Engineer to all Engineering Group Supervisors on April 12, 1979.

23-8 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

2. Engineering Department Project Instruction 4.49.1 was revised in Revision 2 to state, "Under no circumstances will interoffice memoranda, memoranda, telexes, TWXs, etc be used to change the requirements of a specification."

Corrective Activa (Generic) : A review of interoffice memoranda, memoranda, telexes, TWXs, and other corres-pondence relating to specifications for construction and selected procurements of Q-Listed items will be initiated.

The purpose of the review will be to identify any clarifications which might reasonably have been inter-preted as modifying a specification requirement and for which the specification itself was not formally changed.

An evaluation will be made to determine the effect on the technical acceptability, safety implications of the potential specification modification, and any work that has been or may be affected. If it is determined that the interpretation may have affected any completed work or future work, a formal change will be issued and remedial action necessary for product quality will be taken in accordance with approved procedures.

The foregoing procedure will be followed for all specifi-cations applying to construction of Q-Listed items.

For specifications concerning the procurement of Q-Listed items, the foregoing procedure will be implemented on a random sampling basis. The sample size has been established and the specification selection has been made.

Review and acceptance criteria for the specifications will be defined by November 30, 1979.

The review of construction and selected procurement specifications is scheduled to be completed by October 1980.

If the acceptance criteria are not met, the review will be expanded to include other specifications for Q-Listed items. At that time, a revised completion date will be established.

1338 306 23-9 Revision 4 11/79 1

/

, RESPONSE TO QUESTION 23, PART (1) [50.54(f)}

3.3 Category I, Item 3 Deficiency

Description:

Inconsistency of information within the FSAR relating to diesel generator building fill material and settlement I&E Report

Reference:

Pages 6 through 8 CPCo Response

Reference:

Category I, Item 3 Discussion: When the FSAR was prepared and reviewed, the major backfill operations were complete. There were no known inconsistencies or recent design document changes related to FSAR Subsections 2.5.4 and 3.8.5; therefore, these subsections were essentially inactive and were not subject to any further review. The incon-sistencies within the FSAR and between the 'AR and design documents were not detected. The inconsistency between Subsections 2.5.4 and 3.8.5 with respect to the settlement values resulted because the two subsections were prepared by separate organizations (Geotechnical Services and Civil Engineering), neither of which were aware of the multiple display of similar information in the opposite subsection. The inconsistency between FSAR Subsection 2.5.4 and the project design drawing (Drawing 7220-C-45) with respect to the fill material resulted because at the time of FSAR preparation the Geotechnical Services personnel preparing the FSAR were unaware, in this case, of the status of the design drawing prepared by Civil Engineering.

Quality Assurance Program Criterion: Design control Program Element: Design input Quality Assurance Program Policy: Nuclear Quality Assurance Manual,Section II, Number 4, " Design Criteria" (March 1974)

Control Documents: Engineering Department Procedure 4.22, Revision 1, " Preparation and Control of Safety Analysis Roports" (June 1974) ; Engineering Department Project Instruction 4.25.1, Revision 6, " Design Inter-face Contro!. (Internal) " (September 1979) ; and Engineering Department Project Instruction 4.1.1, Revision 0, "Prepara'. ion of the Design Requirements Verification Checklist" (July 1974) , 1338 307 Root Cause: The control document did not provide sufficient procedural control for preparation and review of the FSAR.

23-10 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

Remedial Action (Soils): The inconsistencies between FSAR Subsections 2.5.4 and 3.8.5 have been corrected via FSAR Revision 18 ( February 28, 1979). The same revision also corrected the inconsistency between FSAR Subsection 2.5.4 and Design Drawing C-45.

Corrective Actions (Programmatic):

1. A study was completed which examined current procedures and practices for the preparation and control of the FSAR in view of these experiences.

Procedural changes will be initiated by the revision of or addition to the Engineering Department Procedures. This action is scheduled to be completed by January 31, 1980.

2. Tb preclude any future inconsistencies between the FSAR and specifications, Engineering Department Project Instruction 4.1.1 will be revised to state that all specification changes, rather than just

" major changes," will be reviewed for consistency with the FSAR. This action is scheduled to be completed by December 1, 1979.

Corrective Action (Generic): FSAR sections are being rereviewea as ciscussea in the Response to Question 23, Part (2).

1338 308 23-11 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54 (f) }

3.4 Category I, Item 4 Deficiency

Description:

Inconsistency between basis for settlement calculations for diesel generator building and design basis I&E Report

Reference:

Pages 20 and 21 CPCo Response

Reference:

Category I, Item 4 Discussion: The initial settlement calculations were performed by Geotechnical Services based on preliminary information provided by Project Engincering. The final diesel generator building foundation design configura-tion (as described in the FSAR) was different from the preliminary inf.ormation. The originator of the final design configuration did not interface with Geotechnical Services to verify impact on final settlement calculations.

It was subsequently determined that the change in foundation design would have an insignificant effect on the calculation. However, no changes or notations to the original calculations were made, thus resulting in an inconsistency between the basis for settlement calculations and design basis.

Quality Assurance Program Criterion: Design control Program Element: Design coordination Quality Assurance Program Policy: Nuclear Qualiuy Assurance Manual,Section II, Number 2, " Design Control Procedures" (April 1978);Section II, Number 9, ' Design Interface" (March 1974); and Section II, Number 10, "Speciality Group Design Control" (June 197/)

Control Documents,: Engineering Departmer.c Procedure 4.22, Revision 1, " Preparation and Contr0% of Safety Analysis Reports" (June 1974) ; Engineering Department Project Instruction 4.25.1, Revision 6, " Design Inter-face Control (Internal)" (September 1979) ; Procedure FP-6437-1, " Design Calculations" (January 1979); and Engineering Department Procedure 4.37, Revision 2,

" Design Calculations" (May 1976).

Root Causes:

1. Diesel generator building foundation design changes initiated by Project Engineering were not coordi-nated with Geotechnical Services, as required by the control documents.

1338 309 23-12 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) (50. 54 (f) ]

2. Geotechnical Procedure FP-6437 did not require that the calculations show evidence of any evalua-tions for changes to input data, even when considered to be of no significance to the results.

Remedial Action (Soils) : Settlament calculations will be revised after the completion of the diesel generator building surcharge operation. At that time, the design drawing will be coordinated with Geotechnical Services and any changes or notations needed to reflect design changes will be made.

Corrective Actions (Programmatic) :

1. An interoffice memorandum dated April 12, 1979, was issued by Geotechnical Services to alert personnel of the need to revise or annotate calculations to reflect current design status.

2. In view of the above, Geotechnical Services will revise Procedure FP-6437 by Dacember 31, 1979, to require that calculations be annotated to reflect current design status.

3. Engineering Department Procedure 4.37 will also be revised by December 31, 1979, to require that calculations be annotated to reflect current design status.

Corrective Action (Generic): This is considered an isolated case and not generic based on Quality Assurcnce audits of Geotechnical Services conducted in February and August 1979. The results of these audits indicate that this area is effectively controlled. Quality Engineering surveys and Quality Assurance monitorings will verify future coordination of design documents by Geotechnical Services and Project Engineering.

1338 310 23-13 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50. 54 (f) ]

3.5 Category I, Item 5 Deficiency

Description:

Inadequate design coordination in the design of the duct bank I&E Report

Reference:

Pages 23 and 24 CPCo Response

Reference:

Category I, Item 5 Discussion: Four vertical duct banks were designed and constructed without sufficient clearance to allow for relative vertical movement between the duct banks and the building footings. Civil Drawings 7220-C-1001 and 7220-C-1002 (which show the footing requirements) were coordinated with Electrical Drawing 7220-E-502 (which shows the duct bank stub-up location and dimensions),

as required by Engineering Department Procedure 4.46 and Engineering Department Project Instruction 4.25.1.

Drawing 7220-E-502 refers to Drawing 7220-E-543, which shows a minimum size for the underground duct bank some distance away from the stub-up. Neither electrical nor civil drawings show how or where to accomplish the transition from the stub-up size to the underground duct size, nor do they show firm definition of duct size. The transition and final size of each duct were established by the Field Engineers during construction.

The civil design was based on the stub-up dimensions shown in Drawing 7220-E-502, and did not acknowledge that the duct bank size under the slab and/or footing was to be determined by Field Engineering.

Quality Assurance Program Criterion: Instructions, procecures, and drawings Program Element: Preparation of drawings Quality Assurance Program Policy: Nuclear Quality Assurance Manual,Section II, Number 2, " Design Control Procedures" (April 1978) ; and Section II, Number 9,

" Design Interface" (March 1974)

Control Documents: Engineering Department Procedure 4.46, Revision 3, " Project Drawings" (May 1976) and Engineering Department Project Instruction 4.25.1, Revision 6, " Design Interface Control (Internal)"

(September 1979)

Instructions, Procedures, and Drawings: Electrical Standard Detail Drawings and Civil Standard Detail Drawings .

23-14 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

Root Cause: Failure of the drawings to provide Construction with the information necessary to prevent interference.

Remedial Actions (Soils) :

1. Provisions were made to allow independent vertical movement between th: diesel generator building and the duct banks.

2. Bechtel Project Engineering has reviewed the design drawings for cases where ducts interface with structures to determine the possibility of the duct being enlarged over the design requirements and the effect this enlargement may have upon the structures' behavior. Forty-four individual or groups of similar buried electrical duct banks were reviewed. The terminations of each case were reviewed, resulting in the identification of 23 questionable vertical interfaces. Based on geometry, depth of vertical leg, and whether sufficient details were available on the design drawing, 11 cases were identified for detailed investigation.

Additional information was obtained from the jobsite to define how the interface was constructed and whether any unusual behavior existed.

The review concluded that several nonsafety-rele.ted transformer pads experiencing differential sett.lement may be exaggerated by the duct bank intarface. However, in no case except the diesel generator building has settlement been completely restricted or do details, geometry, or subgrade conditions indicate that settlement would be completely restricted.

Corrective Actions (Programmatic):

1. Civil / Structural Design Criteria 7220-C-501 will be modified to contain the requirement that a duct bank penetration shall be designed to eliminate the possibility of the nonspecific size duct interacting with the structures. This action is scheduled to be completed by December 31, 1979.

2. The civil standard detail drawings will be revised to include a detail showing horizontal and vertical clearance requirements for duct bank penetrations.

The detail will address any mud mat restrictions.

This action is scheduled to be completed by December 31, 1979.

23-15 Revision 4 11/79 1338 312

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

Corrective Action (Generic) : This condition is not considered generic, but rather an anomaly unique to electrical duct banks. The uniqueness arises from the practice of not pinpointing the size or location of the duct bank on the drawings and leaving it to be established during construction.

1338 3i3 23-16 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

3.6 Category II, Item 1 Deficiency

Description:

Insufficient compactive effort used in backfill operation I&E Report

Reference:

Not applicable CPCo Response

Reference:

Category II, Item 1 Discussion: Specifications 7220-C-210 and 7220-C-211 specified requirements for selection and approval of compaction equipment on the basis of demonstration.

The equipment was used on the basis of achieving either satisfactory in-place test results or satisfactory evaluation of the test results. There were no field control documents or procedures to define requirements for the qualification of soils compaction equipment. There were no control documents to govern the requirements for control measures pertaining to soils placement and compaction. Conattuction and Quality Control relied on in-place soil test results, or on the evaluation of these results , to determine the acceptability of placement and compaction activities. These soil test results or their evaluations were in error in numerous cases.

Quality Assurance Procram Criterion: Instructions, procedures, and drawings Program Element: Preparation of instructions, Jrocedures, and drawings Ouality Assurance Program Policy: Nuclear Quality Assurance Manual,Section IV, Number 1, " Construction Site Quality Program" (April 1978); and Section V, Number 13, " Procedure Control" (June 1977)

Control Document: Field Procedure FPG-1.000, " Initiating and Processing Field Procedures, Instructions, and Spertifications" (January 1979)

Instructions, Procedures, and Drawincs: Field Instruction FIC 1.100, Revision 0, "Q-Listed Soils Placement Job Responsibilities Macrix" (July 1979)

Root Causes:

1, Reliance was placed on in-place test results, or on the evaluation of the test results, for evaluating compaction equipment. Satisfactory soil test results, or evaluations of test results, implied that adequate compactive effort was obtained and equipment capability and fill placement methods were not questioned.

(Incorrect soils test results are addressed in Subsection 3.10.) g 3j4 Revision 4 23-17 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

2. The Quality Assurance Program requirement to establish responsibility for measures to control the placement and compaction of soils and the qualification of construction equipment was not adequately implemented.

Remedial Actions (Soils):

1. Compaction equipment currently in use has been qualified and Construction has been notified of the parameters governing the use of the equipment.

2. Project Quality Control Instruction (PQCI) C-1.02 was revised to include verification of the use of qualified equipment and compliance with qualified procedures.

Corrective Actions (Programmatic):

1. Field Instruction FIC 1.100, "Q-Listed Soils Placement Job Responsibilities Matrix," has been prepared and establishes responsibilities for perfo; ming rioils placement and compaction.

2. Field Instruction 1.100 will be supplemented by establishing requirements for demonstrating equipment capability, including responsibility for equipment approval, and providing records identifying this capability. This action will be completed by November 15, 1979.

3. Quality Assurance will issue a Nuclear Quality Assurance Manual amendment to clarify the requirement that procedures include measures for qualifying equipment under specified conditions. This action is scheduled to be completed by December 14, 1979.

4. Engineering and Construction will revise or prepare procedures governing the placement and compaction of soils and implementing the requirements of the Nuclear Quality Assurance Manual as stated in Corrective Action Item 1 (above). This is scheduled to be completed by January 31, 1980.

Corrective Action (Generic): Ccnstruction specifications, instructions, and procedures were reviewed to identify any other equipment requiring qualification which had not yet been qualified. No such eqt ipment was identified.

1338 315 Revision 4 23-18 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)J 3.7 Category II, Item 2 Deficiency

Description:

Insufficient technical direction in the field I&E Report

Reference:

Pages 24 through 26 CPCo Response

Reference:

Category II, Item 2 Discussion: The Dames & Moore Report and Civil / Structural Design criteria 7220-C-501 state, in part, " Filling operations shall be performed under the technical supervision of a qualified Soils Engineer...." The technical direction and supervision were provided by Field Engineers and Supervisors who were assigned the responsibility for soils placement. The technical direction and supervision provided were not properly deployed to overcome the lack of documented instructions and procedural controls. Rel4.ance on test results, or on the evaluations of test results, did not identify the need for additional direction and supervision.

Field Procedure FPG 3.000, " Job Responsibilities of Field Engineers, Superintendents, and Field Subcontract Engineers," was not intended to provide instructions for the performance of specific tasks and functions.

Quality Assurance Program Criterion: Instructions, procedures, and drawings Program Element: Preparation of instructions, procedures, and drawings Quality Assurance Program Policy: Nuclear Quality Assurance Manual,Section IV, Number 1, " Construction Site Quality Program" (April 1978); and Section V, Number 13, " Procedure Control" (June 1977)

Control Document: Field Procedure FPG 3.000, " Job Responsibilities of Field Engineers, Superintendents, and Field Subcontract Engineers" (October 1977)

Instructions, Procedures, and Drat.ings: None Root Cause: Reliance on test results, or on the evaluations of test results, and surveillance by Quality Control instead of providing sufficient technical direction through documented instructions and procedural controls.

(Incorrect Soil Test Results are addressed in Subsection 3.10).

1338 316 23-19 Revision 4 11/79

RESPONSE TO CUESTION 23, PART (1) [30.54(f)]

Ramedial Action (Soils): One fulltime and one parttime onsite Geotechnical Soils Engineer have been assigned.

These engineers provide technical direction and monitoring of the process.

Corrective Action ( Prot rammatic): Field Instruction FIC 1.100, "Q-Listed Su'ls Placement Job Responsibilities Matrix," has been prepared and establishes responsibilities for performing soils placement and compaction.

Corrective Action (Generic): Design documents, instructions, and procedures tor those activities requiring inprocess controls will be reviewed to assess the adequacy of existing procedural controls and technical direction.

Engineering review is scheduled for completion by December 31, 1979, and Field Engineering and Quality Control review is scheduled for completion by January 31, 1980. Any revisions required will be completed by March 14, 1980.

1338 317 23-20 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

3.8 Category III, Item 1 Deficiency

Description:

Inadequate Quality Control inspection of placement of fill I&E Report

Reference:

Pages 25 through 29 CPCo Response Refererce: Category III, Item 1 Discussion: The Nuclear Quality Assurance Manual requires that Construction Quality Control Procedures

" define the method for indirect control by monitoring of processing methods, equipment, and personnel, when inspection of processed items is impossible or disadvantageous."

Control Document SF/ PSP G-6.1, " Quality Control Inspection Plans," does not adequately include or reference chis requirement in the instructions for preparation of Quality Control Instructions. Quality Control Instruction PQCI C-1.02 did not adequately satisfy this requirement.

The inspection of soils was accomplished by " surveillance,"

and did not require verification of the controls specified in Specifications 7220-C-210 and 7220-C-211. Soil test results, or the evaluations of soil test results, were used as the basis for quality verification.

Quality Assurance Program Criterion: Inspection instructions, procedures, and drawings Program Element: Establishment of an inspection program, documented instructions and procedures for accomplishing the inspection activity, and the preparation of instructions and procedures Quality Assurance Program Policy: Nuclear Quality Assurance Manual,Section IV, Number 5, " Field Inspection and Test" (June 1977) ccatrol Document: SF/ PSP G-6.1, Revision 4, " Quality Control Inspection Plans" (January 1978)

Instructions, Procedures, and Drawings: PQCI C-1.02, Revision 4, " Compacted Backfill" (July 1979)

Root Causes:

1. Control Document SP/ PSP G-6.1 does not include sufficient specificity in its requirements for 'the preparation of inspection instructions.

1338 318 Revision 4 23-21 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

2. Too much reliance was placed on the Quality Control Inspector's ability, without sufficiently specific inspection instructions.

3. Reliance was placed on soil test results, or on the evaluation of soil test results, which were in error in numerous cases. (Incorrect Soil Test Results are addressed in Subsection 3.10.)

Remedial Actions (Soils):

1. PQCI C-1.02 has been revised to incorporate the specific characteristics to be verified by Quality Control.

2. An in-depth soils investigation program, which was implemented as described in our prior transmittals, provides verification of the acceptability of the soils or identifies any nonconformances requiring further remedial action.

Corrective Action (Programmatic): Control Document SF/ PSP G-6.1 will be revised to provide requirements for inspection planning specificity and for the utilization of scientific sampling rather than percentage sampling.

This action is scheduled to be completed by January 24, 1980.

Corrective Actions (Generic)

1. OCIs in use will be reviewed to ascertain that provisions have been included consistent with the revised control document. This action and any required revisions are scheduled to be completed by March 8, 1980.

2. The impact of Corrective Action Item 1 (above) on completed work will be evaluated, and appropriate actions will be taken as necessary. This action is scheduled to be completed by May 23, 1980.

1338 319 23-22 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50. 54 (f) ]

3.9 Category II., Item 2 Deficiency

Description:

Inadequate soil moisture testing I&E Report

Reference:

Pages 14 through 16 CPCo Response

Reference:

Category III, Item 2 Discussion: Prior to 1978, moisture content was controlled by tests performed after compaction. Few or r.o tests were performed on the fill during compaction, as required by Specification 7220-C-210, Section 12.6. "During compaction" was interpreted by personnel in the field as the entire process of placing, compacting, and testing. The moisture content was measured during the density test, which was performed immediately after compaction.

Reconditioning was done after testing.

Quality Assurance Program Criterion: Inspection instructions, procedures, and drawings Program Element: Establishment of an inspection program, the documented instructions and procedures for accomplishing the inspection activity, and the preparation of instructions and procedures Quality Assurance Program Policy: Nuclear Quality Assurance Manual,Section IV, Number 5, " Field Inspection and Test" (June 1977)

Control Document: SF/ PSP G-6.1, Revision 4, " Quality Control Inspection Plans" (January 1978)

Instructions, Procedures, and Drawings: PQCI, C-1.02, Revision 4, " Compacted Backfill" (July 1979)

Root Causes:

1. Concrol Document, SF/ PSP G-6.1 does not require sufficient specificity for establishing an inspection program and for the preparation of. inspection instructions.

2. Reliance was placed on the informal incorrect

, interpretations of the specification relative to moisture testing. This is discussed in Subsection 3.2.

3. Reliance was placed on Quality Control surveillances of moisture testing.

1338 320 23-23 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

4. Reliance was placed on the incorrect results of the density tests, or on the incorrect evaluation of the results, to the exclusion of the moisture test results. (Incorrect Soil Test Results are addressed in Subsection 3.10).

Remedial Actions (Soils):

1. The specifications were revised to provide more definitive requirements for soil moisture testing.

2. POCI C-1.02 was revised to provide specific inspection requirements for verifying soil moisture content, rather an surveillance.

3. Field instruction FIC 1.000, "Q-Listed Soils Placement Job Responsibility Matrix," has been prepared, and establishes responsibilities for performing soils placement and compaction.

Corrective Actions (Programmatic):,

1. Control Document SF/ PSP G-6.1 will be revised to provide requirements for inspection planning specificity and for the utilization of scientific sampling rather than percentage sampling. This action is scheduled to be completed by January 24, 1980.

2. Engineering Department Project Instruction 4.49.1, Revision 3 now states, "Under no circumstances will interoffice memoranda, memoranda, telexes, TWXs, etc be used to change the requirements of a specification." This will provide controlled and uniform interpretation of specification requirements.

3. On April 3, 1979, Midland Project Engineering Group Supervisors in all disciplines were reinstructed that the only procedurally correct methods of implementing specification changes are through the use of specification revisions or Specification Change Notices. This was followed by an interoffice memorandum from the Project Engineer to all Engineer-ing Group Supervisors on April 12, 1979.

1338 521 23-24 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

Corrective Actions (Generic):

1. OCIs in use will be reviewed to ascertain that provisions have been included consistent with the revised control document. This action and any required revisions are scheduled to be completed by March 8, 1980.

2. The impact of Corrective Action Item 1 (above) on completed work will be evaluated, and appropriate actions will be taken as necessary. This action is scheduled to be completed by May 23, 1980.

3. A review of interoffice memoranda, memoranda, telexes, TWXs, and other correspondence relating to specifications for construction and selected procurements of Q-Listed items will be initiated.

The purpose of the review will be to identify any clarifications which might reasonably have been interpreted as modifying a specification requirement and for which the specification itself was not formally changed. An evaluation will be made to determine the effect on the technical acceptability, safety implications of the potential specification modification, and any work that has been cr may be affected. If it is determined that the inter-pretation may have affected any completed or future work, a formal change will be issued and remedial action necessary for product quality will be taken in accordance with approved procedures.

Tne foregoing procedure will be followed for all specifications applying to construction for Q-Listed items.

For specifications concerning the procurement of Q-Listed items, the foregoinc procedure will Le implemented on a random samp'.ing basis. The sample size has been establisted and the specification selection has been made. Review and acceptance criteria for the specifications will be defined by November 30, 1979.

The review of construction and selected procurement specifications is scheduled to be completed by October 1980.

If the acceptance criteria are not met, the review will be expanded to include other specifications for Q-Listed items. At that time, a revised completion date will be established.

1338 327 Revision 4 23-25 11/79

RESPONSE TO QUESTION 23, PART (1) ( 50. 54 (f) J 3.10 Category III, Item 3 Deficiency

Description:

Incorrect soil test results I&E Report

Reference:

Not applicable CPCo Response

Reference:

Category III, I tem 3 Discussion: A review of soils test reports indicates that some test reports contain errors and inconsistencies in data. Surveillance and test report reviews did not identify these errors and inconsistencies. The Quality Control surveillance and re"iew included steps to verify that the test results were reported as either percent compaction or relative density, as appropriate; that specification requirements for compaction and mois ture content were within specified limits; and that the report form was properly completed and contained the required data and authorized signature. This was in accordance with the requirements of Quality Control Ins truc tion 7 220-SC-1. 0 5, " Material Tes ting Laboratories ,"

which includes instructions for monitoring the performance c f verification testing performed by the tes ting laboratory.

Quality Assurance Program Criterion: Control of purchased material, equipment, and services (subcontractors)

Program Element: Surveillance of the subcontractor's performance Quality A ssura:ee Program Policy: Nuclear Quality Assurance Manual, SeJtion IV, Number 11, " Field Subcon-tractor Control" (June 1977) ; and Section IV, Number 5,

" Field Inspection and Tes t" (June 1977)

Control Document: SF/ PSP G-9.1, Revision 1, " Control of Subcontractor Work" (July 1977)

Ins tructions , Procedures , and Drawings: Quality Control Ins truc tions 7 2 20-SC-1. 05, " Material Tes ting Services" (October 1977)

Root Cause: Technical procedures available to control the tes ting were iradequate, and the technical direction of the tes ting operations did not avoid or detect the incorrect soil tes t results.

1338 323 23-26 Revision !

11/79

RESPONSE TO QUESTION 23, PART (1) f 50. 54 (f) J Remedial Actions (Soils) :

1. Geotechnical Services has completed an inves tigation which includes an in-depth review of testing performed by U.S. Tes ting and the reported tes t resul ts . The purpose of this inves tigation was to identify the type of tes ting errors which were made in order to facilitate analysis by U.S.

Tes ting and to accomplish Programmatic Corrective Action (below) and Remedial Action Item 2 (below).

2. Based on Item 1 above, the requirements for the control of tes ting were adjusted, requiring the Testing Subcontractor to check all field density tes ts for cohesive material against a zero-air-voids curve. A specification change has been issued. Selection of proctor curves will no longer be a problem because each field density test will be accompanied by a separate laboratory s tandard which will provide a direct comparison.

This was directed by a letter to U.S. Tes ti ng a nd reflected in Specification Change No tice C-208-9004, dated April 13, 1979.

3. PQCI-SC-1.05 was revised to add more s tringent requirements for in-process inspection of U.S.

Tes ting's soil tes ting activities.

4. An in-depth soils investigation program which was implemented as described in our prior transmittals, provides verification of the acceptability of the soils or identifies any nonconformances requiring further remedial action. This action is identical to Remedial Action Item 2 in Subsection 3.8.

Corrective Action (Programmatic) : Guidelines for surveillance of testing operations will be developed and included in Field Instructions for the onsite Soils Engineer. Engineering / Geotechnical Services will develop the guidelines by November 30, 1979, and Field Engineering will prepare the instructions by December 31, 1979.

Corrective Actions (Generic) :

1. U.S. Tes ting will be required to demons trate to the cognizant Engineering Representative that tes ting procedures , equipment, and personnel used 1338 324 23-27 Revision 4 11/79

9 RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

for quality verification testing (for other than NDE and soils) were, and are, capable of providing accurate test results in accordance with the requirements of applicable design documents. This action is scheduled to be completed by May 1, 1980.

2. A sampling of U.S. Testing's test reports (for other than NDE and soils) will be teviewed by the cognizant Engineering Representative to ascertain that results evidence conformance to testing requirements and design document limits. This action is scheduled to be completed by May 1, 1980.

1338 325 9

Revision 4 23-28 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

3.11 Category III, Item 4 Deficiency

Description:

Inadequate subcontractor test procedures I&E Report

Reference:

Not applicable CPCo Response

Reference:

Category III, Item 4 Discussion: The procedures used for soils testing did not cover the following activities:

1. Developing and updating the family of proctor curves;

2. Visually selecting the proper proctor curves;

3. Developing additional proctor curves for changing materials occurring between normal frequency curves; and

4. Using alternativr methods of determining the proper laboratory maximum density where visual comparison is not adequate.

Bechtel Specification 7220-G-22, Revision 1 (June 22, 1973) is an attachme~t n to Specification 7220-C-208 and specifies the requirements for instructions, procedures, and drawings. These technical procedures were not prepared.

Quality Assurance Program Criterion: Control of purchased material, equipment, and services (subcontractor)

Program Element: Control of supplier-generated (subcontractor-generated) documents Quality Assurance Program Policy: Nuclear Quality Assurance Manual,Section III, Number 9, " Supplier Document Review" (June 1977); and Section IV, Number 11, " Field Subcontractor Control" (June 1977)

Control Document: SF/ PSP G-9.1, Revision 1, " Control of Subcontractor Work" (July 1977)

Instructions, Procedures, and Drawings: Quality Control Instructions 7220/SC-1.05, " Material Testing Services" (October 1977) l@ }}f Revision 4 23-29 11/79

RESPONSE TO QUESTION 23, PART (1) (50.54(f)] Root Cause: Adequate technical procedures for control of the testing were not prepared. Remedial Actions (Soils):

1. Geotechnical Services has completed an investigation which includes an in-depth review of testing performed by U.S. Testing and the reported test results. The purpose of this investigation was to identify the type of testing errors which were made in order to facilitate analysis by U.S.

Testing and accomplish Remedial Action Item 2.

2. Based on Item 1 above, the requirements for the ,

control of testing were adjusted requiring the Testing Subcontractor to check all field density tests for cohesive material against a zero-air-voids curve. A specification change has been issued. Selection of proctor curves will no longer be a problem because cach field density test will be accompanied by a separate laboratory standard which will provide a direct comparison. This was directed by a letter to U.S. Testing and reflected in Specification Change Notice C-208-9004, dated April 13, 1979.

3. One full-time and one part-time onsite Geotechnical Soils Engineer have been assigned. These engineers will review U.S. Testing's procedures and monitor their implementation.

Corrective Action (Programmatic): Field Instruction FIC 1.100, "Q-Listed Soils Placement Job Responsibilities Matrix," has been prepared and establishes responsibilities for performing surveillance of testing operations. Corrective Actions (Generic):

1. Design documents, instructions, and procedures for those activities requiring inprocess controls will be reviewed to assess the adequacy of existing procedural controls and technical direction.

Engineering review is scheduled for completion by December 31, 1979, and Field Engineering and Quality Control review is scheduled for completion by January 31, 1980. Any revisions required will be completed by March 14, 1980. 1338 327 23-30 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)]

2. U.S. Testing will be required to demonstrate to the cognizant Engineering Representative that testing procedures, equipment, and personnel used for quality verification testing (for other than NDE and soils) were, and are, capable of providing accurate test results in accordance with the requirements of applicable design documents. This action is scheduled to be completed by May 1, 1980.

3. A sampling of U.S. Testing's test reports (for other than NDE and soils) will be reviewed by the cognizant Engineering Representative to ascertain that results evidence conformance to testing requirements and design document limits. This action is scheduled to be completed by May 1, 1980.

W 1338 328 23-31 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50. 54 (f) ] 3.12 Category IV, Item 1 Deficiency

Description:

Inadequ. ate corrective action for repetitive nonconforming conditions I&E Report

Reference:

Pages 17 through 20 CPCo Response

Reference:

Category IV, Item 1 Discussion: There were nonconformances reported whi.n are considered to be repetitive. These include, but are not limited to: CPCo Nonconformance Reports QF-29, QF-52, QF-68, QF-120, QF-130, QF-147, QF-172, QF-174, QF-199, and QF-203; CPCo Audit Findings F-77-21 and F-77-32; and Bechtel Nonconformance Reports 421, 686, d98, and 1005. The Nuclear Quality Assurance Manual, Section V, Number 10, states in Subparagraph 2.5.b, "Nonconformances which, due to their repetition or impact (potential or actual) upon quality, should be brought to management's attention for special action." Quality Assurance Department Procedure C-101, Revision 1,

    " Project Quality Assurance Trend Analysis" (July 1977) states in Paragraph 1.0, "This procedure provides a mechanism for identifying quality trends and initiating corrective action to prevent recurrence...." The reviews made in accordance with this procedure did not identify the significance of the repetitive nature of the nonconformances and the need for special action beyond that for the individual reports.

Cor. trol Document SF/ PSP G-3.2 dafines the requirements for review of Management Corrective Action Requests (MCARs). Quality Assurance Program Criterion: Corrective action Program Element: Actions pertaining to significant conditions adverse to quality Quality Assurance Program Policy: Nuclear Quality Assurance Manual, Section V, Number 10, " Management Corrective Action" (March 1979) Control Documents: SF/ PSP G-3.2, Revision 5, " Control of Nonconforming Items" (September 1979) and QADP C-101, Revision 1, " Project Quality Assurance Trend Analysis" (July 1977) 1338 329 23-32 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)] Root Causes:

1. The conditions under which nonconformances are considered to be repetitive are not adequately defined in the control documents.

2. The trending activity did not provide timely responses to repetitive product nonconforming conditions.

Remedial Action (Soils): Not applicable Corrective Action (Programmatic): Control documents are in tne process of being revised to provide an improved definition of implementing requirements for identifying repetitive non-conforming conditions. This action is scheduled to be completed by January 24, 1980. Corrective Action (Generic): Consistent with the intent of the programmatic change above, Quality Assurance will review nonconformance reports which are open, cr will become open between chis time and January 23, 1980. This review will be to identify any repetitive nonconforming conditions pertaining to pr03uct type or activity, or pertaining to nonconformance cause. This action is scheduled to be completed by January 24, 1980. 1338 330 Revision 4 23-33 11/79

RESPONSE TO QUESTION 23, PART (1) [50.54(f)] 3.13 Category IV, Item 2 Deficiency

Description:

Bechtel Quality Assurance auditing and monitoring did not identify the problems relating to the settlement. This lack of identification of problems by the auditing and monitoring contributed to a conclusion that soils operations were adequately controlled. I&E Report

Reference:

Pages 17 through 20 CPCo Response

Reference:

Category IV, Item 2 Discussion: Quality Assurance auditing and monitoring is aimed at evaluating the adequacy of policies and procedures and evaluating the degree of compliance with the policies and procedures. It is not a quality verification activity, although it may identify deficiencies in the performance of quality-related activities that could result in unsatisfactory product quality. In the case of soils operations, Quality Assurance auditing and monitoring found that quality-related activities were being performed as planned, quality verification activities (primarily soil testing) were being performed, and the soil test results, or their evaluation, provided evidence of compliance with the established standards. The auditing and monitoring did not identify the policy and procedure inadequacies. Quality Assurance Program Criterion: Auditing Program Element: Auditing Ouality Assurance Program Policy: Nuclear Quality Assurance Manual, Section VI, Number 1, " Quality Audit System" (March 1979) Control Documents: Quality Assurance Department Procedure, Section C, Number 1, " Project Quality Monitoring" (September 1977); and Section C, Number 5, " Project Quality Audits" (September 1977) Root Cause: Quality Assurance audit and monitoring was oriented more toward evaluating the degree of compliance with established procedures rather than toward the assessment of policy and proccdural adequacy or toward the assessment of product quality, j}}8 33} Revision 4 23-34 11779

RESPONSE TO QUESTION 23, PART (1) [50.54(f)] Corrective Action (Generic) : The Quality Assurance audit and monitoring program will be revised to emphasize and increase attention to the need for evaluating policy and procedural adequacy and asressment of product quali ty. A specialized audit training program will be developed and implemented to ensure guidance for this revised approach. These actions will be accomplished by December 31, 1979. 1338 532 23-35 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (2) Revision 4 11/79 1338 333

RESPWSE 'IO NRC QUESTION 23, PART (2) (50.54 (f) ] SECTIN 1.0, NRC OUESTIN SUPPIDH7IAL wwdr FOR ADDITIONAL SOIIS SEITIDefr INFORMATICN

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 aire _rd.ients or supplanents in your letters dated May 31, July 9, and Atsust 10, 1979. We find that the information provided is not sufficient for empletion of our review. Accordingly, provide the following additional information:

(2) Regarding your response to cuestion lb:

a. 'Ihe first seven paragraphs do not provide sufficient information to assure that contradictions do not continue to exist in the PSAR, FSAR, design docunents, implenenting procedures, and as-built condir tions since the controls described in these seven paragraphs werb in effect prior to the I&E findings reported in J. Keppler's letter of March 15, 1979. Modify your response to clearly describe the control revisions you have instituted to preclude design contradictions.

b. Itms 1, 2, and 3 of the eighth paragraph describe the review and update of the PSAR ccmnitznent list, the review of the inactive _ sections of the FSAR, and the review of procedure EDP 4.22, " Preparation and Contr 1 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. It s 2 of the eighth paragraph states that a review of the r m aining 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 and prior to any corrective actions resulting therefrm..

d. Desence the extent of the audit to which you have ccumitted -in iten 4 of the eighth paragraph.

[338 334 23-36 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (2) [50. 54 (f) ] SECTION 2.0, RESPONSE TO PART (2)a Mr. J. Reppler's letter of March 15, 1979 described inconsist-encics in the FSAR which occurred at the time of origination of '.he FSAR. Paragraphs 1 and 2 of the CPCo response to Question 1, Part b dated April 24, 1979, describe the procedures used to prepare the FSAR. Paragraph 3 of that response provides a brief history of the preparation of the FSAR. Paragraphs 4, 5, and 6 describe the procedures and activities undertaken, subsequent to the submittal of the FSAR, to update the FSAR to include missing information, reflect design changes, and resolve identified inconsistencies between the FSAR and project design documents. Paragraph 7 explains why the incol gistencies created in FSAR Section 2.5 and. Subsection 3.8.5 at the time of preparation of the FSAR were not initially identified and corrected by the implementation of the original procedures. The following supplements the response to Question 1, Part b, and describes the control revisions instituted etnce submittal of the FSAR to preclude design contradictions. When the FSAR was docketed in November 1977, it became the prime licensing document superseding the design cammitments contained in the PSAR. Therefore, it is not valid to compare a PSI.R commitment to a current design document, implementing procelure, or as-built condition. It is valid to compare these design documents against the licensing commitments contained in the FSAR. PSAR design cammitments were incorporated into the FSAR when the FSAR was written. Attachment 1-1 to the Question 1, Part b response shows that the following documents were considered as input in the preparation of each FSAR subsection:

1. Regulatory Guide 1.70, Revision 2

2. NRC Standard Review Plans and. Branch Technical Positions

3. DRL Safety Evaluation 23-37 Revision 4 11/79 1336 335

RESPONSE TO QUESTION 23, PART 2 [50.54(f)]

4. Midland PSAR

5. Unincorporated SAR Change Notices

6. Regulatory Guides and Results of Regulatory Guide Review Program

7. Supplemental Environmental Report

8. Final Environmental Report

9. Design Documents

10. BESSAR 3-1 compares the soils area to other areas with respect to the preparation, initial review, and rereview of the FSAR. The root cause of the inconsistencies that occurred in the soils area are addressed in Part (1), Subsection 3.3 of this response. Mitigating circumstances that contributed to the inconsistencies were the change in level of detail required in licensing documents, the multiple display of technical information contained in cue FSAR, and the lack of change or question activity in the soils area.

Additional inconsistencies (other than the soils area) that may exist in the FSAR are being corrected by the total rereview program that has been undertaken as described in Parts (2)b and c of this response. An additional benefit of the FSAR rereview program is that an education process is occurring within all design disciplines, making them more aware of the level of design detail contained in the FSAR. Control document revisions that have been instituted to preclude design contradictions are described in Part (1), Subsection 3.3. 1338 336 23-38 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (2) [50. 54 ( f ) ] SECTION 3.0, RESPONSE TO PART ( 2)b 3.1 Review of the PSAR Commitment List Original PSAR commitments are contained in the PSAR Commitment List. This List includes the PSAR section, a statement of the commitment, the PSAR page containing the commitment, the revision number of that PSAR page, the company responsible for the commitment, the status of the commitment, and the commitment disposition document. Each PSAR commitment is either attached to an FSAR section for review or, if not applicable to any specific saction, distributed for review as an individual rereview package so that all PSAR commitments are included in the 3AR rereview program. The review of the PSAR Commitment List items is described in the sequence of the rereview program activities discussed in this response. As part of the rereview program, the PSAR Commitment List will be updated by completing the columns titled " Status" ar;d " Disposition Document" to ensure that they contain carrent information. Our April 24, 1979, responce to Question 1, part b, stated, "To assure that the PSAR design commitments were properly dispositioned through incorporation into a project design document or the FSAR, a final review and update of the PSAR Commitment List will be completed by January 1, 1980." It was determined that a review of the PSAR Commitment List, in lieu of reviewing the PSAR itself, was sufficient for this purpose for the following reasons.

a. When the PSAR Commitment List was prepared, the following steps were taken:

1. Initial preparation by an engineer in the Mechanical discipline; (The Mechanical discipline at that time was responsible for the preparation of the SAR.)

2. Complete review of the Conmitment List versus the PSAR commitments by the Project SAR Coordinator;

3. Review of the Commitment Liat by the Nuclear Group Leader, Mechanical Group Supervisor (Licensing Engineer), and Project Engineer.

1338 337 23-39 Re ision 4 11 79 4

g RESPONSE TO QUESTION 23, PART (2) [50.54(f)] These reviews were documented by reviewers initials each time the List was revised and reissued. Thus, the PSAR Commitment List received the same leve.1 of review as other project " design documents."

b. The PSAR and related documents were used in the preparation of the FSAR. There are existing documentation forms for the preparation of the FSAR sections that identify the PSAR sections reviewed in preparing that FSAR section. Thus, the PSAR Commitment List was not the primary document used in the preparation of the FSAR.

Significant changes that have been made in plant design since the issuance of the construction permit are identified in FSAR Table 1.3-2.

c. The FSAR is a complete document which does not rely on the PSAR previously submitted. Therefore, a rereview of the FSAR against project design documents is sufficient in itself to ensure that areas of contradiction do not exist.

1338 338 23-40 Revision 4 11/79

RESPONSE TO QUESTION 23, PART '2) [50.54 (f) ] 3.2 Rareview of the FSAR 3.2.1 Organization Personnel and organizations participating in the FSAR rereview program are as follows:

a. The FSAR rereview program involves various disciplines within the organizations of CPCo, B&W, and Bechtel.

b. Each company has dercloped or utilizes existing procedures for the conduct of this rereview as follows:

Company Procedure No. Procedure Title CPCo MPPM-19 " Conduct of Final Safety Analysis Report Review Program"; Revision 0 Bechtel IOM, R.L. Castleberry "FSAR Review Procedure - to File LF 9.0, June Midland Project" 1979 B&W NPG-0414-13 " Processing Contract Engineering Licensing Documents," Revision 3

c. The rereview program is managed by the Bechtel Licensing Group (composed of engineers) , which distributos the applicable rereview documents to various disciplines within Bechtel and also forwards applicable rereview documents to CPCo and B&W.

These rereview packages are reviewed by engineers within these organizations having cognizance in the subject matter of the rereview package, aad these rereview results are evaluated by supervisory engineers, as described in the sequence of rareview activities and rereview documentation given in this response.

d. The engineers, as well as the cognizant supervisory engineers in all three organizations, involved in this rereview are the same engineers currently involved in design activities.

1338 339 23-41 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (2) 150.54(f)1 3.2.2 Rereview Procedure The FSAR rereview process, as summarized in Attachment 23-2, is more fully described in the following sequence of activities.

a. The Bechtel Licensing Group prepares an FSAR rereview package for each subsection or group of consecutive subsections addressing the same subject, including FSAR NRC questions pertaining to that subsection and associated PSAR commitments from the PSAR Commitment List. Also PSAR commitments which are not specifically related to any FSAR section are distributed as separate rereview packages. Prior to distributing the rereview packages, the Bechtel Licensing Group completes Blocks 1 through 7 on the documentation form shown in Attachment 23-3.

b. Af ter receiving an FSAR rereview package, the Primary Rereviewer establishes which documents (e.g., P& ids, flow diagrams, single-line meter and relay diagrams, control logic diagrams, and various other documents in which licensing commitments are contained) the package must be rereviewed against and notes these in Block 8 of Attachment 23-3.

c. The Primary Rereviewer then systematically rereviews each document noted in Block 8 and ind icates whether any conflicts exist between the document and the FSAR section. The rereviewer makes any corrections arising from a conflict and notes these in the resolution column of Block 8. The rereviewer also rereviews the pcckage for consis-tency of cross-referenced FSAR sections, f ig ures ,

and tables, chapter references, NRC questions, and PSAR commitments and makes appropriate corrections. Following this, the Primary Rereviewer indicates any required interface review by a check in Block 11. The Primary Rereviewer and the Group Supervisor (cr other specitied individuals, depending upon the company procedure) then sign the form in Block 9.

d. The signature of the Group Supervisor indicates agreement with the quality and quantity of the review by the Primary Rereviewer. The Supervisor checks to ensure that the applicable documents are included in the review package and that all applicable interface rereviews have been designated. The rereview package is then transmitted to the Bechtel Licensing Group.

23-42 133 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (2) [50.54(f)]

e. The Bechtel Licensing Group makes a copy of the original rereview package to correspond to each interface rereview designated in Block 11 of Attachment 23-3. Prior to distributing the inter-face rereview packages, the Bechtel Licensing Group completes Block 10 on the documentation form to signify the date scheduled for the completion of the interface rereview. The original rereview package is retained in the Licensing Group files.

f. Af ter receiving an FSAR rereview package for interface rereview, the Interface Rereviewer determines which, if any, additional documents the package must be reviewed against and adds those to the list in Block 8 of Attachment 23-3 beneath those listed by the Primary Rereviewer. The Interface Rereviewer then systematically rereviews each of the documents added to Block 8 to determine if any conflicts exist betweens these documents and the FSAR section. For his areas of responsibility, the Interface Rereviewer also rereviews the package for consistency with cross-referenced FSAR sections, figures, tables, chapter references, NRC questions, and PSAR commitments. Following completion of the rereview, the Interface Rereviewer and Group Supervisor (or other specified individuals, depending upon the company procedure) then initial the form in Block 11. The interface rereview package is then transmitted to the Dechtel Licensing Group.

g. The Bechtel Licensing Group forwards the original rereview package and all interface rereview packages with comments to the Primary Rereviewer. Prior to distributing the packages for resolution of comments, the Bechtel Licensing Group completes Block 12 on the documentation form to schedule the completion of the resolutions.

h. Af ter receiving the original rereview package and all interface rereview packages with comments, the Primary Rereviewer resolves all interface comments which have outstanding questions with the respective Interf ace Rereviewer. The Primary Rereviewer clearly indicates whether an interface comment is to be incorporated into an FSAR change. The Primary Rereviewer is responsible for determining if any recent changes to the FSAR affect any of the comments. The Primary Rereviewer indicates in 1338 341 23-43 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (2) [50.54(f)] Block 13 of Attachment 23-3 if an FSAR change is required for the package and then signs, along with the Group Supervisor (or other specified individuals, depending upon the company procedure), in Block 13 to indicate completion of the rereview. The entire package is then transmitted to the Bechtel Licensing Group.

i. Upon completion of the resolution of comments by the Primary Rereviewer, the Bechtel Licensing Group initiates an FSAR change (if required) in accordance with Engineering Department Project Instruction 4.23.1. They obtain final approval (following review) from CPCo, B&W (if required),

and Bechtel and then prepare the input for FSAR revision typing, printing, and distribution.

j. The original rereview packages and interface rereview packages are retained in the Bechtel Licensing Group files.

k. Changes to the FSAR identified during the rereview process are incorporated into the FSAR during future revisions. Changes to design documents identified during the rereview process are identi-fled in the " Resolution" column of Attachment 23-3 and are tracked by the Bechtel Licensing Group in accordance with the rereview procedure until a change to the design document has been executed.

1338 342 23-44 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (2) [50.54(f)] 3.2.3 Processing Resulting Changes

a. The revised design documents are routed to Field Engineers in accordance with the requirements of FPD-1.000, " Design Document and Correspondence Control." The Field Engineers, in accordance with FIG-3.200, " Field Engineer Responsibilities," are required to review the design documents and their resultant effect on construction with respect to

1) interferences and conflicts, 2) incorporation of change addenda, 3) correlation of references and interfacing documents, 4) clear, concise, and adequate details and notes, 5) technical clarity,

6) legibility, 7) changes affecting completed work and current construction planning, 8) other pertinent features. Any deficiencies or discrepancies are resolved.

b. In accordance with Project Special Provision G-6.1, " Quality Control Inspection Plans," changes in design documents will be reflected in revisions to the activity descriptions, inspection criteria, supplementary records, and inspection activity codes in the Project Quality Control Instructions and Inspection Records.

c. Open Inspection Records which are affected by revisions to Project Quality Control Instructions will be revised to incorporate the changes. These revisions will be controlled by a revision to the Quality Control Inspection Record number.

d. A design document change which pl .rsically affects completed work will require the initiation of a new Inspection Record. The new Inspection Record will be developed to cover the inspection of the work required to accomplish the design change.

Each new Inspection Record will be identified with the number of the record for the original work plus an alpha suffix (a, b, c, etc). Each new Inspection Record, when it is completed, will be attached to the original Inspection Record. The new Inspection Record will specify the design change that brought about the additional inspection work.

e. Design changes to completed work are addressed in Project Special Provision G-3.2, " Control of No nconforming Items." Completed work which has been inspected and found to be satisf actory is classified as conforming.

                                                      }}}} TA}

{ 23-45 Revision 4 11/79

RESPONSE TO QUESTION 23, PART 2 [50. 54 (f) ] 3.3 Review of Engineering Department Procedure 4.22 The following sequence of events took place relative to the review of Engineering Department Procedure 4.22, " Preparation and Control of SAR."

a. Review of Engineering Department Procedure 4.22 was by the Project Quality Engineering, and included coordination with the Project SAR Coordinator.

b. Primary consideration was given as to whether the originator of a SAR section had sufficuent guide-lines in which to prepare a SAR section.

c. The results of the review were affirmative; the engineer had sufficient direction in the procedure.

This was documented in an IOM dated July 23, 1979, R.L. Castleberry to L.A. Dreisbach.

d. Subsequent to the completion of Itera c, above, it was decided during a series of meetings to revise Engineering Department Procedure 4.22 for clarifi-cation. (The requirements of Regulatory Guide 1.70,

         " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," were moved from Section 2.0, " Scope" to Section 5.0, " Engineering and Administrative effort." This revision is to be completed by December 1, 1979.)

23-46 Revision 4 11/79

                                                    }338 bk

RESPONSE TO QUESTION 23, PAP.1' (2) [50.54 (f) ] SECTION 4.0, RESPONSE TO PART (2)c The FSAR rereview program has been extended from the original plan to include the entire FSAR, with certain excepH.ons as follows:

a. Appendixes such as 2A, 2B, and 2C contain only test data for which a rereview would be meaningless.

b. Security Plan which is currently under review and will be completely revised when it is submitted.

c. Technical Specifications (Chapter 16) which will be extensively reviewed prior to NRC final review 6 months to 1 year prior to the issuance of an operating license.

d. Fire Protection Evaluation Report which will be completely reviewed and revised upon receipt of fire protection questions from the NRC.

e. Site Emergency Plan which was extensively revised in Revision 18 (February 1979) to the FSAR and will be revised as necessary to meet new, additional requirements.

The entire rereview program will be completed by July 1980, with all resulting revisions to the FSAR made by the July 1980 amendment. 23-47 Revision 4 11/79 1338 545

RESPONSE TO QUESTION 23, PART (2) [50.54(f)] SECTION 5.0, RESPONSE TO PART (2)d The purpose of the audit committed to in Item 4 of the eighth paragraph of Question 1, Part b, is to verify the effectiveness of the rereview. The audit will cover two aspects as follows:

a. Degree of compliance with rereview procedures.

b. Technical correctness of rereview dispositions.

The audit committed to in our response to Question 1, Part b and described in the preceeding paragraphs will be conducted once during the course of the FSAR rereview (commencing January 1, 1980) and again after completion of the rereview (August 1, 1980) . An audit plan will be prepared consistent with the CPCo, Bechtel, and B&W policies and procedures governing audits. Bechtel will serve as the audit team leader. The audit team will comprise personnel from each of the three organizations. 1338 346 23-48 Revision 4 11/79

RESPWSE 'IO QUESTICN 23, PARE (3) (50.54 (f)] SECTICN 1.0, NBC QUESTICN SUPPLEMENIAL i<t.an:a EOR ADDITIWAL SOILS SETILEMENT INEURMATICN

23. We have reviewed your response to question 1 of our March 21, 1979 letter, "10 CFR 50.54 Request Regarding Plant Fill," incitriing related aire.rdrunts or c"ppla' ants in your letters dated May 31, July 9, and August 10, 1979. We find that the infonmtion provided is not sufficent for ocxrpleticn of our review. Accordingly, provide the following additional infocation:

(3) Question le requested that other activities be investigated to deemina whether programmtic quality assurance daficimciaa exist in view of the apparent breakdown or 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 frcan one to two per year; increasing the staff of Mch+al's OA engineers at the site frcru five to eight; instituting an overinspection sv:rmu on certain 0-listed constrtction activities; assigning resident engineers at the site to aid in the interpretation of drawings and increas-ing their number frcxn one to twenty-two; and initiating a trend analysis s vg m a.

a. Accxarding to your response, most of these actions were initiated in 1977. Describe your rationale for assu:ning that these actions provide mnfidance that quality assurance daficia ries do not exist in other areas. In order to de*-ina if other areas have daficiancias, work already accmplished in these areas should be investigated. 'Ihis includes the review of cmpleted d~'~ntation, inc1 Ming inspecticn results, to verify consistency with design and SAR requiremnts.

Also, representative sanple inspections of ccmpleted work would seem appropriate to defamina the acceptability of this work. AcmMingly, describe a program in detail to acomm14 =h the above or provide rationale as to why it is not necessary.

b. Your use of generalized statenents such as "the review of"," increased aulits," "overinspection," " identifying trends," and " increase of staff" does not provide sufficient spacificity regarding the detail arxi 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 inpact they will have in assuring an effective OA program and in sufficient detail to assure that other areas are not deficient.

In those cases where credit is taken for actions already accmplished (such as review, inspections, and audits), provide a su:nnary of the results of these actions such that the success or failure of the actions can be determined. d38 347 23-49 Revision 4 11/79

A COMPARISON OF REVIEW AND CilANGE ACTIVITY FOR Tile SOILS FSAR SECTION AND FOR OTIIER FSAR SECTIONS TIME ' PERIOD SOIIS OTHER AREAS ORIGINATION

• PREPARED BY GE0/TECII
• PREPARED BY TGAR CPSANIZATION 1977
• REVIEWED PRIOR TO SUH1ITTAL
• REVIEWED PRIOR 'IU SUEMITTAL BY DISCIPLIllES BY DISCIPLIIE

                                                         * (NOT ALL SPECS AVAILABLE)

REVIEW

• INACTIVE
• ACTIVE-1977 to
• NO NRC QUESTIONS
• 1600 CHANGE NOTICES PRESENT
• NO CHANGE NOTICES
• REVIEWED BY DISCIPLIllES u
• METHOD:

u CO

• EDP I+.23 6
• ELDENP REVIEW p-
• DEGREE OF REVIEW BASED ON DEGREE OF ACTIVITY N RE-REVIEW
• SPECIAL PROCEDURE
• SPECIAL PROCEDISE rt

@ JUNE 1979

               . SYSTEM /SUBSY N RE-REVIEW

• SYSTEM /SUBSYSTDi RE-REVIIM

{ TIIRU $ JULY 1980

• RE-REVEN BY DISCIPLDE & GE0/ TECH
• RE-REVIEW BY DISCIPLIEES rt u
• TOTAL RE-REVIEW
• TOTAL REMEVIEW Y

~

Midland Plant Units 1 & 2 FSAR REVIEW FLOW CHART consumers Power company: BeChtel Job 7220 o s *9'sc b Interface / Review Comp / Disc Bechtel nsing gp Final Approval Project Administration REVIEWS FSAR REVIEW PACKAGE AGAINST DESIGN PREPARES FSAR DOCUMENTS. IN. REVIEW PACKAGES DiCATES REQUIRED M mem BY FSAR SUB-CHANGES. SECTION & PSAR DESIGNATES RE. COMMITMENT LIST. QUIRED INTERFACE ' REVIEW. I ' COPIES FSAR REVIEW PACKAGES. DISTRIBUTES REVIEW PACKAGES TO DESIGNATED INTERFACE REVIEW COMP / DISC. REVIEWS FSAR REVIEW PACKAGE g r------ > s8C'" 5 M ?3

                              ^

l h'HAN S SENDS ORIGINAL g FSAR REVIEW PACKAGE AND U l l INTERFACE REVIEW U 'l [ COPIES TO PRIMARY COMP / DISC FOR Q l RESOLUTION OF IN-u l TERFACE COMMENTS. % I FINAL REVIEW / e y APPROVAL BY CPCo, m ' 1 n B&W (IF REQUIRED) lI RESOLVES A A CHANGE NOTICES IN mb AND BECHTEL PROJECT ENGINEER. $ MENTS AND O AN E num TYPING " SENDS REVIEW ' g DB NS FINAL APPROVAL SIG. PRINTING w PACKAGE IN FINAL ' DISTRIBWON y FORM TO LICENSING GROUP. NATURES. PREPARES INPUT FOR FSAR ^ N " REVISION. G 0633

FSAR REVIEW DOCUMENTATION FORM MIDLAND PROJECT JOB 7220 1. REVIEW LOG NO.

2. COMPANY: 3. PRIMARY REVIEW DISCIPUNE:

O CPCo O BECHTEL O Baw

4. FSAR SUBSECTION: 5. NRC QUESTIONS: 6. PSAR COMMITMENT UST ITEMS:

8. PHASE 1: DESIGN DOCUMENT REVIEW 7. RETURN TO BECHTEL UCENSING BY:

DESIGN DOCUMENT CONFUCT RESOLUTION YES / NO YES / NO YES / NO YES / NO YES / NO YES / NO YES / NO YES / NO YES / NO YES / NO YES / NO , 9. INITIAL REVIEW APPROVAL (INDICATE REQUIRED INTERFACE REVIEW IN BLOCK 11.) (PRIMARY REVIEWER) (DATE) (SUPERVISOR) (DATE)

11. PH ASE II:lNTERFACE REVIEW 10. RETURN TO BECHTEL UCENSING BY:

O BECHTEL BECHTEL DISCIPUNE INTERFACE REVIEW: INTERFACING STAFF REVIEW: C ARCH C PLANT DSN O ARCH ' OM&CS OCML O PGAE OCML O MECH I i CONTROL SYS I1 STRESS _ n CONTROL SYSTEM iiNUCLEAR . .._.,. _ . U ELEC U OTHER O ELEC O PLANT DSN C MECHINUCLEAR O GEOTECH O STRESS O CPCo OB&W

13. PHASE lil: RESOLUTION OF COMMENTS 12. RETURN TO BECHTEL UCENSING BY:

FSAR CHANGE REQUIRED YES / NO All Interface Comments Resolved. Ucensing Group is Authonzed.To initiate A FSAR Change Without Additional Interface Review. , 1338 350 (PR6 MARY REVIEWER) (OATE) (SUPERVISOR) (OATE) G-o648 Attachment 23-3

RESPONSE TO QUESTION 23, PART (2) [50.54(f)] ATTACHMENT 1 TO ATTACHMENT 23-3 The form illustrated in Attachment 23-3 is used to document the various phases and steps of the rereview of the Midland plant FSAR. Thirteen numbered blocks are completed for each rereview package.

a. The first block, " Review Log No," identifies each rereview package by a unique number assigned by the Bechtel Licensing Group.

b. The second block, " Company," designates the primary rereview company for the rereview package as assigned by the Bechtel Licensing Group.

c. The third block, " Primary Review Discipline," is used to designate the discipline assigned primary rereview responsibility by the Bechtel Licensing Group.

d. The fourth block, "FSAR Subsection," is completed by the Bechtel Licensing Group to designate the FSAR subsections included in the rereview package.

e. The fif th block, "NRC Questions," is completed by the Bechtel Licensing Group to indicate any FSAR phase NRC questions pertaining to the subsections identified in Block 4 included in the rereview package.

f. The sixth block, "PSAR Commitment List Items," is completed by the Bechtel Licensing Group to indicate any PSAR Commitment List items pertaining to the subsections identified in Block 4 included in the rereview package.

g. The seventh block, " Return to Bechtel Licensing by," is completed by the Bechtel Licensing Group to 'icate the date when the completed Phase rereview package is to be received by the Bechtel Licensing Group.

h. The eighth block, " Phase I: Design Document Review,"

is completed by the Primary Rereviewer to indicate all documents against which the rereview package is rereviewed, to indicate whether conflicts exist between the rereview FSAR section and the other documents, and to indicate the necessary resolution of any conflict, as appropriate. For NRC Questions and PSAR Commitment List items, the Primary Rereviewer verifies that no conflicts exist with the FSAR text, and that the FSAR text corresponds to the commitments in the FSAR questions and PSAR 1338 35i Commitment List and is complete and correct. Attachment 23-3 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (2) (50.54 (f) ]

i. The ninth block, " Initial Review Approval," is completed by the Primary Rereviewer and the Group Supervisor (or by other specified individuals, depending upon the company procedure). Prior to signing for rereview approval, the Primary Rereviewer designates all required interface rereview by checking the appropriate boxes in Block 11. The signature by the Grcup Supervisor indi-cates agreement with the quantity and quality of the review by the Primary Rereviewer. The Supervisor checks to ensure that the documents used by the Primary Roreviewer cover all applicable interfaces. The rereview package is then returned to Bechtel Licensing.

j. The tenth block, " Return to Bechtel Licensing by," is completed by the Bechtel Licensing Group to indicate the date when the completed Phase II rereview package is to be received by the Bechtel Licensing Group following an interface rereview.

k. The eleventh block, " Phase II: Interface Review," is completed by the individual performing the interface rereview as designated by the Primary Rereviewer (see Block 9 above). If additional documents are used by the Interface Rereviewer, these documents are listed in Block 8 in accordance with the procedures described therefor. Following satisfactory completion of the interface rereview, the Primary Reviewer and the Group Supervisor or other specified individuals (depending upon the company procedures) initial this block. The Supervisor's initialsindicates approval of the rereview performed by the Interface Rereviewer as discussed under Block 9, above. The interface reroview package is then returned to the Bechtel Licensing Group.

1. The twelfth block, " Return to Bechtel Licensing by," is completed by the Bechtel Licensing Group to indicate the date when the completed Phase II rereview package is to be received by the Bechtel Licensing Group following resolution of the comments.

m. The thirteen block, " Phase III: Resolution of Comments,"

is completed by the Primary Rereviewer following the resolution of all interface comments resulting from the interface review. The Primary Rereviewer indicates whether each interface comment is to be incorporated into the FSAR. The Primary Rereviewer indicates whether an FSAR change is required by designating "yes" or "no" and, following resolution of all interface comments, signs the form along with the Group Supervisor or 1338 552 Attachment 23-3 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (2) [50. 54 (f) ] other specified individuals (depending upon the company procedures) to indicate completion of the rereview package. The Supervisor's signature indicates approval of the resolution of comments by the Primary Rereviewer consistent with the original rereview discussed under Block 9, above. 1338 353 Attachment 23-3 Revision 4 11/79

i RESPONSE TO QUESTION 23, PART (3) 1338 354 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3) [50.54(f)] SECTION 2.0, INTRODUCTION In Subpart a of Part (3) of the question, it was requested that we provide our rationale for our conficence that quality assurance deficiencies do not (or will not ) exist in other areas. Our confidence stems from three factors, as follows:

a. The recognition of the differences between soils ar.d other work, as described in Section 3.0.

b. The fact that, from the outset, a Quality Assurance implementation.

Subsection 4.1 provides a list of Quality Assurance Program improvements. Subsection 4.2 provides more detail as to the extent and results of selected improvements as requested in Subpart b of Part (3) of the question.

c. the programmatic and generic corrective actions which have been taken, or will be taken, as described in our response to Parts (1) and (2) of the question and as summarized in Section 5.0.

1333 355 23-50 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3) [50.54(f)] SECTION 3.0, DIFFERNECES BETWEEN SOILS WORK AND OTHER WORK Prior to 1977, the major site construction activities were in the civil and structural areas. The major specific activities were soils, rebar and embeds, concrete, cadwelding, structural steel erection, and liner plate erection. In 1977, electrical and mechanical installation activities became significant. Soils and concrete are similar bulk installation activities which rely, in large part, upon the tests at a given point representative of the quantity of material placed. Additional confidence in the quality of the concrete is achieved through several, factors that are not available to soils work. Concrete work is more scientific than soils placement and compaction and the variables of concrete work are more quantifiable and measurable. The physical testing of concrete (cyliner breaks) provides acceptable or unacceptable results on a short-term basis. With soils, the only veritication, subsequent to the initial acceptance test, is the long-term monitoring program for settlement of structures supported in the fill. The inspection and controls for the construction activities for cadwelding, rebar, and embeds provide high confidence in the quality of these items. Rebar has had a 100% overinspection by CPCo QA from April 1976 to September 1978 and embeds have had a 100% overinspection by CPCo QA from June 1972 to September 1978. Structural steel erection and other civil activities, including welding and liner plate erection, are activities for which there are characteristics accessible to inspection and reinspection, allowing for independent subsequent verifications of the quality of these items. The above is also true of most aspects of mechanical and electrical construction activities. The major improvements with regard to specifications and QCIs were made prior to significant construction activities in the Mechanical and Electrical disciplines. These systems will be subject to overinspections and walkdown inspections by CPCo QA at the time of turnover, which will provide additional detailed evaluation of these systems. Subsequent to the construction acceptance, a system verification is accomplished through the checkout and preoperational testing activities. 1338 356 23-51 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3) [50.54(f)] 4.1 History and Chronology of Improvements, In General 1970

1. CPCo QA Program as presented in the Midland Plant PSAR was approved by the AEC Staff in the Safety Evaluation Report.

1973

1. The Bechtel Quality Control Organization at the site was reorganized to be independent of the Bechtel Construction Organization at the site.

2. The CPCo Quality Assurance organization was formed with a staff of five persons.

1974

1. The review and approval by CPCo Quality Assurance of Bechtel Quality control administrative procedures and inspection instructions was initiated.

2. The number of CPCo Quality Assurance professional personnel overviewing the Bechtel Quality Assurance Program was increased from five to six.

3. The CPCo Quality Assurance program policies and proedures were significantly improved.

1975

1. CPCo Quality Assurance inspection of stored materials was instituted.

2. The number of CPCo Quality Assurance professional personnel overviewing the Bechtel Quality Assurance Program was increased from six to seven.

, 1976

1. Bechtel quality trending was instituted.

2. The CPCo Quality Assurance Program (Topical Report) was approved by NRC.

3. CPCo Quality Assurance overinspection of rebar install-ation was instituted.

4. The Bechtel Quality Control Notices Manual was prepared specifically for the Midland Project and the Bechtel Field Inspection Manual was phased out.

5. Major biennial audits of the Quality Assurance Program, utilizing outside consultants, were initiated by CPCo Quality Assu ance.

1338 557 Revision 4 23-52 11/79

RESPONSE TO QUESTION 23, PART ( 3 ) [ 50. 54 ( f ) ]

6. The number of CPCo Quality Assurance professional personnel (excluding auditors) overviewing the Bechtel Quality Assurance Program was 1/freased from seven to nine.

7. Bechtel Resident Engineering was established at the jobsite.

1977

1. CPCo Quality Assurance overine ection of embeds was instituted.

2. CPCo Quality Assurance Program Procedures dealing with nonconformance reporting, audit, and personnel certifi-cation were significantly improved.

3. CPCo Quality Assurance Program Procedures dealing with reporting to NRC and turnover were originated.

4. The Bechtel quality trending activity was significantly improved.

5. CPCo Quality Assurance was reorganized to form the Quality Assurance Engineering Section and the Inspection, Examination and Test Verification Section, the latter having emphasis on hardware evaluation.

6. The following five additional Regulatory Guides were implemented: 1.38, dealing with the quality requirements for packaging, shipping, receiving, storage, and handling; 1.39, dealing with housekeeping; 1.55, dealing with concrete placement for Category I structures; 1.58, dealing with the qualification of inspection, examination

, and testing personnel; and 1.94, dealing with the quality assurance requirements for the installation, inspection, and testing of structural concrete and structural steel.

7. An extensive training activity was implemented for CPCo Quality Assurance personnel.

8. CPCo Quality Assurance became the overinspection organization for Q-listed pressure tests.

                                                         !338 358 Revision 4 23-53                            11/79

RESPONSE TO QUESTION 23, PART (3)[50.54(f)]

9. NRC implemented an " increased inspection" program.

10. The number of CPCo Quality Assurance professional personnel (excluding auditors) overviewing the Bechtel Quality Assurance Program was increased from nine to twenty-two.

11. Bechtel and CPCo reviewed specifications to improve specificity.

12. Bechtel QC and CPCo QA reviewed Quality Control Instructions (QCIs) to improve inspection callouts in the QCIs.

13. The Bechtel monitoring activity was improved to conduct mc;e product-related monitors.

14. Bechtel QA management audits were increased from one to two per year.

1978

1. CPCo Quality Assurance overinspection of all other areas, in addition to the civil area, was instituted.

2. Approximately 30 CPCo Quality Assurance overinspection plans were prepared and implemented.

3. One hundred percent CPCo Quality Assurance review of supplier radiographs being received with new deliveries was instituted.

4. The ASME Code Stamp Authorizations were extended to Bechtel for another three years.

5. Fifteen CPCo Quality Assurance Department Procedures were completed, revised or originated dealing with department procedures; organization; personnel training, qualification and certification; processing procurement documents; source and receiving inspection planning and inspections; nonconformance reporting, corrective actions and statusing; periodic reporting; review of quality-related regulations, codes, standards, speci-fications, and other external documents; procurement quality assurance requirements; inspection stamp control; 1338 359 23-54 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3){50.54(f)] qualification and certification of quality assurance audit team leaders; qualification and certification of quality assurance audit team members; qualification, training and certification of inspection and test personnel; analysis and resolution of significant quality problems; overinspection and primary inspection.

6. The primary responsibility for the overview of the B&W NSSS installation was given to CPCo Quality Assurance.

7. The number of CPCo Quality Assurance audits performed was doubled from the previous year.

8. Resident inspection was instituted by NRC.

9. The number of CPCo Quality Assurance professional personnel (excluding auditors) overviewing the Bechtel Quality Assurance Program was increased from twenty-two to twenty-three.

1979

1. The rereview of qualification test data for Bechtel procured items was completed.

2. The rereview of qualification test data for B&W procured items was initiated.

3. The rereview of quality documentation for B&W procured items was completed.

4. The rereview of quality documentation for Bechtel procured items was initiated.

5. " Surveillance" was eliminated as a Bechtel final inspection technique.

6. Nonscientific sampling was eliminated (with minor exceptions) as a Bechtel final inspection technique.

7. ASME Code Stamp Authorizations were granted for B&W site installation work.

8. A CPCo Quality Assurance Program Procedure was originated and implemented for processing NRC Bulletina, Circulars, and Information Notices.

1338 360 Revision 4 23-55 11/79

                                                           +
                                  -                                                                                                                                                                                                                                                                   k
                                                    ,*,*,e
                                                                                                                                                                                                                                           ~
       +      -                                                                                                                                                                                                                    .-                                                               s' 4
                                                                                                                                                                                                                                                                                        *N .,.
                                                                                                 +                                                                                                                                               '                                                    *
                                                                                                                                                                                                                                                                                                      +
                                                                                                                                                                                                                                                                                                    +
                                                                                                                                                    .                                                                                                                                                 g o

A, p  ? '

                                                                                                                           '                                                                                                                                                                        ^
                                                                                            .                                                                 [                                                                    ~ ,,

s ,

                                                                                                                                                                                              - =

9

                                                                                                                                                                                                                                                                                                     /,

o

                                                                                          ^

N

                                                                                                                                                                                                                                                                                 ,8
                                                                                                                                     ,                                                     ~'

(A ~

                                                                                                                                                                                                                                                                                ~ '

g*

                                                                                                                                                                                                                     ,_                                                                             +
                                                                                                                                                                                                                                                                                                      ^

n f

                                                                                                                                                                                                                        /

N s,

                                                                                                                                                                                                                                                                                                      +
                                                                                                                                                                                                                                                                                                      /

w *

                                                                                                                                                                                                                                                                                                     \..
                                                                                                                                                                                       ~                                   -

_- \, a s.

                                                                                                     ~                                    -

4,

                                                                                                                                                                                                                                                               $                                     s
                                                                                          \                             ;

k[ ,. ', s c

                                                                                                                                                        +                                                                        ,
                                                                                                                                                                                                                                                                                                     \

[jN@c g k'- M , ~g _4g

f. ,

g![i ff;*'

i. s N.$ x - gg hg ,

ma wii # fIp;"A4a%%p n e ~ g)yz ' gl i 5 ,

                                                                                                                                 ?_ :                                                                                                                                          !c>

a*

                                                                    ~,,m.*%r#n
                                                                           <                                                                          h ~ g;g-                                                                                                                                     s, f lwg f0       2n        :s          bN                                 a '7 l- _

eu'wO,n'3 M g hS"@s,g$

                                                                                                                                                                                                                                                                                        . \

y , k;$2s.? 4 5' aa l \,

                                                                                                                                                                           %g
                                                                                                                                                                                                                          /y
                                                                                                                                                                                                                        %g*kf;sr p
                                                                                                                                                                                                                               .j xA ?f-
                                                                    %y.       , W~ Mu,a,,
                                                                                                                                                                                %                                  fgfw-
                       ; f,.y c-                                                      ah                                                                                                        efm.                             I                     sm Mf                                                                                             ?a                                                 h,                       ,
                            ;; 9                                                                                                                                                                        R                        y;,.               J wf 3                                                                                                                                                                                                                    H ,. a                                      s
                                                                                                                                                                                                                                                                            'm gv !28 n g g

x%,u

     , y:Qq\

u I8 E.h x hd m-c p

                                                                                                                                                                                                                                                                             %                       8
                                                                                                                                                                                                                                                                                                      \

sag.WCwAeg$yrp s f I. kN kn j

                                                                                                                                                                                                                                                                    ,x N
                                            )                                                                 g w                                                                                                                        )t
                                                                                 ~,lN
                                                                                                                                            ~,          uy*N                    Ma                                                                                                                   s s

h .nwg h gg ,

                                                                 ',-                                                                                                           pkN                                 T#yy w g$f,fgsgt?kis;g                                                            e

[ 3 f,[em

                               +g                           .,[a        -

j.y ~ *v e g 1: m + 3 3,?::. W r

                                            }l yjf -

3 3 W g wmg% g g> p kdyu poS'wg y f* t 9 hd

  ^
                                                                              }. ~                        -
                                                                                                            'py c                                                                                                ,           ,

r

  -s
                                                                                                                                                                                                                               =                                                                     '

k N

1. d)9$$!'*

   \\\\       IMAGE EVALUATION TEST TARGET (MT-3) k$k    NNNN 1'0   '" HM HM E m 6s g ,3 1.1  ,E
                          , 'S lim l.8 y 1.25    1.4   1.6
        =               s~                 =
  +>

>>,4

          %                            +
                                     + /4
*>4:> %or%////
                                       + ;a /4Ns
                                          <pp ge}Y/jj O
                                        +<Rf**

4 9A'%,

'& +

(*Ab

 $$         , .eEEv<e TEST TARGET (MT-3) 1,. $'%'

1'0

               -       'em E Ena]n m    ,,    L2
                                   =

l.l [',E ll!M l.8 1.25 1.4 1.6 4 6"

# *e                                  +4%

• $$%f 5,, b,A;y>

     \ .. _

4 4

1. +4>%% <s%e f4A T.ST TARG,T (MT-3) 1.0 'H38 12M l@ lilE u Lm llllas la 1.25 1.4 jg

 =             s             =

%s$/ 4/7k*%, /+$ dh ff f43'<%

RESPONSE TO QUESTION 23, PART (3)[50.54(f)]

9. CPCo Quality Assurance Department Procedures were originated and implemented dealing with turnover, forms, requests for information, and oral communications.

10. " Midterm Inspection" was performed by NRC.

11. LCVIP Inspection of the Bechtel Ann Arbor Office was performed by Region IV.

12. Review and revision of the CPCo Quality Assurance Program Procedures was completed by tne Senior Vice President and his staff.

13. The number of CP o Quality Assurance professional personnel (excluding auditors) overviewing the Bechtel Quality Assurance Program was increased from twenty-three to twenty-six.

1339 001 Revision 4 23-56 11/79

RESPONSE TO QUE3 TION 23, PART (3)[50.54(f)] 4.2 Specifics of Select 2d Improvements 4.2.1 Review of Specifications In September 1977, a review of specifications was initiated by Dechtel Engineering and CPCo Quality Assurance. This review was performed in association with the review of Quality Control Instructions (CCIs) as described in Subsection 4.2.2. The specifications reviewed were selected specifications for Q-listed equipment and activities. Reviewers (Quality Assurance Engineers, Quality Engineers, and cognizant discipline engineers) were to determine any areas where the specifications lacked clarity, conflicted with other project criteria, or lacked necessary criteria, including dimensions or tolerances. A total of 50 specifications, as follows, were reviewed by CPCo Quality Assurance, and 23 of these 50 specifications were also reviewed by Bechtel Project Engineering: 5 architectural, 25 civil, 11 mechanical, 1 control systems, and 8 general specifications. At that time, there was a total of 189 Q-listed specifications issued for use on the Midland project. As a result of this review, specification revisions were made in 12 instances to provide specific tolerances or further clarity, or correction of editorial comments. A review of those specifications being used for construction and not included in the reviaws described above was initiated on May 8, 1979, and was completed by Project Engineering on July 13, 1979, resulting in revision to three specifications. In addition to the above specification reviews, the Bechtel Chief Engineering Staff, and CPCo QA, performed a dimensional tolerancing review of a portion of the containment spray system from November 2 to December 13, 1977. This was a review to determine if there were any problems associated with tolerancing for specified quantitative parameters (dimensions, pressure, temperature, chemical content, etc). As a result of the dimensional tolerancing review, there were 8 revisions to specifications to provide tolerances or more clarity. 1337 002 Revision 4 23-57 11/79

RESPONSE TO QUESTION 23, PART ( 3 ) [5 0. 54 ( f) ] In March 1978, 95 Field Change Requests (FCRs) issued in January 1978 were reviewed to determine whether project personnel were demonstrating a concern for specificity. Eleven FCRs provided positive demonstration of project concern for specificity and improved awareness in this area. An example of revisions that were made as a result of these specificity reviews is provided by the following comment and response. Comment: It should be noted here that Specification 7220-C-42 is incomplete in that the tolerances required for fabrication are not included in this specification. Blank spaces have been inserted in the specification where these tolerances are to be inserted at a later date. Response: The current revision of Specification 7220-C-42 is Revision 2, dated July 2?, 1978, " issued for purchase." This revision is now complete and up-to-date. This review resulted in some project specifications being revised and emphasized the need for specificity to a broad spectrum of project perronnel. The specification changes were processed utilizing the change control system described in the response to Part 2 to ensure consideration of impact on completed work. 1339 003 Revision 4 23-58 11/79

RESPONSE TO QUESTION 23, PART (3) [50.54(f)] 4.2.2 Bechtel QC and CPCo CA Review of Quality Control Instcuctions From April 1977 to August 1977, a review of all issued Quality Control Instructions (OCIs) was conducted jointly by Bechtel Quality Control (QC) and CPCo Quality Assurance. The purpose of this review was to improve the specificity of the inspection callouts in the QCIs. 52 QCIs were reviawed in their entirety, resulting in all QCIs being revised to incorporate agreed upon changes. As a result of this QCI review, it was considered necessary to revise SF/ PSP G-6.1 " Quality Control Inspection Plan". This revision added requirements to provide improved clarity of inspection callouts. As committed by the April 24, 1979, response to Question 1, Part a, Section D, Page I-18, a further review of the QCIs was completed by Bechtel in June 1979 to identify those QCIs which call for "Surveillances" and which call for supplementary records documentation reviews. As a result of this identification, revisions were initiated: (a) to require the utilization of " Inspection" activity for inspections of record, and to limit the utilization of " Surveillance" for defect prevention activity only and (b) to clarify the " Review" activity of supplementary records. As of October 1979, 7 identi-fied QCIs have been revised to incorporate this criteria, 17 identified QCIs have been reviewed and found acceptable and 26 identified OCIs are in the review stage with completion scheduled for December 1979. The following additional actions are planned as described in Part (1) Subsection 3.8. A. SF/ PSP G-6.1, " Quality Control Inspection Plans," will be revised to provide requirements for inspection planning specificity and for the utilization of scientific sampling rather than percentage sampling. This action is scheduled to be completed by January 24, 1980. B. QCIs in use will be reviewed to ascertain that provisions have been included consistent with the revised control document. This action and any required revisions are scheduled to be completed by March 8, 1980. C. The impact of B (above) oncompletedworkwillbei 339 004 evaluated, and appropriate actions will be taken as necessary. This action is scheduled to be completed by May 23, 1980. 23-59 Revision 4 11/79

RESPONSE TO QUESTION 23, PART ( 3 ) [50. 54 ( f) ] 4.2.3 CPCo QA Review and Approval of Bechtel QC Administrative Procedures Since January 1974 CPCo QA has reviewed and approved the administrative procedures in the Bechtel Field Inspection Manual and Quality Control Notices Manual. The controlling documents have varied, but all have been CPCo QA department procadures or Midland Project QA Procedures. This activity is continuing today. 1339 0'05 23-60 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3)[50.54(f)] 4.2.4 Bechtel Resident Engineers The Resident Engineering activity, an extension of Project Englaeering, was established at the Midland jobsite in 1976 to provide a cJoser liaison between the Ann Arbor Office Project Engin2ering and Project Field Engineering; to provide, as needed, interpretations of ' design specifications and drawings; to expedite disposition of design changes resulting from Field Change Requests, Field Change Notices and Design Change Notices; to provide approvals of construction activities as required by specifications; and to expedite resolution of design and construction problems. These Resident Engineering activities allow for in-situ determinations of the root causes of design and construction interface problems and provide for timely, hands-on solutions which are backed up by Project Engineering reviews. The Resident Engineering activities are described in Engineering Department Project Instruction (EDPI) 2.14.2, Rev. 6. This EDPI, in addition to prescribing the boundaries of the authority of the Resident Engineers, establishes the channels for control and review c f the actions af the Resident Engineers, and the follow-up activities of Ann Arbor Office Project Engineering. All Engineering Department Procedures are applicable to any design functions which may be performed by the Resident Engineers. As their benefits became apparent and their activities increased, the Resident Engineering Group was increased to the present level of 22 persons, which includes an experienced Assistant Project Engineer. As the nature of activity. shifts during the construction phase (e.g., civil work to mechanical to electrical), the mix of disciplines in the Resident Engineering Group has been shifted correspondingly. The timeliness of Resident Engineering interpretations, responses to Field Change Requests, design changes, dispositions for Nonconformance Reports, and approvals of Field Change Notices reduces the probability of deficiencies in construction. The physical presence and availability of Resident Engineering at the site invites and encourages consultation and discussion 1339 006 Re'ision 4 23-61 11/79

RESPONSE TO QUESTION 23, PART (3)[50.54(f)] during construction. The Resident Engineers thus serve as the focal point and channel for the exchange of information between Constru ' tion and Engineering, thereby improving the level of confidence ti.at SAR and design requirements are met. It is the intent of the Project Management to continue the supportive and beneficial activities of the Resident Engineers at a level commensurate with the construction activities. 1339 007 Revision 4 23-62 11/79

RESPONSE TO QUESTION 23, PART (3) [50.54(f)] 4.2.5 Bechtel Monitoring Activity Improvements The standard monitoring activity, as described in Quality Assurance Department Procedure C-1, was amended September 15, 1977, to provide a more representative assessment of Quality Assurance Program effectiveness. The amended monitoring procedure was structured to use systematic auditing techniques to assess the conformance of a product to the essential requirements of project documents specifying quality. The effect of the amended procedure was to increase expanded the number of design office documents (drawings, specifications, calculations, et.:) that were to be monitored. It caused additional effort to be applied to completed work, as well as to inprocess work. It required preparation of a list of potential monitoring subjects to be developed from the Quality Assurance Program elements and it required the preparation of checklists which were extracted from the various project procedures and manuals. The revised monitoring activity has enabled a more thorough assessment of the Quality Assurance Program, and permitted the early identification and correction of potential problems before they could become repetitive. The first year of activity following the amended procedure resulted in the performance cf over 300 combined monitoring and project audit activities with 76 findings, as compared to the performance of approximately 100 combined monitoriag and project audit activities with 42 findings performed during the previous year. 1339 008 23-63 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3) [50.54(f)] 4.2.6 Quality Assurance Engineering Staffing Levels The site Bechtel Quality Assurance staffing level was increased from five to eight during 1977 to 1979 to accomodate the increase in the number of aforementioned monitors and to be responsive in resolving CPCo overview findings. 1339 009 23-64 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3) [50. 54 ( f) ] 4.2.7 Bechtel Quality Assurance Management Audits In an effort to better assess the effectiveness of the Quality Assurance Program requirements, the number of Quality Assurance mana ement audits was increased from one to two per year. 1339 010 23-65 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3) [50.54(f)] 4.2.8 Bechtel Quality Trending Activity The Bechtel quality trending activity, as described in Procedure C-101, was put into effect in July 1976 as a Quality Assurance Program improvement. Trending provides a working tool for Quality Assurance Engineering and its output is used to identify repetitive nonconformances requiring more effective corrective action. Repetitive nonconformances warranting corrective action are processed to the responsible organizations via a Quality Action Request, corrective actions are negotiated, and Quality Assurance follows up to assure the adequacy and timeliness of the actions. Publishing of quality trend data was initiated in July 1976 in the Monthly Project Quality Assurance Activity Report addressed to Bechtel and CPCo key project personnel. In April 1978, Bechtel Quality Ass 2rance initiated supplementary quidelines for the trending. These guidelines provided criteria for initiating graphic trend charts. Prior to this time, trends were identified and charted based upon the judgement of the reviewer. The nonconformances for approximately 120 repetitive construction processes or portions thereof, are tracked monthly and issued to CPCo and Bechtel Quality Assurance Management. Since April 1978, 14 Quality Action Requests have been issued. As a result of a suggestion made during the NRC's Midterm Inspection of the Midland Project in May 1979, a revision is in process to group certain construction activity and nonconformance categories to provide increased sensitivity. The revision was implemented on a trial basis in September 1979. The revised procedure is scheduled to be issued in November 1979. 1339 011 Revision 4 23-66 11/79

RESPONSE TO QUESTION 23, PART (3)[50.54(f)] 4.2.9 Bechtel Topical Report, BO-TOP-1A In November 1976, in order to update the QA Program from that which was committed to in the PSAR, the Bechtel QA Program was revised to incorporate the Bechtel Topical Report, which committed the project to the following ASCI Standards nd Regulatory Guides: (Only those marked with an ascerisk were a carry over from the e' '.) ANSI Standard Regulatory Guide-Revision Date

 *N45.2-1971                         1.28 - June 7, 1972
 " Quality Assurance Program Requirements for Nuclear Facilities" N45.2.4-1972                        1.30 - August 11, 1972
 " Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Constraction of Nuclear Power Generating Stations" N45.2.1-1972                        1.37 - March 16, 1973
 " Cleaning of Fluid Systems and Associated Components During the Construction Phase of Nuclear Power Plants" N45.2.2-1972                        1.38 - March 16, 1973
 " Packaging, Shipping, Receiving, Storage and Handling of Items for                                 '

Nuclear Power Plants During the Cor;':ruction Phase" N45.2.3-1973 1.39 - March 16, 1973

 " House. keeping During the Construction Phase of Nuclear Power Plants" N101.4-1972                         1.54 - June 1973
 " Quality Assurance for Protective Coatings Applied to Nuclear Facilities" 1339 012 Revision 4 23-67                     11/79

RESPONSE TO QUESTION 23, PART (3)[50.54(f)] N/A 1.55 - June 1973 N45.2.6-1973 1.58 - August 1973 " Qualifications of Inspection, Examination and Testing Personnel for Nuclear Power Plants" N45.2.11-1974 1.64 - Rev. 1, Feb. 1973 " Quality Assurance Requirements for the Design of Nuclear Power Plants" N45.2.10-1973 1.74 - February 1974 " Quality Assurance Terms and Definitions" N45.2.9-1974 1.88 - August 1974 " Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants" N45.2.5-1974 1.94 - April 1975 " Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nucleac Power Plants" N45.2.8-Draft 3, Rev 4 N/A " Supplementary Quality Assurance Requirements for Installat ion, Inspection and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants." N45.2.12-Draft 4, Rev 1 N/A " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants" 1339 013 Revision 4 23-68 11/79

RESPONSE TO QUsSTION 23, PART (3)[50.54(f)] N45.2.13-Draft 3, Rev 3 N/A " Quality Assurance requirements for Control of Procurement of Items and Services for Nuclear Power Plhncs" Examples of implementing procedures that were either originated or revised in response to these QA Program improvements were: MED 2.13 " Project Engineering Team Organization Responsibilities" EDPI 4.55.1 " Project Material Requisitions, Midland Project" FPG-4.00 " Storage and Storage Maintenance of Equipment and Materials" FPG-7.000 " Housekeeping and Cleanliness Control During Construction" PSP-G-7.1 " Documenta tion , Records and Correspondence Control" 1339 014 Revision 4 23-69 11/79

RESPONSE TO QUESTION 23, PART (3)[50.54(f)] 4.2.10 CPCo QA Inspection of Stored Materials As a result of the construction slowdown in 1975, CPCo QA began the inspection of stored materials to assure that those materials were not degraded. Items inspected included NSSS component's, miscellaneous cechanical and electrical equipment, cadweld materials, tendon sheathing and trumplates, reactor building liner plate, carbon steel and stainless steel pipe, rebar, and structural steel. After resumption of normal work activities, these operations were phased out with the exception of surveillance of NSSS storage whirh continued until August 1977. Inspection was dono in accordance with Midland Project QA Procedure M-2 " Surveillance of Material Dur#.ng Pr? longed Storage at the Midland Site." (This procedure no longer exists.) 1339 015 23-70 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3) [50.54(f)] 4.2.11 CPCo Biennial OA Audits CPCo Biennial Audits were instituted in 1976. Audits were performed of the CPCo Design and Construction Nuclear Quality Assurance Program. In 1976, the Biennial Quality Assurance Audit included 24 man-days of audit effort. The audit involved 15 man-days of auditing for adequacy and implementation of the CPCo Quality Assurance Program Procedures (QAPPs) at the CPCo General Office in Jackson, Michigan; and 9 man-days of auditing for the adequacy and implementation of the CPCo QAPPs and Bechtel Nuclear Quality Assurance Manual (NOAM) at the Midland Site. Tha 1978 Biennial Audit included 70 man-days of audit effort. The audit included: 20 man-days nf auditing for adequacy and implementation of the CPCu QAPPS, CPCo QA Jepartment Procedures and the Midland Testing Program Manual Procedures at the CPCo General Office in Jackson, Michigan; 20 man-days of auditing for adequacy and implementation of the Bechtel NQAM, Bechtel Field Procedures and Bechtel QC Notices Manual at Bechtel in han Arbor, Michigan; 5 man-days of auditing for adequacy and implementation of CPCo Department Procedures, including the Midland Management Organization and Service Departments; and 25 man-days of auditing for implementation of these procedures by CPCo,Bechtel, and BcW at the Midland Site. All 1976 cad 1978 Biennial Audit Findings have been closed. 1339 016 23-71 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3)[50.54(f)] 4.2.12 CPCo QA Overview The CPCo QA overview activities started in April 1976 for rebar and in June 1977 for en. beds. For all other

ivil, mechanical, welding, NDE, electrical, and instru-montation and controls, the overview activities started at the end of June 1978 and was fully implemented by the end of March 1979 for activities then in progress.

The overview activities implemented between June 1978 and March 1979 was improved over that which was utilized in 1976 and 1977. The improvement consisted of review of Becthel drawings, specifications, field procedures, and quality control instruction for specificity, and of CPCo QA's utilization of specific overinspection plans. CPCo QA performed overinspection of rebar installation in accor: lance with Midland Project Quality Assurance Procedure M-R, " Inspection of Rebar Placement." From its inception thru December 1978, this overinspection was performed on a 100% basis for Q-listed concrete placements and, thereafter, on less than a 100% basis. Based on CPCo QA records of Bechtel's inspection results and the simplicity of the remaining concrete pours, there was sufficient confidence that 100% overinspection was no longer necessary. CPCo QA performed overinspection of embed installation in 0-listed concrete placements in accordance with Midland Project Quality Assurance Procedure M-12, " Inspection of Embedded Items." From its inception through September 1978, this overinspection was performed on a 100% basis. Based on CPCo QA records of Bechtel's inspection results, there was sufficient confidence to warrant the discontinuance of the overinspection at that time. With regard to mechanical activities, from November 1978 to October 19, 1979, Bechtel completed 1,382 Qu.6.ty Control inspections, whereas in the same time period CPCo QA performed 57 overinspections. Bechtel inspection in the mechanical area was well underway when the CPCo QA overview activity was started, therefore, there was little opportunity for a corresponding CPCo QA overinspection. Thus, there is not a direct correlation between the 1,382 inspections completed by Bechtel from November 1978 to date and the 57 CPCo QA overinspections 23-72 Revision 4 11/79 1339 017

4 RESPONSE TO QUESTION 23, PART (3)[50.54(f)] performed during the same period. Furthermore, the most significant aspects of the mechanical work are the hydrostatic and pneumatic tests. Since October 1977, all of the hydrostatic and pneumatic tests have been witnessed by QA-PE&C. The majority of this effort is not reflected in the CPCo QA overinspection figure of 57 because CPCO Quality Assurance's overinspection of hydrostatic ar.d pneumatic tests are accomplished as a witness point in the Bechtel procedures. With regard to welding, from November 1978 to date, Bechtel completed 5,253 inspections, whereas in the same period CPCo QA performed 56 overinspections. The preceeding discussion regarding the correlation between Bechtel inspection and CPCo overinspection equally. applies to the welding area. Furthermore, for all of Class 1 and Class 2 component and piping welds, radiographic examination is required with minor exceptions and the CPCo QA reviaw of the radiographs has been extensive as indicated below. From June 1978 to the present, Bechtel originated 4951 field radiographs and CPCo QA has reviewed 902. For the same period, B&W originated 304 primary system field radiographs and CPCo QA has reviewed 100%. CPCo QA will continue to review 100% of B&W's field radio-graphs. At present, 1,045 B&W nonprimary system radiographs were made and 670 reviewed. For all other vendors, over 1,560 vendor radiographs received since December 1978 have been reviewed by CPCo QA. The electrical area can be further categorized as indicated in the following paragraphs. For cable tray supports, Bechtel has completed approxi-mately 200 inspections, whereas CPCo QA has performed 13 overinspections. For cable tray installations, Bechtel has completed approximately 200 inspections, whereas CPCo QA has performed 26 overinspections. For conduit, junction boxes, and their supports, Bechtel has completed approximately 500 inspectio" , whereas CPCo QA has performed 26 overinspections. 1339 018 23-73 Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3) (50.54 (f) ] For electrical penetration assemblies, Bechtel has completed 5 inspections, whereas CPCo QA has performed 1 overinspection. For the pulling of power cables, control cables, and instrumeithtion cables, Bechtel has completed approxi-mately 200 inspections, whereas CPCo QA has performed 114 corresponding overinspect4ons (including 20 over-inspections which were acccuplished as part of audits). Of the 114 CPCo QA cable pulling overinspections, 14 were for instrumentation cables. For cable terminations, Bechtel has completed approxi-mately 200 inspections, whereas CPCo QA has performed 153 corresponding overinspections. The higher CPCo QA emphasis on chble pulling in com-parison to cable termination is attributable to the recognition that the cables essentially become inaccessible af ter the pulling, whereas the cable terminations are accessible and any defects are more detectable during checkout and preoperational testing. For equipment installation, Bechtel has completed approximately 24 inspections, whereas CPCo QA has performed 24 cverinspections. For the electrical aspects of I&C, Bechtel has not completed any inspections. Nevertheless, CPCo QA has performed 14 overinspections (the same 14 cable pulling overinspections mentioned above) and 5 instrument overinspections (motor-operated valves that are already included in the 24 overinspections for electrical equipment installation mentioned above). For the mechanical aspects of I&C, the figures are included in the mechanical overinspection figures.

                                                }339 23-74                   Revision 4 11/79

RESPONSE TO QUESTION 23, PART (3) [50.54(f)] SECTION 5.0, ACTION ITEM FOLOW-UP In this table, the action items which provide programmatic and generic corrective actions are arrayed chronologically by scheduled completion dates. The following abPr.viations are used in the table: hA - Not Applicable PE - Project Engineering FE - Field Engineering QC - Quality Control QA - Quality Assurance GT - Geotechnical Service 1339 020 23-75 Revision 4 11/79

ACTION ITE.J PROGRAMMATIC AND GENERIC CORRECTIVE ACTIONS COMMITTED TO IN TIIE RESPONSE TO QUESTION 1, PART (a) AND IN Tile RESPONSE TO QUEETION 23, PARTS (1) AND (2) Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 1 Consultant reports other than Dames & Moore were considered in accordance with the guidelines provided in NRC Regulatory Guide 1.70, Revision

2. Consultant reports were not attached to the PSAR, but portions of consultant reports were extracted and incorporated into the FSAR text itself. Those portions incorporated into the FSAR become commitments. Therefore, disposition of recommendations in consulting reports has o been adequately accounted for in the prepara-y tion of the FSAR.

w Verification that those portions of consultant reports determined to be commitments and incorporated into the FSAR have been adequately reflected in project design documents is being accomplished via the FSAR rereview program described in the response to Question 23, Part (2). The two Bechtel QA audit findings reported in PE - Complete our April 24, 1979, response (Paragraph D.1, Page I-8) have been closed out. The results of this audit are being utilized in the FSAR

     ~"

em control system study committed to in Subsection [j 3.3 of this response to Part (1).

 $         (Question 1, Appendix I, Section D.1, Page I-8 0 cc)      Question 23, Subsection 3.1, Page 7) a r0

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 2 On April 3, 1979, Midland Project Engineering PE - Complete Group Supervisors in all disciplines were reinstructed that the only procedurally correct methods of implementing specification changes are through the use of specification revisions or Specification Change Notices. This was followed by an interoffice memorandum from the Project Engineer to all Engineering Group Supervisors on April 12, 1979. (Question 23, Subsection 3.2, Page 8; and y Subsection 3.9, Page 24) w 1 3 Engineering Department Project Instruction PE - Complete 4 4.49.1 was revised in Revision 2 to state, "Under no circumstances will interoffice memoranda, memoranda, telexes, TWXs, etc be used to change the requirements of a specification." (Question 23, Subsection 3.2, Page 9, and Subsection 3.9, Page 24) y@ LA s< so 4 Y-H. C:) O Ps) N u

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 4 A review of interof fice memoranda, metaoranda, telexes, TWXs, and other correspondence relating to specifications for construction and selacted procurements of Q-listed items will be initiated. The purpose of the review will be to identify any clarifications which might reasonably have been interpreted as modifying a specification requirement and for which the specification itself was not formally changed. An evaluation will be made to determine the effect on the technical acceptability, safety implications of the potential specification modification, and any work that has been or may be affected. U If it is determined that the interpretation 4 may have affected any completed work or future w work, a formal change will be issued and remedial action necessary for product quality will be taxen in accordance with approved procedures.

               - The foregoing procedure will be followed for all specifications applying to construction of 0-Listed items.

u (g For specifications concerning the procurement sc) of Q-Listed items, the foregoing procedure will be implemented on a random sampling basis. PE - Complete em cc) The sample size has been established and the (@ wr Ps) LA specification selected has been made. em

r. (21) Review and acceptance criteria for the specifi- PE 11/30/79 0 cations will be defined by November 30, 1979.

(47) The review of construction and selected PE 10/80 procurement specifications is scheduled to be completed by October 1980.

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 4 If the acceptance criteria are not met, the (con't) review will be expanded to include other specifications for 0-listed items. At that time, a revised completion date will be established. (Question 23, Subsection 3.2, Page 9, and Subsection 3.9, Page 25) 5 A study was completed which examined current PE - Complete current procedures and practices for the preparction and control of the PSAR in view of these experiences. Procedural u changes will be initiated by the revision of or y addition to the Engineering Department 4 Procedures. This action is scheduled to be completed by January 31, 1980. (Question 23, Subsection 3.3, Page 11) 6 An interoffice memorandum dated April 12, 1979, GT - Complete was issued by Geotechnical Services to alert personnel of the need to revise or annotate

               'alculations to reflect carrent design status.

(Questfon 23, Subsection 3.4, Page 13) 7 Field Instruction FIC 1.100, "Q-Listed Soils FE - Complete [$ Placement Job Responsibilities Matrix," has been Dj. prepared and establishes responsibilities for em ._. performing soils placement and compaction. o (#4 D (Question 23, Subsection 3.6, Page 18; L3 A so Subsection 3.7, Page 20; and Subsection 3.11, Page 30) CD N Ju

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 8 Construction specifications, instructions, and FE - Complete procedures were reviewed to identify any other equipment requiring qualification which had not yet been qualified. No such equipment was id e n ti f ied . (Question 1, Appendix I, Section D.2.e, Page I-8 Question 23, Subsection 3.6, Page 18) 9 A dimensional tolerance study was completed PE - Complete using the reactor building spray pump and ancillary system as the study mechanism. (Question 1, Appendix I, Section D.2.b, Page I-8) U 10 Engineering reviewed specifications not PE - Complete

  $          previously reviewed for the specificity or tolerance studies (Question 1, Appendix  I,  Section D.2.c, Page I-8) 11  A specific review of the FSAR and specification           PE          -

Complete requirements for the qualification of electrical and mechanical components has been made as part of the corrective action relating to CPCo's 50.55(e) report on component qualification. (Question 1, Appendix, I, Section D.2.e, Page I-8) [g " 12 Quality Assurance will schedule yearly audits QA - Complete N< l'd of the design calculational process for techni d7 j ques and actual analysis, in each of the design g disciplines. D CD u rs) (Question 1, Appendix I, Section D.4, Page I-8) tri

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 13 Audits of ITT Grinnell hanger design and CPCo QA - Complete relay setting calculation have been conducted. (Question 1, Appendix I, Section D.4, Page I-8) 14 Bechtel Project Engineering will review design PE - Complete drawings for cases where ducts penetrate vertically through foundations. The possibility of the duct being enlarged over the design requirements and the effect this enlargement may have upon the structure's behavior will be evaluated by June 1, 1979. Proper remedial measures will be taken if the investigation w shows potential problems, w I m (Question 1, Appendix I, Section C.S.b, Page I-7) 15 An in-depth aud it of U.S. Testing operations, QA - Complete covering testing and implementation of their QA program will be conducted in late April or early May 1979, by Bechtel Project QA and Engineering. (Question 1, Appendix I, Section C.4.b, Page I-18; and Section D.3.c, Page I-18) 16 An in-depth training session will be given to QA - Complete Midland QA Engineers covering the cettlement problem and methods to ider.tify similar sx cond itions in the future. (@ - gg t3: (Question 1, Appendix I, Section D.l.b, Page I-22) r tea Q NO

 ~   c3 N

ON

Action Action Item Scheduled Actual Item Description Responsible Completion Completion 11 umber and Reference Organization Date Date 17 An in-depth training session will be given to QA - Complete all CPCo and Bechtel QA Engineers and Auditors to increase their awareness of the settlement problem and discuss auditing and monitoring techniques to increase audit ef fectiveness. (Question 1, Appendix I, Section D.2, Page I-22) 18 An in-depth review,of the Bechtel trend QA - Complete program data will be undertaken by Bechtel QA management to assure the identification of any other similar areas that were not analyzed in suf ficient depth in the past reviews. (Question 3, Appendix I, Section D.l.a, Page I-22) 19 Quality (,ntrol Instructions will be evaluated OC - Complete to ensure that the documentation characteristics which are to be inspected (i.e., review callouts) are clearly specified. (Question 1, Appendix I, Section D.3.a, Page I-18) 20 Field Instruction 1.100 will be supplemented FE 11/15/79 by establishing requirements for demonstrating equipment capability, includ ing responsibility _,. for equipment approval, and providing records

      ,y            identifying this capability.

LA gm e3 (Question 23, Subsection 3.6, Page 18) wa Dih. 23 21 See Action Item Number 4 PE 11/30/79 em , ns) o ~4 D 4

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 22 Guidelines for surveillance of testing opcrations PE/GT 11/30/79 will be developed and included in Field In-structions for the casite Soils Engineer. Engineering /Geotechnical Services will develop the guidelines by November 30, 1979. (Question 23, Subsection 3.10, Page 27) 23 Engineering will revise Engineering Depart- PE 12/1/79 ment Procedure 4.22 by December 1, 1979, to clarify that Engineering personnel preparing the FSAR will follow the requirements of g Regulatory Guide 1.70, Revision 2, " Standard y Format and Content of Safety Analysis Reports m for Nuclear Power Plants" (September 1975). Gpecifically, Regulatory Guide 1.70 (Pages iv and v of the Introduction) requires that such consul-tant reports only be referenced with the applicable commitments and supporting informa-tion included in the text ( third paragraph, Page v). Such a requirement would preclude repetition of this circumstance. (Question 23, Subsection 3.1, Page 7) 24 To preclude any future inconsistencies between PE 12/1/79 the FSAR and specifications, Engineering Depart-ment Project Instruction 4.1.1 will be revised to state that all specification changes, rather sw _. than just " major changes," will be reviewed for (@ ta consistency with the FSAR. dbI d r o l'o s (Question 23, Subsection 3.3, Page 11) CJ

   +   r0 00

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Orcanization Date Date 25 Quality Assurance will issue a nuclear Quality QA 12/14/79 Assurance Manual amendment to clarify the requirement that procedures include measures for qualifying equipment number specified conditions. (Question 23, Subsection 3.6, Page 18) 26 In view of Action Item 6, Geotechnical Services GT 12/31/79 will revise Procedure FP-6437 by December 31, 1979, to require that calculations be annotated to reflect current design status. (Question 23, Subsection 3.4, Page 13) u 27 Engineering Department Procedure 4.37 will also PE 12/31/79 y be revised by December 31, 1979, to require that m calculations be annotated to reflect current design status. (Question 23, Subsection 3.4, Page 13) 28 Civil / Structural Design Criteria 7220-C-501 PE 12/31/79 will be modified to contain the requirements that a duct bank penetration shall be designed to eliminate the possibility of the nonspecific size duct interacting with the structures. (Question 23, subsection 3.5, Page 15) [$ 29 The civil standard detail drawings will be revised PE 12/31/79 h$ em -- to include a detail showing horizontal and vertical clearance requirements for duct bank E tea penetrations. The detail will address any mud 3 te4 mat restrictions. u %C) (Question 23, Subsection 3.5, Page 15)

         )

rs) W

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 30 Engineering and Construction will revise or PE 12/31/79 (39) prepare procedures governing the placement and compaction of soils and implementing the require-ments of the Nuclear Qut.lity Assurance Manual as stated in Action Item 2!. (Question 23, Subsection 3.6, Page 18) 31 Design documents, instrictions, and procedures PE 12/31/79 for those activities requiring inprocess controls will be reviewed to ass (ss the adequacy of existing procedural controls and technical direction. Engineering review is scheduled for completion by December 31, 1979. (Question 1, Appendix I, Section Dc2, Page I-ll; and m Question 23, Subsection 3.7, Page 20; and Subsection 3.11, Page 30) 32 Guidelines for surveillance of testing operations will be developed and included in Field Instructions tor the onsite Soils Engineer. Engineering / Geotechnical Services will develop the guidelines by November 30, 1979, and Field Engineering will FE 12/31/79 prepare the instructions by December 31, 1979. (Question 23, Subsection 3.10, Page 27) 33 The Quality Assurance audit and monitoring program QA 12/31/79 will be revised to emphasize and increase attention [@ to the need for evaluating policy and procedural N< adequacy and assessment of product quality. A d EI p {]

    , ,a specialized audit training program will be developed and implemented to ensure guidance for a so       this revised approach, u

cc) (Question 23, Subsection 3.13, Page 35) w CD

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 34 Control Document SP/ PSP G-6.1 will be revised OC 1/24/80 to provide requirements for inspection planning specificity and for the utilization of scientific sampling rather than percentage sampling. (Question 1, Appendix I, Section D.S.f, Page I-20; and Question 23, Subsection 3.8, Page 22; and Subsection 3.9, Page 24) 35 Control documents: SP/ PSP G-3.2, " Control of Nonconforming Items" QC 1/24/80 36 QADP C-101, " Project Quality Assurance Trend QA 1/24/80 Analysis w 1 m are in the process of being revised to provide an improved definition of implementing require-ments for identifying repetitive nonconforming conditions. (Question 23, Subsection 3.12, Page 33) 37 Consistent with the intent of Action Item Numbers QA 1/24/80 35 and 36, Quality Assurance will review nonconformance reports which are open, or will become open between this time and January 23, 1980. This review will be to identify any repetitive nonconforming conditions pertaining to product type or activity, or pertaining to em LN nonconformance cause. )?.

• m L^'

      'O       (Question 23, Subsection 3.12, Page 33)

O CD kb2

    ~%

e

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 38 A study was completed by October 31, 1979, to examine current procedures and practices for the preparation and control of the PSAR in view of these experiences. Procedural changes will PE 1/31/80 be initiated by the revision of or addition to the Engineering Department Procedures. (Question 23, Subsection 3.3, Page 11) 39 Engineering and Construction will revise or FE 1/31/80 (30) prepare procedures governing the placement and compaction of soils and implementing the requirements of the Nuclear Quality Assurance Manual as stated in Action Item 25. U g (Question 23, Subsection 3.6, Page 18) a 40 Design documents, instructions, and procedures for those activities requiring inprocess controls will be reviewed to assess the adequacy of existing procedural controls and technical (31) direction. Engineering review is scheduled for completion by December 31, 1979, and Field FE & QC 1/31/80 Engineering and Quality Control review is scheduled for completion by January 31, 1980. (Question 1, Appendix I, Section D.2, Page I-ll; Question 23, Subsection 3.7, Page 20, and Subsection 3.11, Page 30) N 33 -m ens o les D %O k O L+s FN)

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 41 QCIs in use will be reviewed to ascertain that QC 3/8/80 provisions have been included consistent with the revised control document, SF/ PSP G-6.1,

                " Quality Control Inspection Plans."

(Question 1, Appendix I, Section D.1, Page I-18; Question 23, Subsection 3.8, Page 22; and Subsection 3.9, Page 24) 42 Design documents, instructions, and procedurc; for those activities requiring inprocess controls will be reviewed to assess the adequacy of existing procedural controls and technical (31) direction. Engineering review is ccheduled for U completion by December 31, 1979, and Field 1 (40) Engineering and Quality Control review is m scheduled for completion by January 31, 1980. PE, FE & QC 3/14/80 Any revisions required will be completed by March 14, 1980. (Question 1, Appendix I, Section D.2, Page I-ll; . Question 23, Subsection. 3.7, Page 20; and Subsection 3.11, Page 30) 43 The impact of Action Item 41 on completed work QC 5/23/80 will be evaluated, and ocpropriate actions will be taken as necessary. (Question 23, Subsection 3.'8, Page 22; and {} Subsection 3.9, Page 25) d$ ) 44 FSAR sections are being rereviewed as discussed PE 7/80

  $             in the Response to Question 23, Part (2).

U CD u tra (Question 23, Subsection 3.1, Page 7; and tr4 Subsection 3.3, Page 11)

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Date Date 45 U.S. Testing will be required to demonstrate to PE 10/1/80 the cognizant Engineering Representative that testing procedures, equipment, and personnel used for quality verification testing (for other than NDE and soils) were, and are, capable of providing accurate test results in accordance with the requirements of applicable design documents. (Question 3, Appendix I, Section D.3.b, Page I-18; Question .3, Subsection 3.10, Page 27; and Subsection 3.11, Page 31) 46 A sampling of U.S. Testing's test reports (for PE 10/1/80 y other than NDE and soils) will be reviewed by the a cognizant Engineering Representative to ascertain

  @            that results evidence conformance to testing requirements and design document limits.

(Question 23, Subsection 3.10, Page 28; and Subsection 3.11, Page 31) 47 See Action Item Number 4 PE 10/80 48 CPCo will implement overinspection for soils CPCo-QA - Complete placement, utilizing a specific overinspection plan. (Question 1, Appendix I, Section C.2.b, Page I-ll; and gg Section C.l.c, Page I-16) Hm

• 2iN J 49 CPCo will perform overinspection of the U.S. CPCo-QA NA NA
• $o J Testing soils testing activities and reports, utilizing a specific overinspection plan.

  *            (Question 1, Append ix I, Section C.3.c, Page I-17) l

Action Action Item Scheduled Actual Item Description Responsible Completion Completion Number and Reference Organization Data Date 50 CPCo Project Management and QA review field QC NA NA procedures (new and revised) and CPCo QA reviews QCIs (new and revised) in line with Bechtel before release. (Question 1, Appendix I, Section D.S.b, Page I-19) 51 In 1978, CPCo implemented nn overinspection plan CPCo-QA NA NA to independently verify the adequacy of con-struction and the Bechtel inspection process, with the exception of civil activities. Re-inforcing steel and embeds were covered in the overinspection. u (Question 1, Appendix I, Section D.5.c, Page I-19) o 52 CPCo reviews onsite subcontractor QA manuals CPCo-OA NA NA and covers their work in the audit process. (Question 1, Appendix I, Section D.S.d, Page I-19) 53 An ongoing effort is improving the " surveillance" QC NA NA mode called for in the QCIs by causing more specific accountability as to what character-istics are inspected on what specific hardware and in some cases changing "surve llance" to i

             " inspection.
       ,j    (Question 1, Appendix  I, Section D.S.e, Page I-19) er s<
      -o Q      b H-   tel O    LJi u

RESPONSE TO QUESTION 23, PART (4) 1339 036 Revision 4 11/79

RESPONSE 'IO QUESTICH 23, PARP (4) [50.54 (f)] SECTICU 1.0, NBC QUESTION SUPPIDENIAL mT ER ADDITIClaL SOILS SITILEMENT INMRMATICE

23. We have reviewed your response to questicn 1 of our March 21, 1979 letter, "10 TR 50.54 Bequest Bagardity Plant Fill," 4ebviing related aamaskaisnts or supplements in your letters dated May 31, July 9, and August 10, 1979. We find that the infcnnation provided is not sufficiant far ccrupletion of our review. Accordingly, provide the following additional information:

(4) cnnaidaring the results of your investigaticn requested in our question 1c, question Id asked that you describe your position as to the overall effectiveness of the QA swimu for the Midland Plant. Your overall assessment of the effectiveness of your s wima shouhi be based on your revised response to our question 1c (see above question 23(3)) . The results of this assessment, including a description of the scope and extent of the assessnent effort arrl the identification ad qm14F4 cations of the indivMs'la involved in this assessment, should bo twM to us. 1339 037 23-91 Revision 4 11/79

RESPONSE TO QUESTION 23, PART 4 [50. 54 ( f) ] SECTION 2.0 ASSESSMENT In providing our ocsessment . tr effectiveness of the Quality Assurance Proor 4, first . should be noted that:

a. There are signit ean* differences between soils work and sther werk;

b. From the outset of the project, a Quality Assurance Program has been implemented which meets regulatory requirements and national standards;

c. The Quality Assurance Program has been improved significantly from its initial implementation;

d. Appropriate programmat. , and generic corrective actions have been or are being Laken as a result of this investigation;

e. The Quality Assurance Program has baen subjected to frequent and extensive external evaluations and our responses to the findings from these evaluations have been timely and adequate; and

f. The diesel generator building settlement was detected, at the outset of the settlement, by the Quality Assurance Program.

Based on the major coints listed above (and on a number of lesser points which are not enumerated here), we are confident that the Quality Assurance Program has been and will continue to be effective. From its complexity and extensiveness, the reader may recognize that literally thousands of hours went into the preparation of the investigative response and assessment. The following organizations and their managers participated extensively in this investigation: Bechtel Quality Assurance, Quality Control, Project Management, Project Engineering, Engineering, and Construction; CPCo Quality Assurance, Project Management, and Project Engineering Services; and U.S. Testing Quality Assurance. In addition, there was extensive personal participation by the appropriate officers of each company. 1339 038 23-92 Revision 4 11/79

                                                                     .}}