ML19347A654

Testimony of RA Rohrbacher (AEC) Re Facility Const QA Program

ML19347A654
Person / Time
Site:	Midland
Issue date:	06/28/1974
From:	Rohrbacher R US ATOMIC ENERGY COMMISSION (AEC)
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Text

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Testitieny on Facility Construction - Quality Asnurance Pronrans y

Midland Plant. Units 1 and 2 By i

Roger A. Rohrbacher I.,

INTRODUCTION I am presently employed as a reactor inspector in the Reactor Con-struction Branch of Region III, Regulatory Operations, U. S. AEC.

I am responsible for the reactor plant inspection program activities assigned to me.

In regard to the Midland Plant, I have been actively involved in the RO:III inspection program since being assigned principal inspector for this f acility in latri 1972.

From February 1973 through early March 1974, I conducted and/or participated'in eight inspections at the Midland Plant construction site and three inspections at the corporate offices of the Consumers Power Company.

(Additional follow-up inspections and meetings with Consumers Power Company management p,ersonnel are included as part o'f some of the above inspections.)

1 A basic philosophy of Regulatory Operations' inspections of reactor facilities under construction is to assure that the licensee (and his contractors, vendors, etc.) has an effective and working quality assurance program to provide reasonable assurance that the facility has been constructed in accordanct

'th applicable requirements.

Consequently, a primary objective of t'he RO inspection program is to establish that construction activities are in accord with an adequate quality assurance progrca,_as well as other applicable y soorsugf /

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(requirements 1 relative to~ structures, components, andlsyste'ms that

. prevent o'r mitigate'theLconsequences.of postulated accidents that'cou'1d' e'u:idue! risk to the health and safety 'of the general public.

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This' objective cis ? achieved by a review of quality assurance programs,

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iguality; control procedures, other quality records, review of con-t

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-struction records,' interviews with plant personnel, and observations

-at-the construction site.

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LII.- INSPECTION' ACTIVITIES FROM JUNE 26,1973. TO NOVEMBER 5,1973 -

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_On December 15, 19'72,-' the AEC. issued Construction Permits-No.

CPPR-81.'and No.-CPPR-82 to Consumers Power Company, authorizing-construction.of-two pressurized water nuclear reactors designated.

as the' Midland-Plant,; Units ~1 and 2.

, During June'1973,JIl conducted'a site: inspection to review and

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' observe. preconstruction activities.

These activities included

.. removal of temporary, protective' coverings and enclosures from p

existing-struc'tures, initiation of evaluation.of st'ored components-

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and materials, and work relative to the restart of construction-n l

. activities. 1(RO : Inspection, Reports No.' 050-329/73-05 and No.

L 050-330/73-05)

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AnEinspection of the Architect-Engineer (Bechtel Corporation)

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relativeito design and procurement activities'for the Midland s

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Plant, was: con' ducted in September 1973 by'T. E. Vandel and

';MLq W.':lDickerson. -Ce'rtain~violationsEof-AEC rules'and regulations ~

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i iwerezidentified during this inspection.

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.L(R0 Inspection' Reports :-

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. nom 050-329/73-0'8. andNo.'LO50-330/73-08d;Thesubsequent,.

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' corrective: action' measures proposed,~ relative to

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y theseLviolat' ions, were c'onsidered adequate.

Implementation'of

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these measures 'is continuing in a:' satisfactory manner.

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' In' spec tion l Rep. orts i o. 050-329/74-01 and No.'050-330/74-01)

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INSPECTION ACTIVITIES SUBSEQUENT TO NOVEMBER 5,-1973-i-..

-During 'a routlne R0:III construction site inspection, conducted 'by C. C. Williams and-myself.on November 6

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1973, apparent viola-

-tions relatedi o activities associated with Cadweld' splicing of t

reinforcing steel"were[ identified. As a result of this matter 4.

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and-discussions between Consumers Power Company and RO:III

' personnel following this' inspection; Cons'umers Power Company

. suspended Cadwalding operations l at the site on-November. 9,1973.

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-RO:III. informed Consumers Power Company that' Cadwelding should-not be. resumed until. all Texisting Cadweld splices had been 2

reinspected and requalified-by properly trained personnel and, in addition, a determination by RO:III that an acceptable program

_for Cadwelding activities had been developed and implemented.

l I conducted:a special~ inspection at'the Midland Plant construction site 1on' November-15, 1973, to determine the' scope and adequacy of l

the;Cadweld reinspection program. At the conclusion of:the f

tinspectio'n, it vas' determined;that':.-(1)' adequate cleaning of'

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Cadwelds.had been completed prior.to, reinspection,_ (2) adequate

procedures, techniques, and tools;were being utilized, (3) Cadweld i

' inspectors were adequately-trained and competent, and (4) important at quality. aspects' for each Cadweld vere determined and recorded: con--

currentwishinspection,q(RO.Inspectiod.ReportsUo.. 050-329/73410-j andlNo 050-330/73-10l _ Attachment A)

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On November 16,11973,svia teleph'one, Consumers Power Company f(H M Slager'and G. S.'keeley,'part" time) informed me that-Consumers Power Company expected to be' ready for a reinspection-s A

-by RO:III on November.20, 1973.

(On.several. occasions,. November l16throughNovember 19,.1973, itelephone conversations took place

= on this subj ect between Consumers Power Company and.RO:III u

personnel.)

'RO:III scheduled'a follow-up inspection for November 20 and 21, 1973.: I participated in this special' inspection,-which was to determine the adequacy of corrective action relative to deficiencies in Cadwelding activities and the apparent lack of management involve-ment in the implementation of the Midland Plant quality' assurance program. The results of the inspection estabiished that, although corrective action was substantial,-it was noc adequate' relative to the above two matters.. Consumers Power Ccmpany was informed, at

the, conclusion of the inspection, that Cadwelding should remain suspended pending additional' corrective-action and review of this

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corrective action-by RO:III.

(R0' Inspection Reports No.

,050-329/73-10 and No.-050-330/73-10, Attachment B)

' Subsequent' toL notification from _Ccnoumers Power Company that s

corrective action, relative to the Cadweld matter, had been

{ completed,.a'specialLinspection was scheduled.

I participated i.

in this' inspection '(conducted at the construction, site on'Decemberf

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6-and 7,31973) to' determine'the status of the licensee's corrective s

Laction relative /to specific Cadweldingl violations and. quality

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> -.h s 'ssurance/qualitiy' controlf program deficiencies previously a

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' identified ~inJconjunction.with Cadwelding(activities.-'It=was.

' th'4 opinion'. of( the :RO:III: inspection' team (W. E. Veti., R. A.

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Rohrbacher, -C. C. : Williams, and D. ' E. Whitesell) based on-the-1

results of this ~~1rispection, that the corrective action relative

to-Cadwelding violations'and deficiencies were adequate a'd'-that-n Cadwelding.at th'e site could-be resumed.with reasonable assurance that'such activities would be' fully consistent with appl'icable

' quality [ criteria. ' Moreover, - the corrective action relative to

..ConsumersTPower Company ma'nagement response to quality assurance.

program shortcomings was considered to be adequate. '(R0 2

-Inspection Reports No. 050-329//3-11 and No. 050-330/73-11)

On January 10:and 11,.1974, I participated in a special, unannounced inspection at the Midland Plant construction site. The prinary-purpose of this inspection was to determine the adequacy.of

- implementation of the ;correctiv'e action previously: committed to z

by the licensee! relative to specific. violations and'to quality

. assurance / quality control-deficiencies identified in conjunction with Cadwelding activities and-.in conjunction with design and :

procurement' activities of the architect-engineer (Bechtel Corporation).

. w Thefinspection team determined that the current implementatio'n of-

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EcorrectivC actionfmeasures', relative to the above matters, was Ladequate. L(R0' Inspection' Reports;No..050-329/74-01 and No.

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5-2 The' licensee initiated a number of' corrective action: measures

_ rela'tive 'to ' quality. assurance / quality control deficiencies -

C Iideniified:by RO:III during the.latter part of 1973.

These Jcommitments and, their. implementation are included in RO Inspection

' Reports No. 050-329/73 -11. and No. 050-330/73-11, No. - 050-329/74-01.

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' and 050-330/74-01, and No. 050-329/74-03 and No'. 050-330/74-03.

'I was involved with the following corrective action measures and' their implementation during recent RO:III inspections at the

Midland Plant construction site.

A.' Consumers Power Company to provide a master _ schedule of Consumers

- Power Company quality assurance construction site audit activities and field audit procedures'to be used for these audits.

I reviewed the Consumers Power Company quality assurance site audit activities schedule (Field' Audit Program) at the rite on February 6, 1974.

I observed that-it was approved by the Consumers Power Company quality assurance administrator on January 15, 1974, and that it was adequate and current.

In regard to field audit procedure *s, I reviewed the new format and arrangement of the Consumers Power Company quality assurance field audit procedures on February.6, 1974.

I observed that

-these.new; procedures _(which replace similar individual procedures

. previou' ly)' developed by Consumers Power Company) are -included in-s Section 12.0 of.the Consumers Power Company Quality Assurance Services Procedures Manual.(QAS-PM).

This section was approved

by the-director.of Quality Assurance Services on February 1, L1974.

I concluded that procedures included and/or required by.

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-Section-12.0 of,the Quality Assurance Services Procedures Manual' tolbe-adequate:for Consumers Powerl ompany quality assurance field j

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. Consumers Power CompanyLquality assurancefpersonnel to be' satis-

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with Bechtelt Corporationf efforts to requalify: existing

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J' Ca'ddeld splices ~ at -ths, Midland' Plant' site;

.I reviewed'a consumers

' Power. Company letter, R.' E. Whitaker to S. H. Howell, "Requalifica-

. tion ofx cadweld Splices", dated November:30,1973. ~ This_ letter

. identifies _theisteps taken by Consumers _ Power Company quality.

_ assurance to. verify the adequacy of - th'e Bechtel Corporation -

reinspection activity. and confirms the adequacy of the reinspec-tion. During the January-10,.1974, R0:III inspection, I selectively; examined the Bechtel; Corporation'Cadweld. reinspection records and

-discussed the matter-with Bechtel. Corporation personnel to verify,

.forRO:III,the:adequacyoflthe.reinspectioneffort.

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Consumers Power Company. quality _ assurance' personnel to review Bechtel Corporation Cadialding work.and quality control procedures.

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During the January 10,-1974, inspection, I determined that

. Consumers Power Company quality assurance personnel-at the-Midland Plant; site.had reviewed the'following.Cadwelding work U

andrquality control-procedures,and had no adverse comment:

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Bechtel Specification No. 7220-C-231, Section 10, Revision 4.

j2. fEechtc1' Field Inspection Manual.

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Bechtel Quality. Control. Procedure No. C-231-1, Revision'2.

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Bechtel11nspection' Plan C-231-1 TCadweld), Revision 6.

.5.--Erico Manual-RB5M 768..

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Bechtel_Cadweld Rebarz Splicing Instructions.for the.

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Opera' tor,. Revision 1..

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c1 I D.L. Inspection' plans,ideveloped by Bechtel Corporation, are to_be lsen't'to Consumers Power Company quality assurance for~ review.

lFrom a review'of records:and-discussions.with site personnel on March :7, '1974, ILestablished that about twenty Bechtel'

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/ Corporation inspect 1o'n plans for the Midland facility had been-

-received and: reviewed-by. Consumers Power Company and returned

to Bechtel' Corporation _with' comments,Jprior to March 1, 1974.

At the time of this inspection (March 7, 1974) resolution of comments between Consumers Power' Company and-Bechtel Corporation personnel. relative to these inspection-plans, was in progress'.

E. -Consumers Power Company agreed to initiate a more formal training program for their quality assurance personnel.

From a review of records and from discussions with Consumers Power Company personnel during site inspections, I determined that Consumers Power Co=pany did establish'such a program in December 19h and

'that.all four Consumer. Power Company site quality assurance personnel,-among.others, attended the first (January 3'and14, 1974). and second (February 'll - 14, 1974) sessions. The training.

program-is continuing,-and'.additio'nal. sessions are scheduled.

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Complete'(Bechtel Corporation) procedure revisions for Cadwelding activities.- The tollowing' documents were revised by Bechtel' Corporation:and; reviewed:by me-to verify their adequacy.

1.' ; Sect: ion 10, Mechanical -Splicing of ' Reinforcing Bars, of ~

.Bechtel: Specification No. 7220-C-231(Q), ~ Technical Specifica-tions-for Forming, Placing, Finishing, and Curing.of Concrete, Revision No. 4, November.14,' 1973.

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2. - Bech" el; Quality Control Procedure No. C-231-1, Inspection.

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3. - TCadweld: Inspection and Test Report, Form QC (Cadwelds),

?. Revision No. 1, November 29,.1973.

a GJ. Provide adequate procedures for Cadweld splice inspection.. I

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reviewed'the revised'(Bechtel Corporation) proceduresLand-discussedEthis' matter,with Consumers Power Company and Bechtel Corporation personnel at the site.

I established that the following-documents were adequate relative to Cadweld splice

' inspection:

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Bechtel' Quality Control Procedure No. C-231-1, Inspection-of Cadweld Mechanical' Splicing of Concrete Reinforcing Steel, Revision'2, dated December 6,'1973.

-2. Bechtel Quality Control Inspection Plan No.-C-231-l'

'(Cadweld)', Revision-6, dated Decenberi5, 1973.

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Bechtel Form QC (Cadwelds), Re' vision-1, datied November 29, 1973, which is used in conjunction ~with. Inspection Plan ~ No.

C-221-1.

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Cadweld inspection ~ records are to provide evidence that Cadweld splices conform to quality requirements and provide' adequate visibility.of' inspection results.

I reviewed current Cadweld' inspection records and revised procedures relative to this

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f17 J Bechtel corporation will place'the" Midland Plant: construction-t

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[ ysibe1 estingjlaboratory;under.the1 functional and technical' t

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Froin!discusdon wit h Bechtel personnel and observa-

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Jtions?ati,the' site, I~ determined;that'this commitment was

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implemented,in December A973.-

If J.1 Consthmers Power Company ~ agreed' to. contact firms having quality assurance expertis^e;to determine whether it would-be desirable'

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..to;obtain additional quality assurance pregram viewpoints.

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was: determined,--from a. review of. records'and discussions with u

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' Consumers Power Company personnel,ithat Consumers Pcwer Company _

~had contacted ~four firms relative to'the above matter. In this regard, Consumers Power Company. activated.:antexisting consultant contract with enc NUS Corporativu:Lv review t$a Midland Plant l,

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l-quality assurance-program. This work is nearing' completion,-and.

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. Consumers Powe'r Companyf state'd that they have reviewed and

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_ discussed the preliminary? findings of :the' IMS Corporation; team that conducted this work. =:In addition, Consumers Power Company;

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informed RO:III) thati Consumers Power Company management personnels b"

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_ have contacted and-discussed:the Midland Plant quality' assurance-

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program with'personnelJfrom Grumman Aerospace Corporation, United j Stat s ITestiing ' Company,: and Nuclear Services' Corporation.

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!.The. detail's. off specific RO:IIICinspection results, relative to'

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i Cadudiding ' ac't.ivities and related qualityJ assurance / quality l control L

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. deficiencies,jare? included.in,RO. Inspection Reports-No..050-329/74-01 iand-No.iO50-330/74-01,landNo.~b0-329/7.4-03fandNo.

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050-330/74-03.

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