ML19269F389
| ML19269F389 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/06/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19269F386 | List: |
| References | |
| NUDOCS 7912200648 | |
| Download: ML19269F389 (4) | |
Text
DEC G 1979 Appendix A NOTICE OF VIOLATION Consumers Power Company Docket No. 50-329 Docket No. 50-330 This refers to the investigation conducted by the Office of Inspection and Enforcement at the Midland Nuclear Power Plant, Units 1 and 2, Midland, Michigan, at your offices in Jackson, Michigan, and at Bechtel Corporation, Ann Arbor, Michigan of activities authorized by NRC License No. CPPR-81 and No. CPPR-82.
Based on the results of the investigation conducted during the period December 11, 1978 through January 25, 1979, it appears that certain of your activities were not conducted in full compliance with NRC require-ments as noted below. These items are infractions.
1.
10 CFR 50, Appendix B, Criterion III requires, in part, that measures shall be established and executed to assure that regulatory requirements and the design basis as specified in the license application for structures are correctly translated into specifications, drawings, procedures and instructions.
Also, it provides that measures shall be established for the identification and control of design inter-faces and for coordination among participating design organizations.
CPCo Topical Report CPC-1-A, Policy No. 3, Section 3.4 states, in part, "the assigned lead design group or organization (i.e., the NSSS supplier, A&E supplier, or CPCo) assure that designs and materials are suitable and that they comply with design criteria and regulatory requirements."
CPCo is committed to ANSI N45.2 (1971), Section 4.1, which states, in part, " measures shall be estabiished and documented to assure that the applicable specified design requirements, such as a design basis, regulatory requirements... are correctly translated into specifications,' drawings, procedures, or instructions."
Contrary to the above, measures did not assure that design bases were included in drawings and specifications nor did they provide for the identification and control of design interfaces.
As a result, inconsistencies were identified in the license application and in other design basis documents.
Specific examples are set forth below:
a.
The FSAR is internally inconsistent in that FSAR Figure 2.5-4B indicates settlement of the Diesel Generator Building to be on the order of 3" while FSAR Section 3.8.5.5 (structural accept-ance criteria) indicates settlements on shallow spread footings 2163 299 mec on GM
DEC G 1379 Appenta
<. founded on compacted fill to be on the order of 1/2" or less.
The Diesel Generator Building is supported by a continuous shallow spreai footing.
b.
The design sr.ttlement calculations for the diesel generator and borated water storage tanks were performed on the assumption of uniform mat foundations while these foundations were designed and c m ructed as spread footing foundations.
c.
The settlement calculations for the Diesel Generator Building indicated a load intensity of 3000 PSF while the FSAR, Figure 2.5-47, shows a load intensity of 4000 PSF, as actually constructed.
d.
The settlement calculations for the Dierel Generator Building were based on an index of compressibility of the plant fill between elevations 603 and 634 of 0.001.
These settlement values were shown in FSAR Figure 2.5-48.
However, FSAR, Table 2.5-16, indicates an index of compressibility of the same plant fill to be 0.003.
e.
PSAR, Amendment 3, indicated that if filling and backfilling operations are discontinued during periods of cold weather, all frozen soil would be removed or recompacted prior to the resump-tion of operations. Bechtel specification C-210 does not specif-ically include instructions for removal of frozen / thawed compacted material upon resumption of work after winter periods.
f.
PSAR Amendment 3 indicates that cohesionless soil (sand) would be compacted to 85% relative density according to ASTM D-2049.
However, Bechtel specification C-210, Section 13.7.2 required cohesionless soil to be compacted to not less than 80% relative density.
2.
10 CFR 50, Appendix B, Criterion V requires, in part, that activities affecting quality shall be prescribed and accomplished in accordance with documented instructions, procedures or drawings.
CPCo Topical Report CPC-1-A, Policy No. 5, Section 1.0 states, in part, that, " Instructions for controlling and performing activities affecting quality of equipment or operation during design, construc-tion and operations phase of the nuclear power plant such as procure-ment manufacturing, construction, installation, inspection, testing
... are documented in instructions, procedures, specifications..
. these documents provide qualitative and quanititive acceptance criteria for determining important activities have been satisfactorily accomplished."
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CEC L E5 Appendix A CPCo is commited to ANSI N45.2 (1971), Section 6 which states, in part, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
a.
Contrary tc, the above, instructions provided to field construc-tion for substituting lean concrete for Zone 2 material did not address the differing foundation properties which would result in differential settlement of the Diesel Generator Building.
b.
Also, contrary to the above, certain activities were not accom-plished according to instructions and procedures, in that:
(1) The compaction criteria used for fill material was 20,000 ft-lbs (Bechtel modified proctor test) rather than a compactive energy of 56,000 ft-lbs as specified in Bechtel Specification C-210, Section 13.7.
(2) Soils activities were not accomplished under the continuous supervision of a qualified soils engineer who would perform in place density tests in the compacted fill to verify that all materials are placed and compacted in accordance with specification driteria.
This is required by Bechtel Specification C-501 as well as PSAR, Ameriment 3 (Dames and Moore Report, page 16).
3.
10 CFR 50, Appendix B, Criterion X requires, in part, that a program for inspection of activities affecting quality shall be established and executed to verify conformance with the documented instructions, procedures and drawings for accomplishing the activity.
CPCo Topical Report CPC 1-A, Policy No. 10, Section 3.1, states, in part, that " work activities are accomplished according to approved procedures or instructions which include inspection hold points beyond which work does not proceed until the inspection is complete or written consent for bypassing the inspection has been received from the organization authorized to perform the inspections."
CPCo is commited to ANSI N45.2 (1971), which states, in part, "A program for inspection of activities.affecting quality shall be
~
established and executed by or for the organization performing the activity to verify conformance to the documented instructions, procedures, and drawings for accomplishing the activity."
Contrary to the above, Quality Control Instruction C-1.02, the program for inspection of compacted backfill issued on October 18, 1976, did not provide for inspection hold points to verify that soil work was satisfactorily accomplished according to documented instructions.
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CEC G 1575 Appendix A 4.
10 CFR 50, Appendix B, Criterion XVI requires, in part, that mea-sures shall be established to assure that conditions adverse to quality such as failures, deficiencies, defective material and nonconformances are promptly identified and corrected.
In case of significant conoitions adverse to quality, measures shall assure that corrective action is taken to preclude repetition.
CPCo Topical Report CPC-1-A, Policy No. 16, Section 1.0 states, in part, " corrective action is that action taken to correct and pre-clude recurrence of significant conditions adverse to the quality of items or operations.
Corrective action includes an evaluation of the conditions that led to a nonconformance, the disposition of the nonconformance and completion of the actions necessary to prevent or reduce the possibility of recurrence."
Contrary to the above, measures did not assu e that soils conditions of adverse quality were promptly corrected to preclude repetition.
For example:
a.
As of January 25, 1979, moisture control in fill material had not been established nor adequate direction given to implement this specification requirement.
The finding that the field was not performing moisture control tests as required by specifi-catian C-210 was identified in Quality Action Request 50-40, dated July 22, 1977.
b.
Corrective action regarding nonconformance reports related to plant fill was insufficient or inadequate to preclude repeti-tion as evidenced by repeated deviations from specification requirements.
For example, nonconformance reports No. CPCo QF-29, QF-52, QF-68, QF-147, QF-174, QF-172 and QF-199 contain numberous examples of repeated nonconformances in the same areas of plant fill construction.
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