ML19351G122
| ML19351G122 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/07/1981 |
| From: | Fiorelli G, Gallagher E, Gilray J, Knop R, Landsman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19351G111 | List: |
| References | |
| 50-329-80-32, 50-330-80-33, NUDOCS 8102230150 | |
| Download: ML19351G122 (31) | |
See also: IR 05000329/1980032
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U.S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
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Reports No. 50-329/80-32; 50-330/80-33
Docket Nos. 50-329; 50-330
Licenses No. CPPR-81; CPPR-82
Licensee: Consumers Power Company
1945 West Parnall Road
Jackson, MI 49201
Facility Name: Midland Nuclear Power Plant, Units 1 and 2
Inspection At: Bechtel Power Co., Ann Arbor, Michigan
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Inspection Conducted: December 8-11, 1980
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Inspectors: E
. (al g
r, Region III
R. B. Landsman, Region III
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J. Gi ray NRR Qua ity Assurance Branch
R. C.q'nop, Chiefie d e
Reviewed By:
g 7_ y/
Projects Section No. 1
Approved By:
G. Fiorelli, Chief
Reactor Construction and
Engineering Support Branch
Inspection Summary
Inspection on December 8-11, 1980 (Reports No. 50-329/80-32; 50-330/80-33)
Areas Inspected:
Consumers Power Company response and implementation of
corrective actions regarding the 10 CFR 50.54(f) request of Question 1 of
NRC letter dated March 21, 1979 and Question 23, request for additional
information dated September 11, 1979. The inspection involved 106 inspector-
hours at the Bechtel Ann Arbor office by threc NRC staff.
In addition,
approximately 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of review of the licensee response was performed prior
to the inspection.
Results: Two items of noncompliance were identified in the above areas
inspected - Severity Level IV, Inadequate Design Control with three examples;
Severity Level IV, Inadequate Corrective Action; and Unresolved Items identified
in Paragraph 3(c) and 3(d).
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DETAILS
Exit Meeting Attendees at Ann Arbor, Michigan, December 11, 1980
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Nuclear Regulatory Commission
E. J. Gallagher, Civil Engineer Inspector, IE: Region III
R. B. Landsman, Civil Engineer Inspector, IE: Region III
J. W. Gilray, Quality Assurance Branch, NRR
Consumers Power Company
J. W. Cook, Vice President, Projects, Engineering and Construction
B. W. Marguglio, Director, Environmental Services and Quality Assurance
W. R. Bird, Quality Assurance Manager, Midland Project
D. M. Turnbull, Site Quality Assurance Superintendent
G. R. Eagle, Supervising Quality Assurance Engineer
G. S. Keeley, Midland Project Manager
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G. E. Clyde, Licensing Engineer
H. P. Leonard, Section Head, Quality Assurance Engineer
D. E. Horn, Group Civil Supervisor, Quality Assurance Engineer
Bechtel, Ann Arbor Office
J. Rutgers, Midland Project Manager-
J. Milandin, Manager of Quality Assurance
L. A. Dreisbach, Assistant Project Manager
V. J. Manta, Project Quality Engineer
N. Swanberg, Assistant Project Engineer
G. L. Richardson, Quality Assurance Manager, Midland Project
D. F. Lewis, Licensing Engineer
R. E. Sevo, Quality Assurance Engineer
A. E. Bicc. Quality Assurance Engineer
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R. L. Rixford, Quality Assurance Engineer
J. R. McBride, Quality Engineer
R. C. Hollar, Quality Engineer
1.
Background
Meetings were held on February 23, 1979 and March 5, 1979 at the NRC
Region III office in Glen Ellyn, Illinois to discuss the circumstances
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associated with the settlement of the diesel generator building at
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the Midland facility.
This discussion was part of the investigation
conducted by Region III as documented in NRC Investigation Report
No. 50-329/78-20; 50-330/78-20, dated March 22, 1979. Representatives
of the NRC staff from headquarters attended the meeting on March 5,
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1979. The staff stated that it's concern was not limited to the
narrow scope of the settlement of the diesel generator building, but
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extended to various buildings, utilities and other structures located
in and on the plant area fill.
In addition,_the staff expressed
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concern with the Consumers Power Company Quality Assurance. Program.
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Under the authority of Section 182 of the Atomic Energy Act of 1954,
as amended, and Section 50.54(f) of 10 CFR Part 50, additional in-
formation was requested regarding the adequacy of the fill and the
quality assurance program for the Midland site in order for the
Commission to determine whether enforcement action such as license
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modification, suspension or revocation should be taken. Question 1
of the 50.54(f) letter dateo March 21, 1979 requested information
regarding the quality assurance program. On April 24, 1979,
Consumers Power Company submitted the initial response to the 50.54(f)
request, Questions 1 through 22.
As a result of the NRC staff review
of Question 1, the NRC concluded that.the information provided was not
sufficient for a complete review. Subsequently, on September 11, 1979
the NRC isseed a request for additional quality assurance information
(Question 23). On November 13, 1979, Consumers Power Company submitted
revision 4 to the 50.54(f) responses which included response to Question
23.
As a result of the Region III investigation report and CPC0 responses,
the NRC issued an Order modifying construction Permits No. CPPR-81 and
No. CPPR-82, dated December 6, 1979. The latest revision to Consumers
. Power Company response to the 50.54(f) request is revision 10, dated
November 21, 1980.
2.
Purpose of Inspection
The inspection was conducted at the Bechtel Power Company Ann Arbor,
Michigan offices on December 8-11, 1980 to verify implementation of
the specific commitments and action items reflected in Consumers Power
Company response to 10 CFR 50.54(f) Questions 1 and 23 with the exception
of those areas where completion of commitments has not been satisfied as
of this time.
The inspection was divided into the following areas:
A review of CPCo response to Question 1, Part (a) and Question 23,
a.
Part (1) regarding the identification of the specific quality
assurance deficiencies that contributed to the soils problem,
including the root cause of the deficiency, remedial action in
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the soilr area, the programmatic and . generic corrective actions
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as committed to in the response.
b.
A review of CPCo response to Question 1, Part (b) and Question 23,
Part-(2) regarding the provisions to be implemented to preclude
areas of contradictions between the PSAR, FSAR and design docu-
ments.
A review of CPCo response to Question 1, Part (c) and Question 23,
c.
Part (3) regarding the programmatic and generic' corrective actions
to provide confidence that quality assurance deficiencies do not
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(or will'not) exist in other areas.
The following sections of this report discuss the results of the review
of the above areas of CPCo response to Questions 1 and 23.
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3.
Review of Question 1, Part (a) and Question 23, Part (1)
The identification of quality assurance deficiencies that contributed
to the soils problem was discussed in Question 1, Part (a) and
Question 23, Part (1). Concumers Power Company identified the root
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cause of the deficiencies, the remedial measures in the soils area,
and the programmatic and generic corrective action to preclude further
recurrence of the deficiencies.
CPCo complied a list of specific
action items that would have to be accomplished in order to satisfy
the commitments made in response to Questions 1 and 23 of the 50.54(f)
request.
Attachment No. I provides an action item tracking system which includes
the action item description and reference and the status and documenta-
tion verified by the NRC during this inspection.
Those action items for which CPCo connitments have been accomplished are
identified as being " closed"; items identified as "open" either have not
been completed by CPCo or the action taken was considered insufficient.
Question 1 provided 26 action items of which the NRC verified 18 had
been satisfactorily accomplished while 8 remain open. Question 23
provided 57 action items of which 34 were determined to be satisfac-
torily accomplished while 23 remain open.
The following are NRC findings regading the implementation of certain
CPCo commitments.
a.
Action items 23-5 and 23-38 as identified in Attachment No. 1
provided commitments to examine current procedures and practices
for the preparation and control of the FSAR in view of past
experiences. CPCo committed to procedural changes to existing
engineering department procedures.
Seven Bechtel procedures were examined and revised to clarify
design control procedures for the FSAR. Engineering Department
Procedure Instruction (EDPI) 4.25.1, Design Interface Control,
was revised by Revision 7 by including section 4.2 which states,
"It is the responsibility of the originator of a design document
change to effect coordination of the change with all groups which
reviewed and/or used the original or subsequent revisions of that
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design document."
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Subsequently, Revision 8 to EDPI 4.25.1, changes the above by
adding to the end of the statement, "as determined by the group
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supervisor of the discipline which originated the document." The
originator of Revision 8 stated that the intent was that only
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technical changes have to be interfaced while editorial changes
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would not necessarily require this interface control. The pro-
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cedural change, however, does not reflect the intent and permits
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the group supervisor to waive interface control for any changes
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as evidenced by inspection finding in Paragraph 3(b) of this
report. The engineering procedures EDPI 4.25.1 does not satisfy
CPCo commitment made to the NRC in response to Question 23,
subsection 3.3, page 11 and identified as action item 23-5 of
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Attachment No. 1.
This failure to provide adequate design interface control is
considered contrary to 10 CFR 50, Appendix B, Criterion III as
described in the Notice of Violation.
(50-329/80-32-01; 50-330/
80-33-01).
b.
Engineering Department Procedure Instruction, EDPI 4.25.1,
Section 6.1 requires that, "each originating design group shall
maintain a log of all documents which are routed to personnel
external to the design group. These logs shall be retained .
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providing visibility of the projects design interface control."
It was determined based on a review of specification C-208,
Revision 20, Materials Testing Services, Section 9, Soils Testing
and C-211, Revision 12, Technical Specification for Backfill, that
the civil project engineering group is not maintaining a complete
coordination log of specifications and specification change notices.
Interviews with cognizant Bechtel personnel indicated that it is
up to the originator of the document to transmit the design docu-
ment to the coordinator clerk to log it in as being interfaced
with the appropriate groups.
It was determined from reviewing the
interface log that the originator of the documents are not aware
of this requirement and documents are not being interfaced with
other design groups as required by the procedure. .In addition,
Regulatory Guide 1.64, Quality Assurance Requirements for the
Design of Nuclear Power Plants and ANSI N.45.2.11-1974, Section 10
requires design interface records to be maintained.
This failure to maintain design interface and coordinator control
is considered contrary to 10 CFR 50, Appendix B, Criterion III as
described in the Notice of Violation.
(50-329/80-32-02; 50-330/
80-33-02).
c.
Specification C-208, Revision 10, Section 9 regarding soil testing
requirements was reviewed for technical content. -It was determined
that the specification was not adequate as written. .The following
specific findings were identified.
(1) CPCo was identified in Question 1, Appendix I, Page I-13,
Paragraph A.4(a) that the subcontractors test procedures
for soil testing service were inadequate; specifically,
U. S. Testing procedures did not provide for developing and
updating a family of proctor curves used to compare in place
field density tests to maximum laboratory standards. CPCo
committed to the remedial action on Page I-17, Paragraph 4(a)
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which states, " Selection of proctor curves will no longer be
a problem because each field density test will be accompanied
by a separate laboratory standard compaction test which will
provide a direct comparison." It was also stated that SCN-9004,
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dated April 13, 1979 was issued to require the above.
It was determined that SCN-9004 was issued as committed;
however, during Revision 16, dated August 24, 1979, of
specification C-208, the civil project engineer failed to
include the above requirement and instead revised Table 9-1
to permit the f requency of the laboratory test-to be "as
directed by the on-site geotechnical engineer" rather than
for each field density test.
This does not comply with the commitment made in 50.54(f) response
to Question 1.
This occurred because adequate design interface
controls had not been implemented as required by ANSI N 45.2.11.
There was no evidence that the geotechnical group had reviewed or
approved the revision to the specification.
This failure to provide adequate design interface control is
considered contrary to 10 CFR 50, Appendix B, Criterion III as
described in the Notice of Violation.
(50-329/80-32-03; 50-330/
80-33-03).
(2) Specification C-208, Section 9.1.1 should be reworded to
remove confusion which exists about the word " compaction".
This section should read: Modified proctor tests on t.ohesive
material shall be performed in accordance with ASTM D 1557,
Method D.
(3) Section 9.1.3 (first paragraph) does not specifically
indicate how ASTM D 1566 has been modified by USBR DES E-24.
In addition, why does the specification prohibit the use of
the nuclear density device for measuring in place field
density? This device is an industry accepted method with a
standard ASTM designation.
(4) Section 9.1.3 (second paragraph) assumes a specific gravity
of 2.75.
The actual specific gravity should be known and
used as is the industry practice.
(5) Section 9.1.3(c) should also include:
if the results still
plot to the right of the ZAV curve the test should be
rejected and a new density test performed.
(6) Section 9.1.3(d) uses the phrase 101% compaction. This should
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read 101% of maximum proctor density. This section also permits
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the on-site geotechnical engineer "to evaluate" the results of
tests that exceed 101% proctor density for cohesive material and
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105% for cohesionless material. This section should incl'ude
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the qualitative acceptance criteria and/or instructions to be
used for the basis of this evaluation.
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The above items 3(c) 2, 3, 4, 5 and 6 are considered unresolved
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items pending a review of CPCo response to each item.
(50-329/
80-32-04; 50-330/80-33-04).
d.
Specification C-211, Revision 12 regarding tackfill work activities
was reviewed for technical content.
It was determined that the
specification was not adequate as written. The following specific
items were identified.
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(1) Section 8.1 does not specify the type of material to be used
beneath Category I, safety related structures. This should
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be included in this specification.
(2) Section 8.1.1 does not specify the type of material to be
used around pipes and duct banks. - The specification should
specify or refer to appropriate instructions.
(3) Section 8.3.2 (third paragraph) states, "the uncompacted
lif t thickness of the backfill mat'erial shall be determined
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by the on-site geotechnical rioils engineer .
The on-
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site soils engineer should not have to determine the lift
thickness when At+.achment No. I to specification C-211
specifies the requirement foi each type of equipment based
on equipment qualification tests.
(4) Section 8.5.2 permits the use of rubbe'r-tired rollers to
compact structural backfill and sand, Attachment No. I to
specification C-211 does not indicate' rubber-tired rollers
as having been qualified and rubber-tired rollers should not
be used to compact structural backfill and sand.
The above items 3(d) 1, 2, 3 and 4 are considered unresolved items
pending a review of CPCo response to each item.
(50-329/80-32-05;
50-330/80-33-05).
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4.
Review of Question 1, Part (b) and Question 23, Part (2)
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The provisions and the procedures to be implemented *te preclude conflictsz
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between PSAR, FSAR and design documents was' discussed in response to ~
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Question 1, Part (b) and Question 23, Part (2). Consumers Power Company ~
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included in their response a procedure entitled,. "FSAR Rereview Procedure"
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to be implemented to accomplish this connitment.,
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Action items 23-1, 23-44 and 23-44(a) as identified in Attachment No. I
provided the commitments to be implemented to assure FSAR accuracy. The
following are the NRC findings regarding the implementation of these
commitments.
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It was determined that, in genera), consultant reports were not attached
to the FSAR.
However, the complete text of a consultant report prepared
by Weston Geophysical Engineering Company was found as an attschment to
the FSAR and included in the FSAR, as Appendix 2C.
Therefore, the CPCo
response which staten, " Consultant reports were not attached to the FSAR,
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but portions of consultant reports were extracted and incorporated into
the FSAR text itself" (re: Question 23, Page 23-7) is not correct.
CPCo also stated that the FSAR n s rereviewed against design documents
such as consultant. reports for conflicts.
It was determined that verification of portions of consuitant reports
incorporated into the FSAR have been adequately reflected in design
documents.has not been satisfactorily accomplished.
FSAR Rereview Pro-
cedure, Revision 1, dated March 13, 1980, Subsection 2.1.3 states that
each FSAA section should be carefully reviewed against design documents
. as a sainimum, the following should be checked .
references at
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the end of the FSAR d. apter. The procedure also requires in Item 8
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that engineering design documents agaiist which the FSAR review package
is to be reviewed are to be listed by the primary review engineer in
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Block,8 of the FSAR rereview form. A review of F3AR packages Nos. 9474,
9473,.9472, 9471, 9096, 9097 and 9098 indicates that no design documents
.other than a few drawings were identified and listed. Numerous reports
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were referenced th'roughout the FSAR text of these sections, however,
they were not recorded as required in Block 8 as being reviewed for
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consistency with the FSAR text.
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An interview wit'
itel cognizant priraary review engineer indi-
\\ated' tSt hefph,
.any checked the references to make sure that they
agreed wi'th the'ESAR . text. Spbsequently, after the NRC inspector found
'.~ .Vap apparent dib.repancy between the FSAR text and one of the references,
the Bechtel reviewgr indicated 'that he did act check the text of the
references, but merely checked the reference for consistency of subject
raatter,
i.e., title y . sentenir content"not, technical substance vs.
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FSAR statements. Another cognizant' Bechtel primary review engineer
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indicated he ccald not cht, a refe2ences-in hic section because he was not
quali fied togeriew the techni.t'al matter in xthis area. He indicated that
he relied on the Bechtel*Cetater's group (the ' interface reviewer in Block 11)
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toverifyjthereferences. ' Discussions with a Geiotech reviewer indicated
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he did chck reports for consistency with theiFSAR, but did not list
them la/51ock 8 as required.
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,'her this 4f determined, the ,indpectorWas informed that a CPCo
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InterimauditNo.M-01-53- ,idated March 1980, identified the same
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prob'lem copprning the hc(k of identifying , design documents in
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Block 8 o! the FSAR review f orm. _At,thii time-approximat'ely 600 of
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a total oft 900 FSAR rereview packapes had been completed. However,
no corrective action was taken.'M PCo final audit of this activity,
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wdit No. M-03-292-0, dated Nogmber'IQ80, ronce again identified an
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junresolved item, ISI-3, regarding ~thig same problem. The FSAR rereview-
t' i's'now complete and the unresolved item was pending resolution as of
Qbe,.date bf ',this inspection. '
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. Cognizant individuals indicated that one of the reasons why documents
were not listed in Block 8 was because there was not sufficient space.
An interview with the preparer of the FSAR rereview document indicated
tnat the intent of Block 8, and it's instructions, was to list all of
the design documents to which the FSAR section was reviewed against in
order to assure there were no more conflicts between design documents
and the FSAR text.
Based on the above, it was determined the CPCo failed to provide
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adequate corrective action with regard to the identified audit results.
This is considered contrary to 10 CFR 50, Appendix B, Criterion XVI, as
described in the Notice of Violation.
(50-329/80-32-06; 50-330/80-33-06).
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Due to this finding, CPCo implementation of the specific commitment
as discussed in response to Question 23, Part (2) has not been accom-
plished and the adequacy of the FSAR reraview which has been completed
is questici.able.
5.
Review of Question 1, Part (c) and Question 23, Part (3)
CPCo and Bechtel_have performed a detailed re-review of specifications,
installations, and construction inspection plans, procurement documents,
inspection and test procedures, including the results of inspections
and tests to determine the completeness and accuracy of documents and
the acceptability of hardware.
In this regard, the I&E inspection
activities involved a review and evaluation of activities associated
with the above re-review' actions and included discussions with main
participants in the re-review effort. The following is a summary of -
this inspection.
a.
CPCo and Bechtel were able to demonstrate that an extensive
re-review of specification, insrections and test procedures, and
documents associated with procureuents were conducted with mean-
ingful results. The documents were evaluated by CPCo and Bechtel
to assure that the necessary tolerance call outs and quality
requirements were specifiedL that the qualification requirements
were adequately called out and met; that there were sufficient
specificity provided in the documents; and that there were the
necessary inspection requirements specified.
In addition, the
completed documentation was evaluated to determine that technical
and quality requirements were met in an acceptable manner.
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Areas that were found defic!.ent resulte'd,in revision and improve-
ment to procedural controls and specifications. Hardware suspected
of not meeting quality requirements were re-evaluated by engineering
and quality assurance to determine their accept, repain, or reject
status.
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Throughout this particular I&E inspection effort, specifications,
procedures, and instructions were reviewed and a determination
made that revisions and improvements were accomplished.
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b.
The improved trend analysis and corrective action program estab-
lished by CPCo and Bechtei was evaluated and found acceptable.
It is expected that this program will prove effective in detecting
major weaknesses in the early stages such that meaningful, prompt
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corrective actions can be initiated during the design and
construction phase.
The " flag program," which provides assurance that problems, similar
c.
to those experienced with reactor vessels holddown anchor bolts, do
not exist in other similar procurement actions where in-process
source inspection activities are involved, was evaluated.
Purchase
orders and receiving documentation were reviewed by Bechtel to
determine that critical design and specification requirements were
properly carried out and where questions were raised concerning
product function, a " flag" was identified to the concern requiring
further evaluation, discussions, and resolution by engineering
and quality assurance. Evidence showed this activity to be
productive and in accordance with documented instructions.
d.
The 1978 and 1980 independent audit results performed by the
Management Analysis Corporation on CPCo and Bechtel were evaluated
and found in accordance with program requirements.
Overall, the personnel contacted conveyed their QA knowledge and
their sincerity and dedication towards performing the activities
described above.
However, as a result of the findings identified
during this inspection, it is clear that more emphasis must be
placed on the attention to detail in the preparation and review
of documents.
In order to accomp1'ish this, upper management
must play a more active role in conveying this principle to the
working staff and observing attitudes and activities to assure QA
principles and attention to detail are being properly carried out.
Unresolved Item
Unresolved items disclosed during the inspection are discussed in Para-
graph 3(c) and 3(d) of'the report.
Exit Meeting
The inspector met with licensee and contractor representatives at the
conclusion of the inspection on December 11, 1980 and summarized the
inspection scope and findings. The items of noncompliance identified
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during the inspection were discussed in detail. The licensee acknowl'
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edged the inspection results.
Attachment:
Attachment No. 1
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ATTACIDIENT NUMBER 1
1/5/81
ACTION ITEMS
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PROGRAMMATIC AND GENERIC CORRECTIVE ACTIONS
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COMMITTED TO IN T!!E RESPONSE TO QUESTION 1,
PART (a)
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AND IN THE RESPONSE TO QUESTION 23, PARTS (1) AND (2)
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' Action
Action Item
Item
Description
Actions Verified
Number
and Reference
(Status) ituring NRC Inspection
23-1
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
been adequately accounted for in the prepara-
tion of the FSAR.
Verification that those portions of consultant
(Open)
Refer to Action Item 44 for Review of
reports determined to be commitments and incor-
FSAR Re-review
porated 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).
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23-1(a)
The two Bechtel QA audit findings reported in
(Closed)
Reviewed quality assurance audit 4.0-
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our April 24, 1979, response (Paragraph D.1,
special 1, "SAR change control", & audit findings
and
Page I-8) have been closed out.
The results
A-34 & A-35.
The audit was performed to assure
of this audit are being utilized in the PSAR
that there is a system to assure design changes
. control system study committed to in Subsection
are reflected in the FSAR. Audit findings ident-
3.3 of this response to Part (1).
Ified cases where design changes were not reflected
in the FSAR. Corrective action resulted in a
(Question 1, Appendix I,
Section D.1,
Page I-8
review of all design requirement verification
Question 23, Subsection 3.1,
Page 7)
checklists (DRVCL's) for groups identified with
problems. This review is documented in QE
monitoring report DRVC-8.
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Action
Action Item
Item
Description
.
.
Number
and Reference
(Status)
23- 2
on April 3, 1979, Midland Project Engineering
(Closed) Reviewed & verified memos & letters
Group Supervisors in all disciplines were
instructing proj. engr. field eng, & QC of pro-
reinstructed that the only procedurally
cedure for implementing clarification or change
correct methods of implementing specification
to approved drawings or specifications:
I
changes are through the use of specification
(1) Bechtel memo to QCE's, dtd 5/30/79.
l
revisions or Specification Change Notices.
This
(2) Bechtel memo to Field Engr's, dtd 3/28/79.
was followed by an interoffice memorandum from
(3) CPCo letter to Bechtel, dtd 3/12/79.
'
the Project Engineer to all. Engineering Croup
(4) Bechtel memo to Proj. Engr, dtd 3/21/79.
Supervisors on April 12, 1979.
(5) Bechtel memo to Group Suprv, dtd 3/12/79.
i
(6) Bechtel letter to CPCo, dtd 6/5/79.
!
(Question 23, Subsection 3.2, Page 8; and
Subsection 3.9, Page 24 )
,
23-3
Engineering Department Project Instruction
(Closed) Reviewed & verified EDPI 4.49.1, Rev. 4,
!
and
4.49.1 was revised in Revision'2 to state,
" specification change notice # to include require-
1 - 12
"Under no circumstances will interoffice
ment that IOM's, memo's, telex's, BTS's, etc. can
memoranda, memoranda, telexes , 'NXs , etc
not be used to change spec. requirements. A spec.
be used to change the requirements of a-
specification."
change notice must be issued in order to change
spec. requirements.
(Question 1, Appendix I,
Section 0. 2.d, Page I-8
Question 23, Subsection 3.2,
Page 9, and
Subsection 3.9,
Page 24)
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Action
Action Item
.
.
Item
-
Description
Number
and Reference
(Status)
23-4
A review of interof fice memoranda, memoranda,
telexes, WX s , and other correspondence relating
'
to specifica tions for cons truction 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 ef fect on the
technical acceptabili ty, safety implica tions
~
of the potential specification modifica tion,
and any work that has been or may be af fected.
If it is dc termined that the interpretation
may have af fected 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 folldwed for all
(closed)
Verified Bechtel memo dated 12/20/79
specifications applying'to construction of
Q-Listed items.
(File 0455) which.provides the procedure for
review of all (100%) Q-listed construction type
'
spec's. and sampling plan procedure for procurement
For specifica tions concerning the procurement
type spec's.
of 0-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.
(21)
Review and acceptance criteria for the specifi-
(Open)
Review criteria has been established (see
ca tions have been defined.
above action item 4); acceptance criteria was not
(47)
The review of construction and selected
defined. Audit report NO1-200-0 also identified
this as an unresolved item.
procurement specifications is scheduled to be
completed by April-1, 1981.
(Open)
File had no review data for construction
type or procurement type spec's.
.
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Action
Action Item
1/5/81
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Item
Description
,
Number
and Reference
(Status)
_
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(47)
If the acceptance criteria are not met, the
(0 pen) preliminary indication per Bechtel
'
(cont'd) review will be expanded to include other
Representative indicated that the review will
specifications for Q-listed items
At that
be required to be expanded to include other
.
time, a revised completion date will be
spec's than sampling plan identified.
established.
l.
.
(Question 23, Subsection 3.2, Page 9, and
)
Subsection 3.9, Page 25)
23-5
A s.udy was completed which examined current
,
(23-38)
procedures and practices for the preparation
and control of the FSAR in view of these
experiences.
Procedural changes have been
i
initiated by the revision of or addition to
f
the Engineering Department Procedures.
.
(Question 23, Subsection 3.3, Page 11)
.23-6
An' interoffice memorandum dated April 12, 1979,
(closed) Reviewed & verified inter-office memo
was issued by Geotechnical Services to alert
from S. Blue to Geotech personnel, dated 4/12/79
personnel of the need to revise or annotate
which requires that changes in design be reflected
,
L
calculations to reflect current design status.
In the original calculations & to reflect proper
interdepartmental coordination has been achieved.
(Question 23, Subsection 3.4, Page 13)
$
'
23-7
Field Instruction FIC 1.100, "Q-Listed Soils
(closed) Reviewed'& verified, field instruction
Placement Job Responsibilities Matrix," has been
FIC1.100, Rev. 3, dated 8/15/80 to include daily
prepared and establishes responsibilities for
job responsibilities of the onsite geotechnical
performing soils placement and compaction.
engineer.
(Ouestion 23, Subsection 3.6, Page 18;
Subsection 3.7, _Page 20; and
,
Subsection 3.11, Page 30)
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Action
Action Item
Ztem
Description
Number
and Reference
'
(Status)
-
.
23-7A
Review Field Procedure FPG-3.000 to ensure
(Closed)
Verified that FPG-3,000, Rev.
O," Job
and
clarity and completeness
responsibilities for field engineers"was reviewed
1 - 17
as a result of this review FIC 1.100," Job responsi-
(Question 1, Appendix I,
Section 0.2,
Page I-ll)
bilities for the onsite geotechnical engineer"was
established.
,,
23-8
Construction specifications, instructions, and
and
procedures were reviewed to identify any other
(open)
CPCo commitment not completed.
1 - 16
equipment requiring qualification which had not
yet been qualified.
No such equipment was
identified.
'
(Question 1, Appendix I,
Section D.1,
Page I-ll'
Question 23, Subsection 3.6,
Page 18)
i
1
23-9
A dimensional tolerance study was completed
(closed) verified that dimensional tolerance
'
using the reactor building spray pump and
study was performed on the reactor building spray
ancillary system as the study mechanism.
pump system.
(Question 1, Appendix I, Section D.2.b,
Page I-8)
23-10
Engineering reviewed specifications not previously
(closed) verified that a review of spec's A-17,
and
reviewed for the specificity or tolerance studies.
C- 67, M-342, C-208, C-231 6 A-41 was performed
1-5
for specificity & tolerances. Revisions were
(Question 1, Appendix I,
Section D.2.c,
Page I-8)
made to spec. as needed.
(closod)
Verified a review of FSAR 5 Spec 1
23-11
A specific review of the PSAR and specification
requirements for the qualification of electrical
requirements for qualification of electrical
1
and mechanical components has been made as part
and mechanical components has been performed
of the corrective action relating to CPCo s
& documented in CPCO letter to NRC, Region III
i
50.55(e) report on component qualification.
d ted De ember 5, 1980, as required by 50.55(e)
reporting requirements.
.(Question 1, Appendix I,
Section D.2.e,
Page I-8)
,
!
23-1 2
Quality Assurance will schedule yearly audits of
(0 pen)
CPCo commitment not completed.
the design calculational process for techniques
and actual analysis in each of the design disci-
plines.
,
(Question ' , Appendix I,
Section D.4,
Page I-8)
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Action
Action Item
.
Item
Description
,
Number
and Reference
(Status)
-
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23-1 3
Audits of ITT Grinnell hanger design and CPCo
(Closed) Verified that audit OT-ITT Grinnel
relay setting calculation have been conducted.
(April 5, 1979) and audit of electrical and IEC
(Question 1, Appendix
I,
Section D.4,
Page I-8)
~ '
23- 14
Bechtel Project Engineering will review design
(Closed)
Reviewed file No. 54601-54618
and
drawings for cases where ducts penetrate
(calc #41-1) b red 9/5/78 which identifies each
1 - 10
vertically through foundations.
The possibility
duct bank in the plant and interface with any
of the duct being enlarged ' over the design
buildings.
Results of study were documented in
requirements and the effect this enlargement
memo from L. Curtis to R. Rixford dated 5/27/80
may have upon the structure's behavior will be
which indicates no other safety-related structure
evaluated by June 1, 1979.
Proper remedial
except D. G. Bldg was effected by an interface
measures will be taken if the investigation
with duct banks. Provisions were made to allow
shows potential problems.
independent vertical movement between the diesel
l
generator b1dg and duct banks.
-
,
(Question 1, Appendix I,
Section C.S.b,
Page I-7)
23-1 5
An in-depth audit of U.S. Testing operations,
(Closed) Reviewed and verified audit 25-2-7 of
and-
covering testing and implementation of their
U.S. Testing Company was performed on April 25-26,
1 - 20
QA program will be conducted in late April or
1979.
'
early May 1979, by Bechtel Project QA and
Engineering.
,
(Question 1, Appendix I,
Section C.4.b, Page I-18;
Section D.3.c,
Page I-18)
23-16
An in-depth training session will be given to
(open) See review of Action Item 23-17
and
Midland QA Engineers covering the settlement
1 - 25
problem and methods to identify similar
,
conditions in the future.
(Question 1, Appendix
I,
Section D.l.b,
Page I-22)
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1/5/81
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Action
Action Item
3
-
Item
Description
Number
and Ite f e rence
(Status)
+
.
23-17
An in-depth training session will be given to
(Open) Reviewed IOM dated July 27, 1979 and
,
and
all CPCo and Bechtel OA Engineers and Auditors
June 4,
1979 documenting training .o CPC, and
1 - 25
to increase their awareness of the settlement
Bechtel QA personnel on Midland plant fill
problem and to discuss auditing and monitoring
experiences. The file.does not contiin docu-
techniques to increase audit ef fectiveness,
mentation of the contents or detail of the
training nor any material handed out to parti-
(Question 1, Appendix I,
Section D.2,
Page I-22)
cipants for their future reference.
23-18
An in-depth review of the Bechtel trend
(Open) CPCo commitment not completed.
t
and
program data will be undertaken by Bechtel OA
i
1 - 24
management to ensure the identification of
any other similar areas that were not
analyzed in sufficient depth,in the past reviews.
1
!
(Question 1, Appendix I,
Section D.l.a, Page I-22)
23-19
Quality Control Instructions have been evaluated
(closed) Verified the QCI's were reviewed and
and
to ensure that the documentation characteristics
items requiring further action and resolution
1 - 21
which are - to be ins pected
(i.e.,
surveillance and
identified (See Action Item 23-19A).
1 - 22
review callouts) are clearly specified.
l
- 23-19 A
(This action modified to include necessary revi-
(Open) Completion of required changes to QCI's
and
sion to OCIs resulting from evaluation of surveil-
1 - 21A
lance and _ review callouts. )
per Action Item 23-19 have not been completed.
<
(Ques tion 1, Appendix
I,
Section D.3.a,
Page I-18
and Section D.1,
Page I-18)
~
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23-20
Pield Instruction 1.100 has been supplemented
(0 pen) CPCo commitment not completed.
Records
'
by establishing requirements for demonstrating
identifying equip. capability not documented in
equipment capability, including responsibility
Action Item file.
l
for equipment approval, and providing records
' identifying this capability.
(Ques tion 23, Subsection 3.6, Page 18)
,
23-21
See Action Item Number 4 (21)
(open) Acceptance criteria not defined (See
,
Action Item 4 for review).
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1/5/81
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Action
Action Item
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Item
Description
.
Number
and Reference
(Status)
.
.
,
23-22
Guidelines for surveillance of testing operations
(Closed) Responsibilities for on-site
have been developed and included in Field In-
Geotechnical Engineer have been established per
<
structions for the onsite Soils Engineer.
FIC 1.100, Rev. 3 which include requirements.
Engineering /Geotechnical Services has developed
tha guidelines.
,,
I
(Question 23, Subsection 3.10, Page 27)
4
,
23-23
Engineering has revised Engineering Depart-
(Closed) Verified EDP 4.22 has been revised by
j
and
ment Procedure 4.22 to clarify that Engineering
issuance of MED 4.22, Rev. 6 to include Regulatory
1-3
personnel preparing the PSAR will follow the
Guide 1.70 which requires consultant reports to
requirements of Regulatory Guide 1.70, Revision 2,
be referred with specific commitments included in
" Standard Format and Content of Safety Analysis
text of the FSAR.
Reports for Nuclear Power Plants" (September 1975) .
Specifically, Regulatory Guide 1.70 (Pages iv and
4
v of the Introduction) requires that such consul-
tant reports only be referenced with the
applicable commitments and supporting informa-
tion included in the test (third paragraph,
,
j
Page v).
Such a requirement precludes repetition
of this circumstance'. -
.
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(Question 23, Subsection 3.1, Page 7 and
j-
Subsection 3.3d, Page 46)
.
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a
23-24
To preclude any future inconsistencies between
(Closed) Verified EDP 4.1.1, Rev. 2, Preparation
^
the PSAR and specifications, Engineering Depart-
of the design requirement verification checklist','
ment Project Instruction 4.1.1 has been revised
Para. 3.1 requires the discipline engineer who
i
to state that all specification changes, rather
originates a design change document to fill out
j
than just " major changes," vill be reviewed for
a DRVC as the change is developed. The DRVC
j
consistency with the FSAR.
include verification of consistency with the FSAR
for design changes.
(Question 23, Subsection 3.3, Page 11)
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Action
Action Item
'
Item
Description
Number
and Reference
(Status)
23-25
Quality Assurance has issued a Nuclear Quality
(Closed) Quality Assurance policy,Section II,
' Assurance Manual amendment to clarify the
No. 2," design control procedurest Para. 3.1.4,
requirement that procedures include measures for
Rev. 2B states, engin*cering department procedure
qualifying equipment under specified conditions.
shall include criteria for specifying equip.
qualification requirements. Also construction
(Question 23, Subsection 3.6, Page 18)
quality program,Section IV, No.
1, Rev. 2B
Para. 3.2.3('P) requires instructions for quali-
23-26
'In view of Action Item 6, Geotechnical Services
fications of equip.
-has. revised. Procedure FP-6437 to require that
calculations be annotated to reflect .urrent
design' status.
(Closed) Reviewed and verified procedure
FP-6437-A2 was issued (See ref. letter from
-(Question 23, Subsection 3.4/ Page 13)
S. Blue to R. Rixford dated 4/10/80).
23-27.
Engin~eering Department Procedure 4.37 has also .
(closed) Verified procedure MED 4.37, Rev. 11,
been revised to require that calculations.be
" Design Calculation" and EDPI 4.25.1, Rev. 7,
annotated to reflect current design status.
" Design Interfat.e Control"was issued to require the
(Question 23, Subsection 3.4, Page 13)
originator of a design change to notify all groups
which used the original design document and to
23-28
. Civil /Structur31 Design. Criteria 72202C-501
check the latest design info prior to revising
.
has been meditted to contain the requirements
calculations.
that.a duct bank penetration.shall be designeg
(closed) Verified civil design criteria C-501,
to' eliminate the possibility of the nonspecific
size duct ' interacting wi th. the structures.
Rev. 11, Para. 6.6 has been added which states,
,,All interfaces between b1dg's or foundations and
(Ouestion 23, Subsection 3.5, Page 15)
duct banks designed after Jan. 1, 1980 shall be
'
included on civil design drawings and shall indi-
23-29
The' civil standard detail' drawings have been
cate clearances or const. restrictions as required
revised to include a detail showing horizontal
- account for differential settlement, seismic
and. vertical clearance requirements for duct
n vem nt, etc.
bank penetrations.
The detail addresses any
mud ma t. res trict ions.
(Closed) Verified civil standards and misc.
~
concrete details, sheet 2, dwg C-141, Rev. 6
(Question-23, Subsection 3.5',
Page 15)-
detail 12 provides duct bank clearance criteria.
.
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Action
Action Item
.
Item
Description
Number
and Reference
(Status)
,
23-30
Engineering clarified specifications and
(closed) Verified spec C-211, Rev. 12,
(39)
Construction prepared procedures (governing
Para. 8.5.1 (compactLon equipment) now requires
'
the soils compaction equipment) to implement
proposed compaction equipment to be qualified to
the requirements of the Nuclear Quality Assurance
Manual as stated in Action Item 25.
demonstrate compaction can be achieved at a
'
specified lift thickness, number of passes, speed
,
.
of equipment and frequency of vibration for
(Question 23, Subsection 3.6, Page 18)
vibrating equip.
23-31
Design documents, instructions, and procedures
(0 pen) CPCo commitment not completed,
for those activities requiring inprocess controls
have been reviewed to assess the adequacy of existing
procedural controls and technical direction.
Engineering review has been' completed.
,
'
(Oues tion 1, Appendix I,
Section D.2,
Page I-11; and
Question 23, Subsection 3.7, Page 20; and
Subsection 3.11, Page 30)
23-32
Guidelines for surveillance of testing operations
(closed) See Action Item 23-22.
have been developed and included in {'ield Instruc-
,
tions for the onsite Soils Engineer.
Engineering /
i
'
.Geotechnical Services has developed the guidelines
i
and Field Engineering has prepared the instructions.
l
(Question 23, Subsection 3.10, Page 27)
23-3 3
The Quality Assurance audit and monitoring program
(open) CpCo commitment not completed.
will be revised to emphasize and increase attention
to the'need for evaluating policy and procedural
'
[
adequacy and assessment of product quality.
A
specialized audit training program will be
oeveloped and implemented to ensure guidance for
tris revised approach.
(Question 23, Subsection 3.13, Page 35)
.
3heet 11 ot 21
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1/5/81
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Action
Action Item
Item
Description
Number'
and Reference
(Status)
23-34
Control Document SP/ PSP G-6.1 has been revised
(closed) Verified Procedure G-6.1, Rev. 5 has
and
to provide requirements for inspection planning
been revised to incluji,e requirements for planning,
1 - 23
specificity and for the utilization of scientific
specificity (Para. 3.3.2) and utilization of
sampling rather than percentage sampling.
scientific sampling (Para. 3.3.3.a.8).
This
deleted surveillance type inspection and now
(Ouestion 1, Appendix I, Section D.5.f, Page I-20; and equires inspection by witness or test.
Question 23, Subsection 3.8, Page 22; .
Subsection 3.9, Page 24;
Subsection 4.2.2, Page 59)
23-35
Control Documents SP/ PSP G-3.2,
" Control of
(closed) Verified G-3.2, Rev. 6,aControl of
Nonconforming items," and
Nonconf orming Items'and QAPP C-101"QA Trend
23-36
OADP C-101, " Project Ouality Assurance Trend
Analysis *have been modified to provide for
and
Analysis" have been revised to provide an
identifying repetitive nonconforming conditions.
1 - 24
improved definition of implementing require-
Interviewed Mr. T. K. Subramanian.
1 - 25
ments for identifying repetitive nonconforming
conditions.
(Question 23, Subsection 3.12, Page 33)
23-37
Consistent with the intent of Action ' Item Numbers
(Open) CPCo commitment not completed.
35 and 36, Quality Assurance will review noncon-
formance reports which were open as of November 13,
1979, or became open prior to implementation of
the improved Project Quality Assurance Trend
Analysis program as stated in Action Item 36.
This review will be to identify any repetitive
nonconforming conditions pertaining to product
type or activity, or pertaining to nonconformance
cause.
(Question 23, Subsection 3.12, Page 33)
"
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Action
Action Item
-
Item
Description
Number
and Reference
(Status)
23-38
A study was completed which examined current
(open) See Action Item 23-5
(23-5)
procedures and practices for the preparation and
control of the FSAR in view of these experiences.
Procedural changes have been initiated by the
revision of or addition to the Engineering
Department Procedures.
(Ouestion 23, Subsection 3.3, Page 11)
23-39
Engineering clarified specifications and
(Closed) Verified FIC 1.100, Rev. 3 requires
(30)
Construction prepared procedures (governing
on-site geotechnical engineer to ensure compaction
the soils compaction equipment) to implement
equipment is qualified and listed in the spec and
the requirements of the Nuclear Quality Assurance
Manual as stated in Action I tem 25.
can deliver required degree of compaction-
(Question 23, Subsection 3.6, Page 18)
23-4 0
Design <iocuments, instructions, and procedures
(Open) CPCo commitment not completed.
for those activities requiring inprocess controls
will t; reviewed to assess the adequacy of
t
existing procedural controls and technical
(31)
direction.
Engineering. review has been com-
,
.
Oleted, and Field Engineering and quality
'
control review is scheduled for completion
by February 27, 1981.
(Question 1, Appendix I,
Section D.2,
Page I-ll;
Ouestion 23, subsection 3.7,
Page 20, and
Subsection 3.11, Page 30)
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Action
Action Item
Item
Description
Number
and Reference
(Status)
.
23-41
QCIs in use will be reviewed to ascertain that
(Open) CPCo commitment not completed.
provisions have been included consistent with
the revised control document, SP/ PSP G-6.1,
i
,,
" 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)
23-4 2
Design documents, instructions, and procedures
(Open) CPCo commitment not completed,
for those activities requiring inprocess controls
will be reviewed to assess the adequacy of
existing procedural controls.and technical
(31)
direction.
Engineering review has been completed,
(40)
and Field Engineering and quality' control
j
review is scheduled for completion by
.
'
February 27, 1981.
Any revisions required will
be completed by April 17, 1981.
(Question 1, Appendix I,
Section D.2,
Page I-ll;
"
i
Ques tion 23, subsection 3.7, Page 20; and
Subsection 3.ll, Page 30)
.
,
i
23-43
The impact of Action Item 41 on completed work
(Open) CPCo commitment not completed.
will be evaluated, and appropriate actions will
,
be taken as necessary.
'
I
(Ques tion 23, Subsection 3.8, Page 22; and
'
4
Subsection 3.9,
Page 25)
'
23-44
FSAR sections have been rereviewed as discussed
(0 pen)-
9 re-review packages were reviewed
in the Response to Question 23, Part (2).
by the NRC.
Not all of the design documents were
listed in Block 8 of required form per procedure
(Question 23, Subsection 3.1,
Page 7;
for performing review issued 3/13/80.
This was
Subsection 3.3,
Page 11*
identified as an item of noncompliance as dis-
Subsection 3.2,
Page 41; and
1
Section 4.0,
Page 47)
cussed in Paragraph 4 of this report.
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Sheet 14 of 21.
1/5/81
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Action
Action Item
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Item
Description
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Number
and Reference
23 44A
The audit committed to in our response to
. (open)
(1) CPCo Audit not completed & (2)
l
Question 1, Part b, and described in Part (2),
Existing Audit findings (M01-53-0) not satis-
'
'Section 5.0 was conducted once during the
factorily resolve;
i.e.,
inadequate corrective
course of the FSAR rereview (conmncing March .17,
action. This item has been identified as an
1980) and again after completion of the rereview
item of noncompliance as discussed in para-
(commencing November 3,1980 ) .
graph 4 of this report.
<
4
(Question 23, Part (2), Section 5.0,
Page 48)
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Sheet 15 of 21
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1/5/81
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Action
Action Item
,
4
It7m
Description
I -
Number
'
3.nd Reference
-
.
23- 45
U.S. Testing was required to demonstrate to
(0 pen) CPCo commitment not completed.
l
cognizant Engineering Representatives that
,,
'
testing procedures, equipment, and personnel
used for quality verification testing (for
other than NDE and soils) were capable
of providing. accurate test results in accordance
3
with the requirements of applicable design
,' documents.
i
(Question 1, Appendix I,
Section D.3.b, Page I-18;
.- Question 23, Subsection 3.10, Page 27; and
,
Subsection 3.11, Page 31)
. . .
23, 6
A' sampling of U.S. Testing's test reports (for
(Open) CPCo commitment not completed.
other than NDE and soils) were' reviewed by
cognizant Engineering Representatives to ascertain
that results evidence conformance to testing
requirements and design document limits.
,
i
(Question 23, subsection 3.10, Page 28.; and
i
Subsection 3.11, Page 31)
i
2347
See. Action Item Number 4 (47)
(0 pen) CPCo commitment not completed.
23-48
CPCo performs overinspection for soils
(Closed) Verified CPCo overinspection plan.
placement, utilizing a specific overinspection
01-C-3A, Rev. 1 for soil placement and reviewed
plan.
completed overinspection results performed on
weekly basis.This overinspection program is an
(Question 1, Appendix I,
Section C.2.b, Page I-ll;
ongoing activity by Midland QA gr'.op.
Section C.l.c, Page I-16)
23-49
' CPCo performs overinspection of'the U.S.
(Closed) Verified CPCo overinspection plan
Testing soils testing activities and reports,
01-C-4A, Revision 3, for soil testing and
utilizing a specific overinspection plan.
review completed overinspections performed
on U. S. Testing.
(Ques tion 1, Appendix -I,
Section C.3.c, Dage I-17)
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Sheet 16 of 21
,
1/5/81
.
.
Action
Action Item
Item
Description
Mumber
and Reference
23-50
CPCo Project Management and QA review field
(closed) Verified CPCo reviews of field pro-
procedures (new and revised) and CPCo QA reviews
cedures and quality control instruction in
OCIs (new and revised) in line with Bechtel before
addition to Bechtel prior to release.
release.
4
(Question 1, Appendix I, Section D.S.b, Page I-19)
23-51
In 1978, CPCo implemented an overinspection plan
(Closed) Verified CPCo has overinspection plans
struction and the Bechtel inspection process,
in the civil, electrical, mechanical, and
with the exception of civil activities.
Re-
welding /NDE work activities.
inforcing steel and embeds were covered in the
overinspection.
(Question 1, Appendix I,
Section D.S.c,
Page I-19)
'23-52
CPCo reviews onsite subcontractor OA manuals
(Closed) Verified CPCo reviews subcontractor
and covers their work in the audit process.
QA manuals and audits subcontractor work.
(Ques tion 1, Appendix I, Section D.S.d, Page I-19)
23 53
An ongoing ef fort is improving the " surveillance"
(Closed) Verified that SF/ PSP C-6.1,
Rev. 5
mode called for in the OCIs by causing more
" Procedure for Quality Control inspection plans"
,
specific accountability as to what character-
have deleted surveillance method and new require-
istics are inspected on what specific hardware
ments direct inspection by witness or test to
and in some cases ci'anging " surveillance" to
be performed by Quality Control surveillance
" i ns pe c t io n . =
method has been deleted in para 3.3.3.a.3 of
G-6.1, Rev. 5.
(Question 1, Appendix I,
Section D.S.e,
Page I-19)
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Sheet 17 of 21
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1/5/81
.
Action
Action Item
.
Item
Description
Number
and Reference
(Status)
1-1
Perform a final review & update of PSAR commitment list.
(Open)
Action item not reviewed by NRC during
the inspection.
1-2
Review sections of FSAR determined to be inactive.
(open)- See Action Item 23-44 for NRC review &
,
results.
1-3
Review EDP 4.22.
(Closed)
See Action Item 23-23 for NRC review.
1-4
Audit Action Items 1-3
(open)
See Action Item 23-44A for NRC review &
results.
1-5
Review specifications not included in specificity
(Closed)
See Action Item 23-10 for NRC review
study initially,
and results.
1-6
Dames and Moore Report was reviewed and recommendations
(0 pen)
File indicated review was complete,
identified and dispositioned.
however, no details o' the recommendations
identified or the dispositions were available.
(Question 23, Subsection 3.1, Page 23-6)
(Question 1, Apx, I, Page I-6, Para C.l.(b)
1-7
Complete review of pertinent portions of FSAR s -tions
(Closed)
Verified FSAR, Revision 18 to have
2.5 and 3.8.
corrected:
(1) inconsistency between FSAR 3.8.5.5
and 2.5.4, Figure 2.5-48, settlement values, (2)
Inconsistencies between FSAR subection 2.5.4. and
Table 2.5-9 and Table 2.5-14 regarding soil type
3.8.5 have been corrected via FSAR Amendment 18
supporting structures from clay to (Zone 2)
(Feb 28, 1979) the same revision also corrected
ramdom fill, (3) Table 2.5-16, index of compressi-
inconsistency between 2.5.4 and drawing C-45.
bility factors to be determined from fill studies.
(4) table 2.5-21 compaction requirements.
(Question 23, Subsection 3.3, Page 23-11)
Reviews of Section 2.5.4. are on " Hold" until
(Question 1 Apx I, Page I-6, Para 3)
resolution of soils issue.NRC office of NRR
Geotechnical Branch will review FSAR section
when final.
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Sheet 18 of ;g
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Action
Action Item
1/5/81
Item
Description
,
Nomber
and Reference
-
1-8
Correct Settlement Calculations
(Closed)
Verified settlement calculations have
been made subsequent to surcharge operations (RE:
Settlement calculations will be revised after
calculation No. S-105 File 8230, dated February 14,
completion of diesel generator bailding sur-
1980), results of these calculations have been
charge operations.
included in response to question 27 of 50.54(f)
requests.
Review of this response and results
(Question 23, Subsection 3.4, Para 25-13)
of calculations are being made by NRC office of
NRR Ceotechnical Branch.
(Question 1, Apx I, Page I-6, Para C.4.a)
1-9
Schedule audits of the Geotechnical Section on a six
(Closed)
Review audits of Bechtel Geotechnical
month basis.
dated February 26-28, 1979, and August 29-31, 1979,
and February 26-28, 1980.
A recent Bechtel QA audit of Bechtel Geotech Section
was conducted in February 1979. Additional audits will
Audits are scheduled for every six months.
be performed in this area on a six month cycle until
completion of soil work.
(Question 1, Apx I, Page I-7, Para C.4.c)
1 - 10
Review drawings for possible effect of vertical duct
(Closed)
See Action Item 23-14 for NRC review.
bank restrictions.
1 - 11
Complete actions in response to DRUCL audit.
(Closed)
See Action Item 23-1 for NRC review.
1 - 12
Revise EDP 4-49 to incorporate clarifications and
(Closed)
See Action Item 23-3 for NRC review.
instructors for use of specification change notices.
1 - 13
Schedule audits of each design discipline calculations
(Open)
CPCo commitment not completed.
on a yearly basis.
1 - 14
Re-evaluate construction equipment used for compaction.
(Closed)
Verified 50.54(f) submittal, " Report on
Test Fill Program" which provides documentation for
Compaction equipment currently in use has been qualified
qualification of compaction equipment currently in
and construction notified of parameters governing use of
use, Spec. C-211, attachment 1, provides a list of
equipment.
equipment to be used and compaction requirements.
(Question 23, Subsection 3.6.,
Page 23-18)
(Question 1, Apx I, Page I-11, Para C.1)
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Sheet 19 of 21
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1/5/81
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Action
Action Item
Item
Description
Number
and Reference
,
1 - 15
Assign Field Soils Engineer and Soils Engineer from
(Closed)
Verified Spec. C-211 Para 8.3.5. requires
design section.
soil work to be performed under direction of
qualified onsite soils engineer.
One full time and one part time onsite Geotechnical
Soils Engineer has been assigned.
(Question 23, Subsection 3.7., Page 23-20)
(Question 1, Apx I, Page I-ll, Para C.2.a)
1 - 16
Review construction specifications and procedurea to
_Open)
See Action Item 23-8 , CPCo Commitment
(
identify equipment requiring qualifications.
not completed.
1 - 17
Review field procedure FPG-3.00 to ensure clarify and
(Llosed) See Action Item 23-7a for NRC review.
completeness.
1 - 18
PQCI 1.02 has been revised to incorporate the specific
(closed) Verified PQCI 1.02 (Rev. 5) has been
'
characteristics to be verified by Quality Control,
revised to include specific characteristics to be
inspected.
(Question 23, Subsection 3.8, Page 23-22)
(Question 1, Apx I, Page I-16, Para C.I.a)
.
Project Quality Control Instructions C-1.02 was revised
(Closed) Verified C-1.02, Rev. 5 requires compaction
to include verification of use of qualified equipment &
equipment to be qualified and will adequately com-
,
compliance with qualified procedures.
pact the material being placed and provides for a
daily soil placement report.
(Question 23, Subsection 3.6, Page 23-18)
(Question 1, Apx I, Page I-16, Para C.I.a)
(Question 1, Apx I, Page I-17, Para C.4.a)
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Sheet 20 of 21
1/5/81
.
Action
Action Item
Item
Description
Number
and Reference
1 - 18
PQCI 1.02 was revised to provide specific inspection
(Closed) Verified PQCI 1.02 (Rev. 5) Para 2.3
Cont'
requirements for verifying soil moisture contents,
has been revised to provide inspection of moisture
rather than surveillance.
testing.
(Question 23, Subsection 3.9, Para 23-24)
1 - 19
Complete in depth review of soil test results
(_ Closed) Reviewed and verified report entitled.
Geotechnical Services has completed an investigation
" Review of U. S. Testing Field and Laboratory
which includes an in depth review of testing performed
Construction Test Data on Soil Uses as Fill",
by U. S. Testing and reported test results.
dated July, 1979 was performed.
(Question 23, Subsection 3.10, Page 23-27)
(Question 1, Apx I, Page I-17, Para C.3.a)
An in depth soils investigation program provides verifi-
(closed) Verified that berings test pits,
cation of the acceptability of the soils or identified
laboratory tests, analysis of past test results
any nonconformances requiring further remedial action.
and plots of all tesLs have been performed as part
of the investigation of the subsurface materials.
(Question 23, Subsection 3.8, Page 23-23)
This information has been submitted to the NRC and
is currently under review by NRC office of NRR,
(Question 1, Apx I, Page I-17, Para 3.a)
Geotechnical Branch.
1 - 20
Perform in depth audits of U. S. Testing.
(Closed)
See Action Item 23-15 for NRC review.
1 - 21
Review of QCI's for surveillance call outs.
(Closed) See Action Item 23-19 for NRC review.
1 - 21A
Modify QCI's Based on Item 1-21.
(0 pen)
CPCo commitment not completed.
1 - 22
Evaluate documentation call outs on QCI's
(Closed) See Action Item 23-19 for NRC review.
1 - 23
Incorporate scientific sampling plans for
(Closed { See Action Item 23-34 for NRC review,
inspection.
1 - 24
Complete in depth review of Bechtel trend program.
(closed)
See Action Items 23-35 and 23-36 for
NRC review.
o
Sheet 21 of 21
.
1/5/81
,
3
Action
Action Item
Item
Description
=
,
Wumber
and Reference
1 - 25
Conduct QA Training.
(open) See Action Items 23-16 and 23-17 for NRC
review.
(Uni.ut.bered) Selection of protor curves will no longer be a problem
(open) A review of this commitment resulted in
because each field density. test will be accompanied by
an item of noncompliance as discussed in paragraph
a separate. laboratory standard which will provide a
3.(c) of this report.
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.
(Question 23, Subsection 3.10, Page 23-27)
(Question 1, Apx I, Page I-17, Para C.4a)
(Unnumbered)
Specifications wer- revised to provide more definition
(Closed) Verified spec. C-211, Rev. 12, Para 8.4
requirement for soil moisture testing.
(moisture control) has been revised to provide
specific requirements for moisture testing.
(Question 1, Apx I, Page I-16, Para C.2.a.)
S ec. C-210 and 211 were revised to incorporate inter-
(open)
Interpretations had not been identified or
P
(Unnumbered).
pretations that affected specification requirements.
evidence of being incorporated into specifications.
(Question 23, Subsection 3.2.,
Page 23-8)
(Question 1, Apx I, Page 1-6, Page C.1.a)
(Unnumbered). The requirements for the' control of testing were
(Closed) Reviewed and verified Spec. C-208, Rev. 20 i
adjusted, requiring the testing subcontractor to
20, Para 9.1.3. to require all field devsity tests
l
check all field density tests for cohesive material
to be checked to the zero-air voids curve.
I
1
against the zero-air-voids ~ curve.
(Question 23, Subsection 3 10, Page 23-27)
(Unnumbered)
.PQCI SC-1.05 was revised to add more stringent
require-
(Closed) Verified PQCI 1.05, Rev. 11 was revised
ments for in process inspections of U. S. Testing.
to include requirements for inspecting in process
testing activities.
(Question 23, Subsection 3.10, Page 23-27)
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