ML20005B177
| ML20005B177 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/25/1981 |
| From: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20005B170 | List: |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8107060409 | |
| Download: ML20005B177 (25) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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CONSUMERS POWER COMPANY ) Docket Nos. 50-329 OM & OL-
) 50-330 OM & OL (Midland Plant, Units 1 and 2))
MATERIAL FACTS AS TO WHICH.THERE EXTST GENUINE ISSUES TO BE HEARD A. Staff Allegation. The Staff alleges that there exists nc material fact as to which a genuine issue is to be heard concerning:
"A. The following quality assurance deficiencies involving the settlement of the diesel gen-erator building and soil activities at the Midland site are adequate bases to refuse to grant a construction permit...."
Consumers Power's Response. This is inac-curate. As Consumers Power Response in Opposition to the NRC Staff's Motion for Summary Disposition sets out:
- 1. The standard under which a construction permit can be denied is not met by the facts set forth in the Staff's Motion describing the alleged quality deficiencies involving the Midland settlement problems.
- 2. The Staff's Motion inaccurately states the standard under which the Commission may re-fuse to grant a construction permit (and hence justify the suspension of a construc-tion permit).
- 3. The Staff's Motion and its supporting affi-davits imply that Gallagher, Gilray or some-one else at the NRC reviewed Consumers Power's
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() response to question 23 prior to the issuance of the December 6, 1979 Order. The inference presented is that one of the bases.of the Order was this review and a decision.upon the review, that the response was inadequate.
- a. These affidavits also present.a contrary inference that neither Gilray Gallagher nor anyone else at the NRC reviewed Consumers Power's response to question 23 prior to their issuance of the December 6, 1979 Order.
- b. The deposition testimony of.Gilray, Gallagher and otners contradict the implications in the affidavits that either of them or anyone else at the NRC reviewed Consumers Power's Response to
-question 23 prior to the issuance of the
, December 6, 1979 Order.
- 4. There are material disputed facts as to the necessity for changes in the Midland quality assurance program and its implementation be-fore construction could continue.
- 5. There are disputed material facts concerning whether the actions taken by Consumers Power prior to December 6, 1979 were adequate to correct any quality assurance deficiencies to
-permit construction to continue.
- 6. The conclusion in Gilray's affidavit which states that Consumers Power's' response to question 23 is still "not satisfactory,"
implying that the Midland quality. assurance program implementation is inadequate contra-dicts statements in his deposition.
- 7. There are disputed material facts as to whether any of the alleged deficiencies were uncorrectable.
! A.l. Staff Allegation. The Staff alleges that l there existed no material fact as to which a genuine issue
! is to be heard concerning:
l "1. Inconsistencies between construction speci-fx fications and consultant reports which ex-l
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I') isted between 1973 through the substantial reduction in soils construction during 1978-1979 without correction."
Consumers Power's Response. This is in-accu. ate. Among other things, as Consumers Power's answer to 50.04 (f) question 23 (Consumers Power Response,. Attach-ment 6) demonstrates, as of December 6, 1979:
- 1. A possible quality assurance deficiency had been identified in the possible.interpre-tation problems resulting when.the Dames &
Moore Consulting Report containing speci-fication infnrmation conflicting with that in the PSAR was attached to the PSAR. As Consumers Power response to question 23 notes the information contained in the consultant report was subject to being misconstrued as a
[ construction] commitment. Therefore, the Staff description of this problem is even initially incorrect: one consulting report was involved -- Dames & Moore's -- not sev-eral as the Staff's list of Material Facts states.
- 2. Immediate corrective action was taken to remedy the problem in the soils area. The Dames & Moore report was reviewed, its rec-ommendations identified and dispositioned.
- 3. By December 1, 1979 Engineering Department Procedure 4.22 was revised to preclude re-l petition of similar deficiencies.
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- 4. Action was initiated to insure that no other inconsistencies existed between the construc-i tion specifications in the SAR and other l consultant reports. Consultant Reports were not attached to the SAR but portions of them were extracted and incorporated into the SAR l text. A program was' instituted to re-review l
the FSAR commitments to assure that the commitments were adequately reflected in l project design documents. (Part 2 of Consumers t
Power response to question 23 more fully l describes this.)
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s A.2. Staff Allegation. The Staff alleges that there exists no material fact as to which a genuine issue is to be heard concerning:
"2. Lack of formal revisions of specifications to reflect clarification of specification re-quirements which existed from as early as June 1974 through the substantial _redaction in soils construction during 1978-79 without correction."
Consumers Power's Response. This is inac-curate. Among other things, as Consumers Power's answer to 50.54 (f) question 23 (Consumers Power Response, Attachment 6, (Q 23 pp. 23-8-11) demonstrates, as of December 6, 1979:
- 1. A possible quality assurance deficiency had been identified in a conflict that existea between sections of Specificatior C-210 relating to a laboratory standard. As Consumers Power's response to question 23 notes, in-teroffice memoranda, memoranda, telexes, TWX's etc. were used to clarify the intent of the specifications. These clarifications may have been interpreted by the user as modi-fying the specifications without formally changing wording.
- 2. On April 3 and 12. 1979 the Midland Project Engineering Group Supervisors were rein-structed concerning the procedurally correct
, eethcd of implementing specification changes.
l Engineering Department Project Instruction 4.49.1 was revised to prohibit interoffice memoranda, telexes, etc. from changing the requirements of a specification.
- 3. In late 1977 a review of the references, tolerances and clarity of the specifications was undertaken by Bechtel and Consumers l Power. This study resulted in revisions of several specifications.
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(~') 4. In addition, Bechtel and Consumers Power per-formed a dimensional tolerance study to evaluate drawing and specification tolerances and clarity. Concluding in early 1978, this study preceded the majority of the mechanical and electrical installations. A review of the remaining construction speci-fications was completed by June of 1979.
[ Response to Q. 23 p. 23-80 and Question 1, Appendix 1, Sections D.2.b-c, Page I-8).
- 5. A review of interoffice memoranda,. telexes, <
etc. was planned to determine if any had in-formally modified a specification require-ment. If such a possible modification af-fected completed or future work, a formal change would be issued and remedial action taken. This was planned for all specifi-cations applying to construction of Q-Listed items. A similar project was planned for the procurement of Q-listed items.
- 6. A specific review of the FSAR and speci-fication requirements for the qualification of electrical and mechanical components was made part of the corrective action relating to Consumers Power 50.55(e) report on com-ponent qualifications. [ Response to Q 23, Part 3, Q. 23 p. 23-80 and Question 1, Ap-pendix I, Section D.2.C., Page I-8).
A.3. Staff Allegation. The Staff alleges that there exists no material fact as to which a genuine issue is to be heard concerning:
"3. Inconsistencies of design basis within the i FSAR relating to diesel genericor fill ma-l terial and settlement values...from late 1977 l until FSAR revision 18 dated February 28, l 1979."
i Consumers Power's Response. This is inac-curate. Among other things, as Consumers Power's answer to
- 50. 54 (f) question 23 (Consumers Power Response, Attachment
- 6, (Q 23 pp. 23-10-13) demonstrates, as of December 6, 1979
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() 1. A possible quality assurance deficiency had been identified involving an inconsistency within the FSAR relating to diesel generator building fill material and settlement. As Consumers Power's response to question 23 stated, when the FSAR was prepared the major
-backfill operations were already completed.
Hence, Subsections 2.5.4 and 3.8.5 relating to bettlement values were not subjected to any further review. Because these two sub-sections were prepared by two different organizations neither was aware of.the in-consistency. The same situation explains the inconsistency between subsection 2.5.4 and the project design drawing (7220-C-45) relating to the fill material.
- 2. As of February 28, 1979 FSAR Revision 18 ,
corrected these inconsistencies.
- 3. A study was completed by November, 1979 which
.. examined procedure and practices for the l preparation and control of the FSAR; any necessary procedural changes would be made.
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- 4. By November, 1979 action was initiated to preclude any future inconsistencies by re-4 vising Engineering Department Project In-l struction 4.1.1 to state that all specifi-cation changes, not just " major changes" will l-be reviewed for consistency with the FSAR.
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- 5. By November 1979 a final review and update of the PSAR Commitment List was begun. Before i November 1979 a review of FSAR sections was initiated. (This is described more fully in the Response to Question 23, Part (2), pp.
23-41-45).
6.- To verify the effectiveness of the FSAR re-view an audit'was done once during the FSAR review and another planned after.its com-pletion. [ Response to Question 23, Part (3),
- p.23-88a and Question 23, Part (2), Section 5.0, p. 48] .
A.4. Staff Allegation. The Staff alleges that there exists no material fact as to which a genuine issue is i
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- (_) to be heard concerning
"4. Inconsistencies between the settlement cal-culations and the original design basis of the diesel-generator building which existed from March 1977 until it was identified during an NRC investigation in 1978."
Consumers Power's Response. This is inac-curate. Among other things, as Consumers Power's nnswer to 50.54 (f) question 23 (Consumers Power Response, Attachment 6,.(Q 23 pp. 23-12-13) demonstrates, as of December 6, 1979:
- 1. A possible quality assurance deficiency had been identified in that the fic.21 diesel generator building design configuration (a s described in the FSAR) differed from the preliminary information. The reason for.this is that the initial settlement calculations were performed by Geotechnical Services based on preliminary information from Project Engineering.. It was subsequently determined that the change in foundation design would have'an insignificant effect on the settle-ment calculation.
- 2. As of' November 1979 Consumers Power planned to revise settlement calculations after the completion of the diesel generator building surcharge operation.
- 3. On April 12, 1979 an interoffice memorandum l was issued to alert personnel of the need to revise or annotate. calculations to reflect current design status. Geotechnical Services Procedure FP-6437 was being revised to
, require that calculations be annotated to l
reflect current design status. Engineering Department Procedure 4.37 was similiarly revised.
- 4. Action'was taken to determine if this was an isolated cane. Quality Assurance audits of Geotechnicai-Services done in February and August 1979 determined it was. Quality
- Engineering surveys and Quality Assurance monitorings were planned to verify future gs coordination of design documents by Geotech-s_) nical Services-and Project Engineering.
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A.S. Staff Allegation. The Staff alleges that there (a~')
exists no material fact as to which a genuine issue is to be heard concerning:
"5. Inadequate design coordination in the design of the duct bank."
Consumers Power's Response. This is inac-curate. Among other. things, as Consumers Power's answer to
- 50. 54 (f) question 23 (Consumers Power Response, Attachment 6, (Q 23 pp. 23-14-16) demonstrates, as of December 6, 1979:
- 1. A possible quality assurance deficiency had been identified in~the four vertical duct banks that were designed and constructed without sufficient clearance to allow for
. relative vertical movement between the duct banks and the building footings.
- 2. By November, 1979, provisions were made to allow independent vertical movement between the diesel generator building and the duct banks. Bechtel Project Engineering reviewed 44 similar buried electrical duct banks. The review fcund nonsafety related transformer pads experiencing differential settlement which may have been exagerated by the duct bank interface. However, settlement was not com-pletely restricted.
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( 3. Modification of Civil / Structural Design Criteria 7220-C-501 was begun by November, 1979 to require that a duct bank penetration shall be designed to eliminate the possi-bility of a nonspecific size duct interacting with the structure. At the same time the civil standard detail drawings were being re-vised to show horizontal and vertical clear-ance requi ements for duct bank penetrations.
- 4. By November, 1979 Bechtel Quality Assurance
! had completed audits in the area of design l coordination which indicate there was no generic problem.
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(_) A.6. . Staff Allegation. The Staff alleges that there exists no material fact as to which a genuine issue is to.be heard concerning:
"6. Insufficient compactive effort used.in back-fill operation which existed from.the incep-tion of the plant fill operation.in 1974 through the substantial reduction.in soils-construction in 1978-79."
Consumers Power's Response. This is inac-curate. Among other things, as Consumers Power's answer to 50.54 (f) question 23 (Consumers Power Response, Attachment
! 6, (Q 23 pp. 23-17-18) demonstrates, as of December 6, 1979:
- 1. A possible quality assarance deficiency had been identified in the insufficient com-pactive effort.used in the backfill.oper-ation. As Consumers Power's response to question 23 notes, the reason for.this was that there were no field control documents or procedures to define requirements for the qualification of soils compaction equipment.
There were no control documents to govern the requirement for control measures pertaining to soils placement and compaction. Reliance was put on in-place test results or.upon their evaluations'for evaluating compaction equipment.
- 2. By November 1979 remedial action.had been taken to qualify compaction equipment then in 1
use and Construction had been notified of the parameters. governing the use of this equip-ment. In addition, Project Quality Control Instruction C-1.02 was-revised to include verification of the use of qualified equip-ment and compliance with qualified proced-ures.
-3. -Action was taken to establish responsibility for soil placement and compaction. Field instructicns were.being revised to establish requirements for demonstrating equipment
.,, capability, including responsibility for
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equipment approval and providing records identifying this capability. The Quality Assurance Department planned to issue a Nuclear Quality Assurance Manual amendment to clarify the measures for qualifying equipment under specified conditions. The Engineering Department planned to clarify specifications and Construction planned to prepare pro-cedures (governing the soils compaction equipment)_to implement the requirements of this manual.
- 4. By November, 1979 a review had. determined that no other equipment requiring quali-fication had not yet been qualified.
A.7. Staff Allegation. The Staff alleges that there exists no material fact as to which a genuine issue is to be heard concerning:
"7. Insufficient technical direction in the field which existed from 1974 through the sub-stantial reduction in soils construction in 1978-79."
Consumers Power's Response. This is inac-curate. Among other things, as Consumers Power's answer to 50.54 (f) question 23 (Consumers Power Response, Attachment
[ 6, _(Q 23 pp. 23-19-20) demonstrates, as of December 6, 1979:
- 1. A possible quality assurance deficiency had l been identified in the insufficient. technical direction in the field. As Consumers Power's response to question 23 notes, filling op-erations were performed under the technical ,
supervision of a qualified Soils Engineer.
However, technical direction and supervision were not properly deployed to overcome the lack of documented instructions and pro-
, cedural controls.
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- 2. Remedial action was taken by November, 1979.
One fulltime and one part-time onsite Geo-I technical Soils Engineer were assigned to j 73 provide technical direction and monitor the i
x_) process.
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[~)' 3. By November, 1979 Field Instruction FIC 1.100
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established responsibilities for performing soils placement and compaction.
- 4. In addition, Field Procedure FPG-3.000, con-cerning the duties and responsibilities of Field Engineers and Field Craft. Supervision, was reviewed for clarity and completed.
[ Response to-Question 23, Part (3), p. 23-80, and Question 1, Appendix I, Section 0.2, p.
I-ll].
- 5. By November, 1979 ConsuLers Power planned a review of design documents, instructions, and procedures for those activities which require in process controls.
- 6. In addition, Consumers Power confirmed its overinspection for soils placement, utilizing a specific overinspection plan. [ Response to Question 23, Part (3), p. 23-89 and Question I, Appendix I, Section C.2.b., p. 1-11; and Section C.l.c., p. I-16].
A.8. Staff Allegation. The Staff alleges that there exists no mater *al fact as to which a genuine issue is to be heard concerning:
"8. Inadequate quality control inspection of placement of fill which existed from 1974 through the substantial reduction in soils construction in 1978-79."
Consumers Power's Response. This is inac-curate. Among other things as Consumers Power's answer to 50.54 (f) question 23 (Consumers Power Response, Attachment
! 6, (Q 23 pp. 23-21-22) demonstrates, as of December 6, 1979:
- 1. A possible quality assurance deficiency had been identified with respect to inadequate Quality Control inspection of the placement of fill. As Consumers Power's response to question 23 outlines, this was caused by the lack of sufficient specificity in Control Document SP/ PSP /G-6.l's requirements for the
,-~ preparatior of inspection instructions.
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i ). 2. Remedial action was taken before November, 1979. PQCI C-1.02 was revised to incorporate the specific characteristics to be. verified by Quality Control. An in-depth soils in-vestigation program was instituted to provide verification of the acceptability of the soils or identity any nonconformance re-quiring further remedial action.
- 3. The control document was being revised to pro-vide requirements for inspection planning specificity and for the utilization of sci-entific sampling rather than percentage sampling.
- 4. A review of QCIs in use was planned to as-certain that provisions have been included consistent with the revised control document.
- 5. Consumers Power had an ongoing overinspection program in the soils area. [Respcnce to Question 23, Part (3), p. 23-89, and Question 1, Appendix I, Section C.2.b, p..I-ll; and Section C.l.c p. I-16).
- 6. In addition, there were ongoing reviews to clarify the following areas: field pro-cedures, QCIs, the adequacy of construction and the Bechtel inspection process, onsite subcontractor QA manuals, and the " surveil-lance" mode. (These are described more fully in the Response to Question 23, Part (3), p.
23-90, and Question 1, Appendix A, Section D.5.b-c, p. I-19).
A.9. Staff Allegation. The Staff alleges that there exists no material fact as to which a genuine issue is to be heard concerning:
"9. Inadequate soil moisture testing which ex-isted from 1974 through the substantial reduction in soils construction in 19'/S-79. "
Consumers Power's Response. This is inac-curate. Among other things, as Consumers Power's answer to 50.54 (f) question 23 (Consumers Power Response, Attachment fs
'd
y j 6, (Q 23 pp. 23-23-25) demonstrates, as of December 6, 1979:
- 1. A possible quality assurance deficiency had been identified in inadequate soil moisture testing. As Consumers Power's response to question 23 described the reason for this was that a control document did not. require sufficient specificity for establishing an inspection program and for the preparation of inspection instructions.
- 2. Remedial action was completed by November, 1979. The specifications were revised to provide more definitive requirements for soil moisture testing, verification of soil. moist-ure content and responsibility for performing soils placement and compaction.
- 3. Revisions were planned to provide require-ments for inspection planning specificity and for the utilization of scientific sampling rather than percentage sampling. Engineering Department Project Instructions were revised to provide controlled and uniform inter-pretation of specification requirements. By April, 1979, Midland Project Engineering Group Supervisors were reinstructed con-cerning the procedurally correct methods of implementing specification changes.
- 4. A commitment to take generic corrective actions was made. Review of QCIs was planned to ascertain that provisions have been in-cluded consistent with the revised control document. A review of interoffice memoranda, telexes, etc. relating to specifications for construction and selected procurements of Q-Listed items was initiated to ensure that no informal clarifications modified a specifi-cation requirement.
A.10. Staff Allegation. The Staff alleges that there exists no material fact as to which a genuine issue is to be heard concerning:
"10. Incorrect soil test results which existed from 1975 through the substantial reduction in soils construction in 1978-79."
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() Consumers Power's Response. This is inac-curate. Among other things, as Consumers Power's answer to
- 50. 54 (f) question 23 (Consumers Power Response, Attachment 6, (Q 23 pp. 23-26-28) demonstrates, as of December 6, 1979:
- 1. A possible quality assurance defic.iency had been identified in the incorrect soil test results. Consumers Power's response to question 23 noted that surveillance and test report reviews did not identify these errors and inconsistencies.
- 2. Remedial actions were taken by November, 1979. Geotechnical Services complete 1 an investigation in order to identify the type of testing errors made. Based on this, the requirements for the control of testing were adjusted and a. specification change was issued. More stringent requirements for in-process inspection of U.S. Testing's soil testing activities were instituted. An in-depth soils investigation program provided verification of the acceptability of the soils and identified any nonccnformances requiring further remedial action.
- 3. Guidelines for the surveillance of testing operations were being developed to bo included in the Yield Instructions for the onsite Soils 'angineer.
- 4. By November, 1979 action was taken to require U.S. Testing to demonstrate that testing
- procedures, equipment, and personnel used for quality verification testing (for other tnan NDE and soils) were, and are, capable of providing accurate test results. Plans were made to sample.U.S. Testing's test reports (for other than NDE and soils) to ascertain that results evidence conformance to testing requirements.
- 5. An evaluation.of Quality Control Instructions was planned to ensure that the documentation characteristics to be inspected (i.e., sur-veillance and review callouts) are clearly specified. This included necessary revision
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- to QCIs. [ Response to Question 23, Part (3),
- p. 23-82 and Question 1, Appendix 1, Section D.3.a, Page I-18 and Section D.1, p. I-18).
- 6. Consumers Power planned to perform over-inspection of the U.S. Testing soils testing activities and reports, utilizing a specific plan. [ Response to Question 23, Part (3), p.
23-89, and Question 1, Appendix I, Section C.3.c, p. I-17].
A..ll. Staff Allegation. The Staff alleges that there exists no material fact as to which a genuine issue is to be heard concerning:
"ll. Inadequate subcontractor test procedure which existed from 1974 through the substantial reduction in soils construction in 1978-79."
Consumers Power's Response. This is inac-'
curate. Among other things, as Consumers Power's answer to
- 50. 54 ( f) question 23 (Consumers Power Response, Attachment 6, (Q 23 pp. 23-29-31) demonstrates, as of December 6, 1979:
- 1. A possible quality assurance deficiency was identified in inadequate subcontractor test procedures.
- 2. By November, 1979 Geotechnical Services had completed an investigation which included an in-depth review of testing performed by U.S.
Testing and the test results. Based on this, the requirements for the control of testing were adjusted and a specification change was issued. One full-time and one part-time onsite Geotechnical Soils Engineer was as-signed to review U.S. Testing's procedures and monitor their implementation.
- 3. Bechtel completed an in-depth audit.of U.S.
Testing operations in 1979. [ Response to Question 23, Part (3), p. 23-81 and Question 1, Appendix I, Section C.4.b, p. I-18; and Section D.3.C, p. I-18].
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- 4. Field Instruction FIC 1.100 was prepared by November, 1979 and established responsibility for performing surveillance of testing opera-tions.
- 5. By November, 1979 Consumers Power made a commitment to review design doctaents, in-structions, and procedures for those acti-vities requiring in-process controls to assess the adequacy of existing procedural controls and technical direction. Plans were made to require U.S. Testing to demonstrate that testing procedures, equipment, and personnel used for quality verification
. testing (for other than NDE and soils). were, and are, capable of providing accurate test results.
- 6. During May and August of 1977, a review of all QCI's were performed jointly by Consumers Power and Bechtel. [ Response to Question 1, Appendix I, Section D.5.a. p. I-19]. In 1978 CPCo implemented an overinspection plan to independently verify the adequacy of con-struction and the Bechtel inspection process with the exception of civil activities.
[ Response to Question 23, Part (3), p. 23-90 and Question 1, Appendix I, Section D.5.c, p.
1-19]. Consumers Power, also, reviewed onsite subcontractor QA manuals and covers their work in the audit process. (Pesponse to Question 23, Part (3), p. 33-90 and Question 1, Appendix I, Section D.5.d, p. I-9].
4 A.12. Staff Allegation. The Staff alleges that on December 6, 1979, there exista no material fact as to
, which a genuine issue is to be heard concerning:
"12. Inadequate corrective action for repetitive nonconforming conditions which existed from 1974 through the substantial reduction in soils construction in 1978-79."
Consumers Power's Response. This is inac-curate. _Among other things, as Consumers Power's answer to 50 54 (f) question 23 (Consumers Power Response, Attachment C)
L
() 6, (Q 23 pp. 23-32-33) demonstrates, as of December 6, 1979:
- 1. A possible quality assurance deficiency was identified in inadequate corrective action for repetitive nonconforming conditions. As Consumers Power's response to question 23 explains the conditions under which non-conformances are considered to be repetitive were not adequately defined in the control documents.
- 2. Control documents were being revised to provide an improved definition of imple-menting requirements for identifying re-petitive nonconforming conditions.
- 3. In 1979 an in-depth training session was given to Midland QA Engineers covering the settlement problem and methods to identify similar conditions in the future. [ Response to Question 23, Part (3), p. 23-81 and Ques-tion 1, Appendix I, Section D.1.b., p. I-22].
- 4. In 1979 an in-depth review of the Bechtel trend program data was undertaken by Bechtel QA management to ensure the identification of any other similar areas that were not an-alyzed in sufficient depth in the past re-
, views. [ Response to Question 23, Part (3),
- p. 23-82 and Question 1, Appendix I, Section D.l.a, p. I-22).
- 5. Plans were made to have the Quality Assurance Department to review nonconformance reports to identify any repetitive nonconforming conditions pertaining to product type or activity, or pertaining to nonconformance cause.
A.13. Staff Allegation. The Staff alleges that there exists no material fact as to which a genuine issue is to be heard concerning:
"13. Inadequate quality assurance auditing and monitoring of the plant fill work activities which existed from'1974 through the sub-stantial reduction in soils construction in 1978-79."
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( T Consumers Power's Response. This is inac-
%J curate. Among other things, as Consumers Power's answer to
- 50. 54 (f) question 23 (Consumers Power Response, Attachment 6, (Q 23 pp. 23-34-35) demonstrates, as of December 6, 1979:
- 1. An alleged possible quality assurance de-ficiency was ide..itified in inadequate quality assurance auditing and of monitoring of plant fill work activities. As Consumers Power's response to question 23 noted Quality As-surance auditirq and monitoring was oriented more toward evaluating the degree of com-pliance with established procedures rather than toward the assessment of policy.and procedural adequacy or toward the assessment of product quality.
- 2. Consumers Power planned to revise the Quality Assurance audit.and monitoring program to emphasize the need for evaluating policy and procedural adequacy and assessment of product quality. A specialized audit training pro-gram was planned to develop and implement guidance for this.
- 3. In addition, an in-depth training session was
- given to all Consumers Power and Bechtel QA i
Engineers and Auditors to increase their awareness of the settlement problem and to discuss auditing and monitoring techniques to increase audit effectiveness. [ Response to Question 23, Part (3), p. 23-82 and Question 1, Ar. adix I, Section D.2, p. I-22).
s B. Staff Allegation. The Staff alleges that there
! exists no material fact as to which a genuine issue is to be heard concerning:
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! "B. This quality assurance breakdown cause [ sic]
compaction of the soils at the Midland site."
Consutners Power's Response. This is inac-curate. As Consumer's Power Response in Opposition to the l ,, o
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NRC Staff's Motion for Summary Disposition sets out:
- 1. There are material disputed facts as to whether a quality atsurance " breakdown" occurred at Midland.
- 2. There are material disputed facts a; to whether ..ny quality assurance deficiencies
" caused" inadequate soils compaction at Midland.
C. Staff Allegation. The staff alleges that there exists no material fact as to which a genuine issue is to be 3rd concerning:
"C. Inadequate compaction at the Midland site caused settlement problcms at numerous safety related. structures. "
Consumers Power's Response. This is inac-curate. As Consumer's Power Response in Opposition to the NRC Staff's Motion for Summary Disposition sets out:
- 1. The Staff has not sustained its burden in proving that inadequate soils compaction is material to the quality assurance por-tic n of the December 6, 1979 Order.
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'(_) UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
)
In the Matter of )
)
CONSUMERS POWER COMPANY ) Docket Nos. 50-329 OM & OL
) 50-330 OM & OL (Midland Plant, Units 1 and 2))
)
)
CERTIFICATE OF SERVICE I, JoAnne G. Bloom, hereby certify that a copy of Consumers Power Company Response In Opposition To The NRC Staff's Motion For Summary Disposition On The Issue Of Quality. Assurance was served upon all persons shown in the attached service list by deposit in the United States mail, first class, this 25th day of May, 1981. 'In addition, a copy was sent by American Airlines Priority Package Service to Judges Bechhoefer, Cowan and Decker.
s' JoAnne G.CBl om n
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(.
\) SERVICE LIST Frank J. Kell'ey, Esq. Steve Galdler, Esq.
Attorney General of the 2120 Carter Avenue State of Michigan C' D="1. .ssota 55108 Stewart H. Freeman, Esq.
Assistant Attorney General Atomic Safety & Licensing Appeal Pnl.
Gregory T. Taylor, Esq. U.S. Nuclear Regulatory Commission Assistant Attorney General Washington, D.C. 20555 Environmental Protection Div.
-720 Law Building Mr. C. R. Stephens Lansing, Michigan 48913 Chief, Docketing & Service Section Office of the Secretary Myron M. Cherry, Esq. U.S. Nuclear Regulatory Commission One IBM Plaza Washington, D.C. 20555 Suite 4,C1 Chicago, Illinois 60611 Ms. Mary Sinclair 5711 Summerset Street Mr. Wendell H.-Marshall Midland, Michigan 48640 RFD 10 Midland, Michigan 48640 William D. Paton, Esq.
Counsel for the NRC Staff Charles Bechhoefer, Esq. U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Bd. Pnl. Washington, D.C. 20555 U.S. Nuclear Regulatory Com.-
Washington, D.C. 20555 Atomic Safety & Licensing Bd. Panel U.S. Nuclear Regulatory Commission Dr. Frederick P. Cowan Washington, D.C. 20555 6152 N. Verde Trail Apt. B-125 Barbara Stamiris Boca Raton, Florida-33433 5795 North River Road Route 3 Admin. Judge Ralph S. Decker Freeland, Michigan 48623 Route No. 4, box 190D Cambridge,. Maryland 21613 Carroll E. Mahaney l Babcock & Wilcox l P. O. Box 1260 Lynchburg, Virginia 24505 i
i James E. Brunner, Esq.
l Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 O,
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UNITED STATES OF AMERICA i
) NUCLEAR REGULATORY COMMISSION 1
In the Matter of Docket Nos. 50-329-0M 50-330-0M CONSUMERS POWER COMPANY 50-329-OL 50-330-OL (Midland, Units 1 and 2 STATE OF MICHIGAN)
)ss COUNTY OF JACKSON)
AFFIDAVIT OF BENJAMIN W. MARGUGLIO My name is Benjamin W. Marguglio. I am employed by Consumers Power Company as Director of Environmental Services and Quality Assurance.
From January, 1977 to March, 1980, I was employed by Consumers Power Company as the Director of Quality Assurance-Projects, Engineering and Construction. My duties as Director of Quality Assurance-Projects, Engineering and Construction included overseeing the preparation of
. Consumers Power Company's Response to 10 CFR 50.54 f Question 23 Regaiding Plant Fill. According to a sworn statement of Consumers' Vice President Stephen H. Howell, which is attached hereto, that Response in its original form was filed on November 13, 1979. The original Response was revised in later submittals to the NRC by Consumers. Based upon information, knowledge and belief as of November 13, 1979, the original Response to 10 CFR Question 23 Regarding Plant Fill was true and correct at the time it was filed.
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~ B Jamin W. M'rgugli a gV Subscribed and sworn to before me this 2I A day of /7c , 1981, tl
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Notary Public, Jackson County, Michigan My Commission Expires: gg g, f y f f f
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- Stephen H. Howell J Sewier Vice l>esident General Officos: 1945 West Pernell Road, Jackson, Mich3 gen 49201 e (517) 7884453 Hove-293-79 November 13, 1979 US Nuclear Regulatory Com::tission ATT: Mr. Harold R. Denton Office of Nuclear Reactor Regulation Washington, DC 20555 MIDLAND PROJECT-DOCKET NO. 50-329 and 50-330 RESPONSE TO 10 CFR 50.54 REQUEST ON PLANT FILL -
FILE: Oh85.16 UFI 71*01 SERIAL: 791h Enclosed are ten (10) copies of Revision h to Consumers Power Company's response to April 24, 1979 to your 10 CFR 50.5h(f) request dated March 21, 1979.
Revision h provides a complete response to question 23 transmitted by Mr. L. S. Rubenstein's Request for Additional Quality Assurance Information dated September 11, 1979. This response includes much of the same informa-tion that was presented to the NRC staff on September 5, 1979 except that additional infomation has been added to be responsive to staff requests made by the NRC during that meeting.
The two additional Quality Assurance Branch questions transmitted by Mr. L. S. Rubenstein's letter of September 11, 1979 are being handled as part of the normal operating license review and vill be provided in the next planned FSAR revision in January 1980.
Consumers Power Company By k.
l StephbsdH. Howell, Sr Vice President Svoin and subscribed to before me on this 10th day of November 1979.
Ya a k x. & W NotaryPubye,JacksonCountf, Michigan My commission expires September 21, 1982 CC: JGKeppla" (w/h att)
NRC, Regn n III hT WLavhead (w/att)
V Corps of Engineers s '
DOP Or pIllf N
g UNITED STATES OF AMERICA U NUCLEAR REGULATORY COMMISSION In the Matter of )
CONSUMERS PCWER COMPANY ) DOCKET NOS. 50-329-0M
) 50-330-0M (Midland, Units 1 and 2) ) 50-329-OL
) 50-330-OL
)
STATE OF MICHIGAN )
) SS COUNIT OF JACKSON )
AF7/IDAVIT OF THOMAS C. COOKE 1
Thomas C. Cooke, being duly sworn, deposes and says that he is employed by Consumers Power Company as Construction Superintendent for the l Midland Project, and that the records of Consumers Power Company show that soils placement activities for the purpose of providing support for the desig-l nated structures, and for the purpose of constructing the project dike, occurred l
l during the time periods shown on the schedule attached hereto as Appendix I.
Affiant further says that the records of Consumers Power Company show that no Q-list soils placement activities for the purpose of providing support for the l designated structures occurred after the complet* dates .
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Thomas C. Cooke Subscribed and sworn to before me this 20th day of May, 1981.
A -I- h r k e _]W A h [x l Catherine M. Carlin Notary Public, Bay Councy, MI My Commission Expires : U-16-81 O
Appsndix I to Affidavit 4
O = nt**n raoascr Selected Soil.s Placement Activity
- Starting Completion Date Date Q-List Soils Placement Structure
- Auxiliary Building electrical penetration area December 1974 November 1976 Tank Farm Area (Borated Water Storage Tanks) September 1975 August 1976 i
Service Water Structure Cantilever Section November 1976 June 1977 Diesel Generator Building October 1975 October 1977 Non-Q-List Soils Placement Dike July 1969 October 1975 "Q-list soils placement" shown is soils placement for support of the structure only.
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(q_j LIST OF ATTACHMENTS
- 1. 7,etter from James Keppler to Myron Cherry, dated December 14,
-1978.
- 2. Shewmaker Deposition Exhibit 21: Notes of February 6, 1979 meeting.
- 3. Shewmaker Deposition Transcript, pages 53,'60, 78, 107-108.
- 4. Shewmaker Deposition Exhibit 13: Notes of November 28, 1979 meeting.
- 5. Hood deposition Exhibit 15.
- 6. Consumers ' Response to 50.54 (f) Question 23, Revision 4.
- 7. Gallagher Deposition Transcript, page 68.
- 8. Gilray Deposition Transcript, pages 34, 47-50.
- 9. Shewmaker Deposition Exhibit 14.
- 10. ~ Hood Deposition Exhibits 14 and 19.
- 11. Fiorelli Deposition Transcript, pages 13-22.
- 12. Thornburg Deposition Transcript, pages 32-35.
l 13. Keppler Deposition Transcript, page 22.
l 14. Hood Deposition Exhibit 8.
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l Mr. Myron M. Q arry one I3M Plaza l Qicago, Illinois 60611
Dear Mr. Qarry:
l This is in reply to your letter of November 20, 1978, concerning the diesel generator building settlement probles at Consunars Power Company's l Midland sita and your serious assertion that "the resident inspector l may have been co-opted by Midland 9ersonnel". The information requested by your letter is provided in the anclosure.
l I would like to assure you that this office shares your interest in the proper construction of nuclear power plants. Recognizing the history of this project, the NRC has given considerabia inspection
. attention toward verifying that the licensee and its contractors are
. satisfying applicable regulatory requirenants. \ While some deficiencies in the implementation of the quality assurance programs have been found C
- during construction since the caduelding suspension in 1973, in our judg=ent these deficiencies were isolated rather than generic in nature, were resolved in a responsible manner, and did not represent a serious breakdown in quality
- assurance. [ In this regard, I have not forgotten the com=itments I made before the ASLB in 1974 and will not hesitate to reco==end strong enforcement action should a serious breakdown in quality assurance occur.
With respect to the diesel generator building settlement problem va have not yet deter =ined the basic cause of the problem nor when it occurred. We have initiated an investigation into the circu= stances of the settling problem and vill base our enforcenest actions on the findings from this investigation.
With respect to your assertion regarding the resident inspector, I have referred this matter to our Headquarters for investigation by the NRC's Office of Inspector and Auditor. You will be contacted by that office directly to obtain specific information relative to this matter.
If you have any questions regarding this response, please contact an.
Sincerely.
gg g' JamesG.KapMr--
Director Y1Nh gy -- __m u
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DEC14 378 Myren x. cherr/
Enclosure:
Infernation Requested b;
- Myron Qaerry w/acr'_J. sets ce v/anelosure and Incoming l Letter J. G. Davis. II H. D. Thornburg, II W. J. 01r. stead, ILD
- 1. Fortuna OIA
- 1. S. Beyd, NRR
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ENCLOSL*RI 1 e
- 1. Requested Information
- "In view of the seriousness of this statement 1/ and the enormous sums of money which Consumers continues to spend, I should like
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a more full explanation, including a submission or a listing of all memorandums, consnunications, letters and reviews, whether femal or informal, which form the basis for the Region III's conclusions made by you."
Su==a-v Respense ne Resident Inspector was initially informed by Consumers Power I
Company of a possible probles with the settlement of the Diesel '
Generator Building on August 21, 1978. Subsequently, on September 7,1978, Region III vaa informed that the settlement was considered reportable pursuant to 10 CTR 50.55(e). A listing of correspondence generated in connection with this natter is provided as Attachment 1. (Copies of the listed correspondence are provided)
The concerns which prompted me to raise this problem as a potential safety tasue can be su=marized as follows: .
- a. Evidence of settlement in excess of. design specifications has been observed with the Diesel Generator Building. nis i buildin's is a safety related structure in that it houses the i
- emergency diesel generators, which are required to provide j
emergency pouer to equipment important to nuclear safety in the event oi loss of normal offsite power. Our concern was l
that proper operability of the diesel generators could be
- i I
affected by the excessive settlement.
- b. De excessive settlenent of the Diesel Cenerator Building appears to be related to the fact that sufficient compaction .
of the supporting soil was not achieved. D is, in turn, appears to result from random fill material being used to support the structure rather than " controlled, compacted cohesive soils" (TSAR cos:mitment). Several other buildings or portions of foundations are also supported by random fill material. As such, although no excessive settlement of these structures had been observed to date, we are concerned that
- the potential may exist for excessive settlement which could
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Possibly affect the operability of safety related equipment.
Statement in memorandum from J. C. Keppler to H. D. nornburg dated J/ November 1,1978 "In our view, this deficiency has the potential for affecting the design adequacy of r,everal safety related etructures at the Midland site."
A.
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O 1 In that the issue is a design question and one which involves the design criteria initially reviewed and accepted by the NRC, we recommended that this problem be evaluated by the NRC's Office of Nuclear Reactor Regulation - the NRC Office responsible for assuring that the facility design meets the General Design Criteria contained in Appendiz A of 10 CFR Fart 50. This transfer of review responsibility was formally completed on November 17, 1978.
- 2. Requested Informatien "Please also tell me how you justify continued construction, in view of this serious breach of quality control, unless, of course, you are content to permit " magic" to ensure safety. I am nost concerned over what appears to be a cavalier attitude towards construction. Can it be that your organization (whether intentionally or otherwise and whether conscious or unconscious)
- is affected by the amounts of money Consumers has spent so that you blind your eyes to reality. If so, you do a disservice not only to the people of the United States but also to the utilities Do who unfortunately take advantage of such lax enforcement.
we need a serious accident before enforcement, in your mind at least, equals the importance of monetary investment?"
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Su==arv Resconse As discussed in my letter, the NRC has not yet determined fully the fundamental cause(s) that has resu*.ted in the excessive settlement of the Diesel Cenerator Bufidi=g - nor have we established the time frane associates' with the problem. We have initiated an investigatic to determine the facts associated with the problem and will base og enforcement actions on the findings from this investigation.
With respect to the safety implications of continued construction, the following considerations are important:
l
- s. The underlying philosophy of the design of nuclear power facilities and the NRC regulation of them is the defense-in-depth concept. This concept consists of three levels of safety involving: (1) the design for safety in neraal operation, providing tolerances for system malfunctions, (2) the assumption that incidents will nonetheless occur
' and the inclusion of safety systems in the facility to minimize damage and protect the public, and (3) the inclusion of systems to protect the public based on the analysis of very unlikely accidents. .
O'
In the safety desip of nuclear power plants, the objective is to. achieve a competent desip at each level and for each physical barrier provided to prevent the release of radio-activity from the plant. At the same time, it is realiaed that, although extensive efforts are made to obtain high quality, perfection can never be achieved because of the normal deficiencies in all processes involving men and materials. In fact, it se the realization that deficiencias will occur that has led t .a safety desip of reactors to be based on the defense-in-depth concept.
Saying it another way, nuclsar facilities are protected by exacting standards of design and construction, independent safety systems and redundant safety systems to provide -
protection in the unlikely event of multiple failures.
Because of " defense-in-depth," nuclear reactors do not require perfect performance and perfect quality for the protection of the health and safety of the public.
- b. The excessive settlement problem with the Diesel Generator Zuilding is recognized and will have to be resolved to the satisfaction of the NRC.
- c. The settlement' of other safety related structures is within design specifications and is being monitoredBovever, continuously.
this As such, there is no problem at this time.
matter will be considered as part of the NRC's overall evaluation of this problem.
- d. Ezeluding this soils foundation problem, which is being investigated, deficiencies identified at Midland since thehave not be cadwelding problems (1973-1971.) -
a serious breakdown in the quality assurance or quality control programs.
- e. The amount of money spent by Consumers Power Company has not been a factor in our inspection and enforcement decisions.
Wit' respect to your comments about what you characte
! while public health and safety is not predicated on error-free construction, my staff and I are every bit as concemed as you are that nuclear power plants are built with proper attention to quality.
The NRC has the authority to stop construction or operation of a f acility if there is sufficient cause to do so l
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and, in fact, has taken such action at Midland. As you know, I testified before the Midland Atomic Safety and Licensing Board in July 1974: "I want to go on record as saying that it is my position that if the Company fails to live up to its obligations
- that we're act afraid to step in and stop construction just like we did this time." I continue to stand behind that statement.
- 3. Requested Infor ation .
"In connection with the last mentioned report, page 3 bas a significant deletion whereby Consumers Power or Bechtel apparently deleted information submitted regarding what you labeled as a serious safety problen, i.e., the diesel building settlement ....
Please-let me know whether you plan to follow up with Consumers and obtain the informacion which they have withheld."
Surarv Restense
- The interim report on the settling of the Diesel Generator Building was submitted in accordance with the requirements of 10 CTR 50.55(e).
This regulation provides that an interim report on a reportable deficiency be providad if the final report can not be submitted within the 30-day period. -
C The written report of a reportable cons't uction deficiency is to include a description of the deficiency an snalysis of the safety i
implication and the corrective actions t o w , and sufficient information to permit analysis and evalu cion of the deficiency and of the corrective action. The final report will contain the above information. It should be noted that no corrective action had been taken at the time Consumers Power Company submitted the interim report and, as such, I have no basic problem with the deletion of the preliminary discussion from the Rechtel Report.
My staff has seen the full Bechtel report at the site, including the deleted section. I will assure you that the final report will satisfy the requirements of 10 CTR 50.55(e).
- 4. Requested Information "In view of all of these situations I should also like to request advance notice of any inspection which Region III intends to make at the Midland plant, so that either I or a representative on my behalf can make arrangements to be in attendance. If any inspection is to be surprise in nature. I will pledge my confidene.
to maintain the confidentiality of any such unannounced on-site visitation and inspection. I would appreciate sufficient advance notice to permit se to arrang my schedule so as to conform with any upcoming inspection (or to permit making arrangements for the
' attendance on my behalf of a representative). Please let se know I at your earliest convenience whether such arrangenents will be made." .
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Su: rare Resoonse
- The NRC has, for some time, permitted government representatives or interested members of the public to accompany NRC inspectors during an inspection. To accompany the inspector an individual must agree to follow the. " Protocol for Acconpaniment on NRC Inspections" (4 copy is enclosed)(Attachment 2) and obtain permission from the licensee for access to the site.
The resident inspector is routinely at the site 40 hcurs a week, and his inspection effort is supplanented by inspections by personnel from the Regional office. The inspections by Regional Office personnel are usually scheduled about a week in advance.
It would not be practical to routinely notify you of inspections "
sufficiently far in advance to make the necessary arrangements to accompany our inspectors. If you vocid inform us of the general time you are interested in acco=panying our inspectors, we could probably adjust inspection schedules td accomodate you.
l Your -
Most-inspections are not announced to the licensee in advance.
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maki=g arrangenents with the licensee to enter the construction would no doubt indicate an inspection were iminent.,
however, this has not proved to be an obstacle in permitting the in the pastsite ,
accompanime=t. "
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ATTACHMni 1 Docket No. 50-329 Docket No. 50-330
,CORRISPONDENCE RE1ATED TO DIF3EL CENERATOR 51II. DIN" SE"TI.EMDT 09/07/78 - Verbal notification and tracking form for licensee reports per 10 CTR 50.55(e) (Site inspector notified of possible settlement problem on 8/21/78) 09/08/78 - IE Morning Report item 09/29/78 - Interim report from licensee, Bowell to Keppler
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10/24/78 - Acknowledgement letter for 9/29/78 interim repor, 11/01/78 - Memo, Keppler to Thornburg, v/attachnents requesting transfer of lead responsibility 11/03/78 - Transmittal letter, Appendix A, and II Report Nos.
50-329/78-13 and 50-330/78-13
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11/03/73 - Memo, olmstead to Vassallo 11/07/78 - Second interim report from licensee Howell to Kappler 11/08/78 - Transmittal letter and IE Report Nos. 50-329/78-14 and 50-330/78-14 11/09/78 - Memo. Thornburg to Cover .
11/13/78 - Memo, vassallo to Engelhardt l 11/13/78 - Memo, Bryan to vassallo -
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11/17/78 - Transmittal letter and IE Report Nos. 50-329/78-12 and 50-330/78-12 11/17/78 - Transfer of lead responsibility. Reinmuth (II) to Vassallo (NR1) 11/22/78 - Acknowledgement letter for 11/7/78 interim report t
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Protocol for Accompaniment on NRC Inspections Persons who accompany on inspections, conducted by the Nuclear Regulatory Commission, Office of Inspection and Enforcement, do so under the following terms and conditions:
- 1. Persons accompanying on NRC inspections are present during the inspection as observers, not as participants. Specific approval for the accompaniment must be obtained from the Office of Inspection and Enforcement prior to an observer accompanying an NRC inspector.
- 2. Acco=paniment is to observe typical NRC inspection activities and techniques and is not .n inspection by the observer of the NRC nor of the licensee. Bance, accompaniment is limited to no more than two observers on any single inspection and to not more than ten percent of NRC inspections at any licensed facility.
- 3. Observers accompanying on NRC inspections shall not, in any asaner, interfere with the orderly conduct of the inspection.
l NEC inspectors are authorized to refuse to permit continued
! accempaginent by any individual whose conduct interferes with a fair and orderly inspection or whose conduct does not follow the -
ter=s and conditions included within this protocol. ,
{ 4. Observers accompanying on NRC inspections must stay physically present with an hRC inspector throughout thr course of-the inspection.
- 5. Observers accompanying on NRC inspections may be present during any discussion by the NRC inspector with the licenses with regsrd to inspectics of matters covered by the accompaniment.
This includes the discussion with licensee management at the conclusion of the inspection.
- 6. Observers receiving information of a proprietary or physical l
- security nature shall safeguard such information such that it ,
is not disclosed to unauthorized persons.
- 7. Observers accompanying on NRC inspections do so at their own risk.
The Nuclear Regulato.y Commission will accept no responsibility for injuries and expowre to barmful substances which may be received during the ins).tetion and will, assume no liability of any kind for action to or by the accompanyir.: individual .
Observers accompanying on NRC inspections agree to waive all
. claims of liability against the Commission.
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Frotocol for Accompaniment - 2-on NRC Inspections
- 8. The NRC will not make arrangenents for the persons accompanying the NRC inspector to gain access to the licensee's facility but will inform the licer. vee that the NRC has no objection to the specific individuals accompanying the NRC inspe ors as observers.
Specific arrangements to gain access to the licensees' facilities sust be made directly by the accompanying individual.
l Signature of Acconpanying Individual Date
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h(c I January 15,1979 MEMORANDUM FOR: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE FROM: J. B. Henderson, Division of Reactor Construction Inspection, IE
SUBJECT:
MEETING IN PREPARATION FOR MIDLAND HEARING DATE: February 6, 1979 TIME: 9:00 AM LOCATION: East / West Towers, Room 322B
. PURPOSE: To discuss the current status of Midland 1, 2 inspection j and IE input to the hearing.
PARTICIPANTS: S. Varga, NRR D. Hood, NRR W. Haass, NRR t
J. Keppler, RIII
! R. Heishman, RIII D. Hayes, RIII R. Cook, RIII i"
T. Vandel, RIII
( W. Olmstead, ELD /
l t R. Shewmaker, IE/
- j t .
1 i il Jm B. Henderson
- 01 sion of Reactor Construction Inspection Office of Inspection and Enforcement
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1 memorandum makes no reference to a show-cause order?
2 A Yes, I agree to that.
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3 Q Okay.
! 4 What, if anything, took place between the February 6
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5 6th meeting and the April 3rd memorandum, to your knowledge, I
l 0 which caused Mr. Keppler to drop the idea of a show-cause f
7 order as an enforcement action?
I C A There was a meeting held with NRR, with repre-I 4
B sentatives from the Office of the Executive Legal Director.
]
- 10 Certain other options were examined at that time. The sugges-
!! tion was made that one of the mechanisms that we had avail-u able to get a licensee to' respond was the 50.54(f) provisions.
13 As a result of that meeting which involved high-14 level management in both NRR and I&E, the decision was made 15 to put out a 50.54 (f) request. And I believe that was issued 16 March the 21st, or something in the middle of March of '79, l
l 17 and basically with the commitment that we would examine the 18 submittals made by the licensee as a result of that request
- 19 and decide on any future or further action that would have J
20 to be taken and that could include some other enforcement.
21 All right, sir.
Q 22 I take it that you are in fact the author of what I
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1 A I think by the date of 3/9/79 that decision to go '
2 with a 50.54 (f) had already been made and we were in the t
j 3 process of coming up with specific questions that we wanted thd
$ 4 Licensee to respond to.
5' Q All right.
l 6 Were you present when that decision was made at 7 the NRC to go with the 50.54 (f) ?
l 8$ A Yes.
t 0 Q By whom was the decision made?
A I believe it was a joint decision between 10 l II Mr. Case and Mr. Vassallo.
12 O Was there anybody who disagreed with that deci-13 sion?
M A I don't believe so.
15 The two pages that are attached to the first page 0
16 of Exhibit 6, are these your suggested questions to be in-I -
17 u
cluded in the 50.54 (f) ?
18 A No, they' re no t.
19 O By whom were these questions prepared?
' O A Those were prepared out in Region III.
21 0 Do you know the individual there who was respon-22 .
sible for them?
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78 1
Q Mr. Shewmaker, can you describe for us what the 2
QIality Assurance Branch position is on the overall quality 3'
assurance program at Midland as far as you know?
4 A I think that their position was that there were 5
i some minor items that they wanted to see added in the way of f
6 a QA program to try and correct the kinds of problems that 7
I&E had identified. But I don't think that they found any E l major defects in the progran as such.
I I' I Q When was that decision communicated to you, 10 j approximately?
i U' A I would say some time in November of '79.
12 Q Do you recall the items that you characterized as 13 minor that were to be added to the program?
14 A No, I do not.
15 0 All right.
6 Do you recall what I&E's position was with respect i
l 17
! to the performance aspects of the quality assurance program?
8
- A I think there were some submittals or a submittal 19 i from Region III some time in -- af ter this meeting of August 0
the 16 th .
21 0 All right, sir.
22 p You think it's contained in a document?
r I v
9
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/~N 107 O
1 Mr. Thornburg. Is that correct?
2 A That's correct. l 7 Q And was that statement made in response to
5 A I think that was sort of a restatement as to what
" the burning issue was as far as Thornburg. He was concernec I about continuation of what the program was for the future.
. 3 Again we talked a little bit about this, but again 2 it's this idea of separating the bigger QA question from the
'O question of the false statements and the soils issue.
11 Q Well, when Mr. Hood was saying that, in effect, 12 NRR's problem,is the QA on the fixes, he wasn't referring to 13 any programmatic problems, was he, that is, the matters that 14 Mr. Gilray and Mr. Haas--
15 A I don' t believe so. I think the reference there i
16 is implementation of the program.
U Q Mr. Olmstead gave everybody a few words of wisdom, l
18 did he not, about what your responsibilities would be when 18 you testified? Is that correct?
20 A That's correct.
21 Q And then Mr. Keppler, what-- Did he give his
(} 22 definition of the quality assurance breakdown?
A.s.u n .a
~
l l
i 108 l O
1 A Yes.
j 2 Q And did he say that there had not been such a I
3 quality assurance breakdown at the Midland site with respect 4 to the soils issue? Is that right?
5 A That's correct.
6 Q All right.
. . 7 Now at the top of page 2 there are the words 8 " Fermi, Zimmer and Midland are all in the same class." Does 9 that mean with respect to quality assurance performance?
10 A This is looking at it from a standpoint of how 11 many NCRs a specific plant might have, trying to compare it 12 in a numbers game.- Region III wouldn't make any distinction i
13 in those plants.
14
~
O All right.
l 15 Then it says: "What about NCRs total in last
- i 16 year? Increasing? Decreasing?"
17 Was that a question somebody asked at the meeting?
18 A This was something that I wrote down as one way 18 you might look at what's happening at the site. I don't think 20 it came up for discussion.
. 21 Q I see.
22 I
These are your notes to yourself; right?
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O RESPONSE TO QUESTION 23 i
1 1
Pa"ision 4 i 11/70 i
1
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Attachment 6
l RESPONSE TO NRC QUESTION 23 [50.54(fil TABLE OF CONTENTS RESPONSE TO OUESTION 23, PART (1) Pace Section 1
1.0 NRC QU,tSTION 2
2.0 - INTRODUCTION 2 2.1 General 4 2.2 Definitions 6
3.0 DISCUSSION AND EVALUATION 6 3.1 Category I, Item 1 8 3.2 Category I, Item 2 10 3.3 Category I, Item 3 12 3.4 Category I, Item 4 14 3.5 Category I, Item 5 17 3.6 Category II, Item 1 19 3.7 Category II, Item 2 21 3.8 Category III, Item 1 23 3.9 Category III, Item 2 26 3.10 Category III, Item 3 29 3.11 Category III, Item 4 32 3.12 Category IV, Item 1 34 3.13 Category IV, Item 2 RESPONSE TO OUESTION 23, PART (2) 36 1.0 NRC QUESTION 37 2.0 RESPONSE TO PART (2)a 39 3.0 RESPONSE TO PART (2)b 39 l 3.1 Review of the PSAR Commitment List 41 3.2 Rereview of the F. CAR 41 l 3.2.1 Organization 42 l
3.2.2 Rereview Procedure 45 3.2.3 Processing Resulting Changes 46 3.3 Review of Engineering Department j Procedure 4.22 i
47 l 4.0 RESPONSE TO PART (2)c j
48 5.0 RESPONSE TO PART (2)d l
l
(- 11 Revision 4 11/79 t
O Table of Contents (continued)
Pace Section Attachment 23-1 FSAR - SOILS VERSUS OTHER AREAS Attachment 23-2 FSAR REVIEW F*.OWCHART FSAR REVIEW DOCUMENTATION FORM, Attachment 23-3 MIDLAND PROJECT, AND EXPLANATION OF FORM l
l RESPONSE TO QUESTION 23, PART (3) 49 1.0 NRC QUESTION 50
- 2. 0 INTRODUCTION 51 3.0 DIFFERENCES BETWEEN SOILS WORK AND OTHER WORK 52 4.0 QUALITY ASSURANCE PROGRAM IMPROVEMENTS 52 4.1 Listing and Chronology of Improve-ments in General 57 4.2 Specifics of Selected Improvements 4.2.1 Review of Specifications 59 4.2.2 Bechtel QC and CPCo QA Review of Quality Control Instructions 60 CPCo QA Review and Approval of 4.2 3 Bechtel QC Administrative Procedures 61 Bechtel Resident Engineers 63 4.2.4 Bechtel Monitoring Program 4.2.5 Improvements 64 4.2.6 Quality Assurance Engineering Staffing Levels 65 4.2.7 Bechtel Quality Assurance
- Management Audits 66 Bechtel Quality Trend Program 4.2.8 Supolementary Guidelines Bechtel Topical Report, BO-TOP-1A 67 4.2.9 70 CPCo QA Inspection of Stored 4.2.10 Materials 71 4.2.11 CPCo Biennial QA Audits 72 4.2.12 CPCo QA Dverview O 111 Revision 4 11/79
. - ~ . . . _ . . .- .. -_ - - - - - . - - -_-
l 4
j Table of Contents (continued)
I Section 75 5.0 ACTION ITEM FOLLOW-UP
.i RESPONSE TO QUESTION 23, PART ( 4 )
91 i 1.0 NRC QUESTION 92 2.0 ASSESSMENT 4
t I.
4 f
i i
iv Revision 4 11/79 O
O l
RESPONSE TO QUESTION 23, PART (1) 1 1
Revision 4 11/79 O
O RESPQlSE TO CESTIO' 23, PART (1) [50.54(f)]
SD:"TIO! 1.0, NRC CUESTIO!
SLM7E*DCAL RECCEST FOR ADDI'"IQiT4 SOILS SLTTIECC E70FFATIO!
- 23. We have re/iewed your respense to question 1 of our .* arch 21, 1979 letter, "10 CFR 50.54 Eequest Regarding Plant Fill," including related 10,anenients 1979. We er supplanents in your letters dated May 31, July 9, and August find that the infomaticn provided is not sufficient for ccepletion cf cur re/iew. Acccrdingly, provide the following additimal infomation:
(1) Ycur response to questicn la does not provide sufficient infc=ation relative to the root causes of the 13 deficiencies. In crder to dete m.ine the acceptability of corrective actims for the 13 deficiencies considering the possibility that these deficiencies are of a generic nature that could affect other areas of the facility, a rnere ec plete understa x!1ng of the root cause of each deficiency is necessary.
Ac.:crdingly, provide a clearer descripticr. of the rect causes of each of the 13 deficiencies, including a detailed discussien cf the ccnditiens that existed to allow these deficiencies and the c.'angesInthat thishave teen regard,
- nade to preclude the recurrence of such deficiencies.
if centributing causes are inadequate procedures, inspecticns, specifi-cation call outs, design reviews, audits, and/or technical directien, a clear and detailed descripticn is necessary as to @.at a11 cued these ccnditions to exist and why.
f)
J Revision t.
23-1 11/79
O RESPONSE TO QUESTION 23, PART (1) [50.54(f)]
SECTION 2.0, INTRODUCTION 2.1 General Subsections 3.1 through 3.13 of this Response to Questien 23, Part (1) provide information supplementing our Responses to the NRC 10 CFR 50.54(f) Request Regarding Plant Fill for Midland Plant Units 1 and 2, Consumers Power Company Docket Numbers 50-329 and 50-330, on transmitted from CPCo (S.H. Howell) to the NRR (H.R. Denton)
April 24, 1979 and in our presentation to the Staff given Bethesda, Maryland, and documented on July 18, 1979, to I&E via our transmittal from CPCo (S.H. Howell)
(J.G. Keppler) on August 10, 1979. This introduction provides the rationale for determining the root cause of eac!. of the 13 deficiencies identified through the investigations by the NRC, CPCo, and Bechtel; comments concerning the significance of the 13 deficiencies; and an explanation of the format used in addressing each deficiency.
In arriving at the root cause, the following f actors were considered.
- a. The purpose of the quality assurance program is to provide confidence that quality-related activities the are performed in a controlled manner such that product conforms to the FSAR and design require-ments.
b.
The control measures applicable to the performance of the quality-related tasks are to provide sufficient direction and methodology to supplement the capability of the assigned personnel.
- c. Personnel assigned t' responsibility of performing the quality-related tasks are to have the required capability, knowledge, and skill (when supplemented by specifications, drawings, procedures, instructions,to satisfactorily and the prescribed control measures) perform their assigned responsibilities.
O 23-2 Revision 4 11/79
O RESPONSE TO OUESTION 23, PART (1) (50.54(f)J d.
As the quality assurance program develops and is implemented, revisions or corrections will be necessary to:
- 1. Achieve the optimum balance or relationship between personnel capabilities and the prescribed control measures
- 2. Accommodate unique or unplanned events
- 3. Incorporate related experience and state-of-the-art improvements The 13 deficiencies identified through invest'igations by Bechtel, CPCo, and the NRC are each addressed withirrespective the same intensive ef fort, The relative contribution to theeach cause of the settlement.
deficiency made to the settlement can ce that qualitatively derived from Sections 7.0 (Cause Investigation) and 8.0 (Ouality Assurance and Ouality Control 10, Aspects)1979 of the documentation transmitted on August Essentially, this documentation pointed out that the most probable causes of the settlement were as follows:
- a. In some cases, lift thickness exceed This wasthe shown capability by of the equipment being used. thickness /compactive effort tests conduct the lift to qualify compaction equipment prior to resuming soils work. This indicates that the equipment was not adequately qualified.
b.
Reliance on soil test results, or on the evaluation of the test results, provided a common mode failure mechanism because:
- 1. Construction relied on test results, or on the evaluation of the test results, from inprogress placements for qualification of equipment during the work.
- 2. Quality Control depended on the results, or on the 1'
evaluation of the results, ofAssociated in-place soils with tests for acceptance of the work.
this principal reliance, surveillance type inspection procedures tre applied to other soils work activity in the power block at least part of the time.
Therefore, deficiencies most closely associated
- with these two prob 4cle causes wculd bear the most significant contribution to settlem6nt.
() . .
Revision 4 23-3 11/79
__._______.s _ - _ . - _ - - _ . -
)
1 0
' RESPONSE TC QUESTION 23, PART (1) [50.54(fli 2.2 nefinitions The following information is provided to achieve a common understanding of the terms used and information included in Part (1) of this Response to Question 23.
Title:
This identifies the informacion als being in response to the applicable part of Question 23 under 10 CFR 50.54(f), transmitted from the NRR (L.S. Rubenstein) to CPCo (S.H. Howell) on Septesber 11, 1979.
De f iciency '
Description:
This provides a restatement of the reported deficiency as originally stated in the CPCo response referenced below.
I&E Report
Reference:
This identifies the pages of Inspection Report 76-20 which bear upon the rcported deficiency.
CPCo Response
Reference:
This identifies the portion of tne CFCo (s.H. Howell) letter to the NRR (H.R. De nton ) ,
Serial Howe-121-79, Appendix I, dated April 24, 1979, ,
which provided the original response.
Discussion: This provides background information relative to the reportad deficiency as it relates to the implementation of the Quality Assurance Program.
This identifies, Quality Assurance Program Criterion:
by title, the Quality Assurance Program criterion, listed in Appendix B to 10 CFR 50, which is applicable to the reported deficiency and the identified root cause.
Procram Element: . This identifies the program element, governed by the criterion, which is applicable to the reported deficiency and the identified root cause.
This identifies the Quality Assurance Program Policy: Job 7220 section and Nuclear Quality Assurance Manual, number which define the related Quality Assurance Program Policy. The Manual identifies requirements and assigns responsibility for developing and implementing control measures for performing related quality assurance activities.
Control Document: This identifies the current control document developed and implemented by the organizations i
assigned the responsibility for performing the quality i assurance activities under their cognizance.
23-4 Revision 4 11/79 1
_ _ _ _ _ _ , . . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ . . _ , _ _ _ _ _ . - - _ _ _ _ . . ~ . _ . _ _ . . _
r RESPONSE TO QUESTION 23, PART (1) (50.54 (f)]
Instructions, Procedures, and Drawings: This identifies the instructions, procedures, and drawings which are is prepared to supplement the control documents when itn This information is provided only when this level of subtier document is pertinent to the deficiency being discussed.
Root Cause: This identifies the root cause, for the reported deficiency described under " Discussion."
Remedial Action (Soils): This describes the actions taken or to be taken as a result of the reported deficiency which are needed to assure that prior and future soil placements conforms to the quality require-ments defined in the FSAR and design documents.
Corrective Action (Procrammatic) : This describes the acticns taken or to be taken to correct the root cause in the policies, procedures, and instructions in order to prevent recurrence of a similar type of deficiency.
Corrective Action (Generic): This describes the actions taken ur to be taken when root causes are Thepotentially actions are generic to work other than soils work.to assure that the same d if found to exist on completed work, are investigated to the extent necessary to assure that the work conforms to quality requirements defined in the FSAR and design documents and that the work quality is evidenced in the quality records.
In view of y3ur comments during our presentation to the NRC Staf f on September 5,1979 in Bethasda, Maryland, during which we presented some of this information, please note the added emphasis that we have placed actions.
Revision 4 23-5 11/79 O' .
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RESPONSE TO QUESTION 23, PART (1) [50.54(f)]
SECTION 3.0, DISCUSSION AND EVALUATION 3.1 Catecory I, Item 1 Deficiency
Description:
Inconsistency between specifi-cations and the Dames & Moord Report I&E Report
Reference:
Pages 9, 10, 16, and 17 CPCo Response
Reference:
Category I, Item i Discussion: A number of consultant reports were added to the PSAR as appendixes. The reports contained considerable and sometimes conflicting information.
The information contained in the consultant reports The was subject to being misconstrued as commitments.
personnel who reviewed and provided input for the PSAR did not provide documented disposition of the Dames &
Moore Report recommendations to identify those recommen-dations which were PSAR commitments and those which were not.
Quality Assurance Program Criterion _:
Design control Program Element: Design input Nuclear Quality Quality Assurance Program Policy:
Assurance Manual,Section II, Number 2, "Desin- Control Procedure" (April 1978) ; and Section II, Numbi.' 4,
" Design Criteria" (March 1974)
Control Document: Engineering Department Procedure l 4.22, Revision 1, " Preparation and Control of SAR" (June 1974)
Root Cause: During the preparation and early revisions .
of the PSAR there were no procedural requirements or methods for documenting the disposition of consultant i
recommendations in the PSAR.
The Dames & Moore Report was Remedial Action (Soils): _
reviewed and recommendations were identified and dispo-sitioned. Dames & Moore recommendations which were included in the FSAR were unaffected by this review and no revisions to the FSAR were necessary as a result of this review. However, as a result of other activities, changes were made in design and construction documents which relate to some subjects covered in the Dames &
Moore Report.
23-6 Revision 4 11/79
RESPONSE TO QUESTION 23, PART (1) [50.54 (f)]
Corrective Action (Programmatic): Engineering will revise Engineering Department Procedure 4.22 by December 1,1979, to clarify that Enyineering personnel preparing the FSAR will follow the requirements of Regulatory Guide 1.70, Revision 2, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants" (September 1975). Specifically, Regulatory Guide 1.70 (Pages iv and v of the Introduction) requires that such consultant reports only be referenced with the applicable commitments and supporting informatien included in the text (third paragraph, Page v). Such a requirement would preclude repetition of this circumstance.
Consultant reports other Corrective Action (Generic): _
than Dames & Moore were considered in accordance with the guidelines provided in NRC Regulatory Guide 1.70, Revision 2. Consultant reports were not attached to the FSAR, but portions of consultant reports were extracted and incorporated into the FSAR text itself.
Those portions incorporated into the FSAR become commit-ments.
Therefore, disposition of recommendations in consulting reports has been adequately accounted for in the preparation of the FSAR.
Verification that those portions of consultant reports determined to be commitments and incorporated into the i FSAR have been adequately reflected in project design documents is being accomplished via the FSAR rereview program described in the response to Question 23, Part (2).
The two Bechtel QA audit findings reportedhave in our1979, re April 24, been closed The results of this audit are being
. utilized in theout. FSAR control system study committed (1). to in Subsection 3.3 of this response to Part l
Revision 4 f 23-7 11/79
1 O RESPONSE TO QUESTION 23, PART (1) [50.54(f)] I I
l 3.2 Catecory I, Item 2 ieficiency
Description:
Lack of formal revisions cf specifica:lons to reflect clarification of specifi-cation requirements I&E Reoort
Reference:
Pages 9 through 14 CPCo Response
Reference:
Category I, Item 2 Discussion: Interoffice memoranda, memoranda, telexes, TWXs, etc were often used to clarify the intent of the specifications.
It is possible that in some situatiens the clarifications provided through these methods were interpreted by the user as modifying the specificatien without for= ally changing the wording of the specifi-cation.
Quality Assurance Program Criterion: Design control Procram Element: Design change control Quality Assurance Program Policy: Nuclear Quality Assurance Manual,Section II, Number 5, " Design Process and Change Control" (June 1977)
Control Document: Engineering Department Project Instr 'et .cn 4.49.1, Revision 3, " Specification Change Notice" (May 1979)
Root Cause: Prior to Revision 2 (May 4, 1979), Ercineering Department Project Instruction 4.49.1 did not address the use of interoffice memoranda, memoranda, telexes, TWXs, etc which might be interpreted by the user as modifying the requirements of the specification.
Remedial Action (soils): Applicable Specifications 7220-C-210 and 7220-C-211 were revised to incorporateThe interpreta-tions that affected specification requirements.
acceptability of the completed work was independently l
determined by a subsequent subsurface investigation program.
Corrective Actions (Programmatic): _
- 1. On April 3, 1979, Midland Project Engineering f Group Supervisors in all disciplines were reinstructed that the only procedurallr aorrect methods of amplementing specificatisa :h'anges are through the use of specification revisions or Specification Change Notices. This was followed by an interoffice l () memorandum from the Project Engineer to all Engineering Group Supervisors on April 12, 1979.
Revision 4 l
23-8 11/79 l
l I
\
\
RESPONSE TC QUESTION 23, PART (1) [50.54(f)]
- 2. Engineering Dt partment Project Instruction 4.49.1 was revised i' Revision 2 to state, "Under no circumstances will interoffice memoranda, memoranda, telexes, TWXs, etc be used to change the requirements of a specification."
Corrective Action (Generic): A review of interoffice memoranca, memoranaa, celexes, TWXs, and other corres-pondence relating to specifications for construction and selected procurements of Q-Listed items will be initiated.
The purpose of the review will be to identify any clarifications which might reasonably have been inter-preted as modifying a specification requirement and for which the specification itself was not formally changed.
An theevaluation technical will be made tosafety acceptability, determine the ef fect implications ofon the potential specification modification, and any work that If it is determined that has been or may be affected.the interpretation may have affected any com or future work, a formal change will be issued and remedial action necessary for product quality will be taken in accordance with approved procedures.
The foregoing procedure will be followed for all specifi-cations applying to construction of 0-Listed items.
For specifications concerning the procurement of Q-Listed The sample size has been on a random sampling basis.
established and the specification selection has been made.
Review and acceptance criteria for the specifications will be defined by November 30, 1979 I The review of construction and selected procurement specifications is scheduled to be completed by October 1980.
the review will If the acceptance criteria are not met, be expanded to include other specifications for Q-At that time, Listed items.
will be established.
nevision 4 23-9 11/79
1 1
RESPONSE TO QUESTION 23, PART (1) (50.54(f)]
3.3 Categcry I, Item 3 Deficiency
Description:
Inconsistency of information within the FSAR relating to diesel generator building fill material and settlement I&E Report
Reference:
Pages 6 through 8 i
CPCo Response
Reference:
Category I, Item 3 I
Discussion: When the FSAR was prepared and reviewed, There
- the ma]or backfill operations were complete.
were no known inconsistencies or recent design document changes related to FSAR Subsections 2.5.4 and 3.8.5; therefore, these subsections were essentiallyThe inactive incon-and were not subject to any further review.
sistencies within the FSAR and between The the FSAR and inconsistency c
design documents were not detected.between Subsections 2.5.4 a settlement values resrlted because the two subsections were prepared by separate organizations (Geotechnical Services and Civil Engineering), neither of which were aware of the multiple display The of similar information inconsistency between in the opposite subsection.
FSAR Subsection 2.5.4 and the project design drawing (Drawing 7220-C-45) with respect to the fill material resulted because at the time of FSAR preparation the Geotechnical Services personnel preparing the FSAR were unaware, in this case, of the status of the design drawing prepared by Civil Engineering.
Design control Quality Assurance Program Criterion:
Progran Element: Design input l Nuclear Quality Quality Assurance Program Policy: Assurance Manual,Section II (March 1974)
Engineering Department Procedure Contr_ol Documents:
l 4.22, Revision 1, " Preparation and Control of Safety Analysis Reports" (June 1974); Engineering Department Project Instruction 4.25.1, Revision 6, " Design Inter-(Septembe face Control (Internal)"
Department Project Instruction 4.1.1, Revision 0, l " Preparation of the Design Requirements Verification Checklist" (July 1974)
Root Cause: The control document did not provide l
() sufficient procedural control for preparation and review of the FSAR.
23-10 Revision 4 11/79
w RESPONSE TO QUESTION 23, PART (1) [50.54(f)]
Remedial Action (Soils): The inconsistencies between FSAR Subsections 2 5 4 and 3.8.5 have been corrected via FSAR Revision 18 (February 28, 1979). The same revision also corrected the inconsistency between FSAk Subsection 2.5.4 and Design Drawing C-45.
Corrective Actions (Programmatic):
- 1. A study was completed which examined current procedures and practices for the preparation and control of the FSAR in view of these experiences.
Procedural changes will be initiated by the revision of or addition to the Engineering DepartmentThis action is schedu Procedures.
by January 31, 1980.
- 2. To preclude any future inconsistencies between the FSAR and specifications, Engineering Department Project Instruction 4.1.1 will be revised to state that all specification changes, rather than just
" major changes," will be reviewed for consistency with the FSAR. This action is scheduled to be completed by December 1,1979.
FSAR secti0ns are being Corrective Action (Generic):es ciscussea in the Response to Question 23, receviewec Part (2).
l l
l O
Revision 4 23-11 11/79
RESPONSE TO QUESTION 23, PART (1) (50. 54 (f) ]
3.4 Category I, Item 4 Deficiency
Description:
Inconsistency between basis for setclement calculations for diesel generator building and design basic I&E Report
Reference:
Pages 20 and 21 CPCo Response
Reference:
Category I, Item 4 Discussion: The initial settlement calculations were performed by Geotechnical Services based on preliminary information provided by Project Engineering. The final diesel generator building foundation design configura-tion (as described in the FSAR) was different from the preliminary information. The originator of the final design configuration did not interface with Geotechnical Services to verify impact on final settlement calculations.
It was subsequently determined that the change in en foundation design would have an insignificant effect the calculation. However, no changes or notations tc the original calculations were made, thus resulting in an inconsistency between the basis for settlement calculations and design basis.
Design control Quality Assurance Program Criterion:
Program Element: Design coordination Nuclear Quality Quality Assurance Program Policy:
Assurance Manual,Section II, Number 2, " Design Control Procedures" (April 1978);Section II, Number 9, " Design Interface" (March 1974); and Section II, Number 10, "Speciality Group Design Control" (June 1977)
Control Documents: Engineering Department Procedure 4.22, Revision 1, " Preparation and Control of Safety Analysis Reports" (June 1974); Engineering Department Project Instruction 4.25.1, Revision 6, " Design Inter-face Control (Internal)" (September 1979); Procedure FP-6437-1, " Design Calculations" (January 1979); and Engineering Department Procedure 4.37, Revision 2,
" Design Calculations" (May 1976).
Root Causes:
- 1. Diesel generator building foundation design changes initiated by Project Engineering were not coordi-nated with Geotechnical Services, as required by the control documents.
23-12 Revision 4 11/79 l
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RESPONSC TO QUESTION 23, PART (1) [50.54(f)]
- 2. Geotechnical Procedure FP-6437 did not require that the calculations show evidence of any evalua-tions for changes to input data, even when considered to be of no significance to the results.
Remedial Action (Soils): Settlement calculations will be revised af ter the completien of the diesel generator building surcharge operation. At that time, the design drawing will be coordinated with Geotechnical Services and any changes or notations needed to reflect design changes will be made.
Corrective Actions (Programmatic) :
- 1. An interoffice memorandum dated April 12, 1979, was issued by Geotechnical Services to alert personnel of the need to revise or annotate calculations to reflect current design status.
- 2. In view of the above, Geotechnical Services will revise Procedure FP-6437 by Decenter 31, 1979, to require that calculations be annotated to reflect current design status.
- 3. Engineering Department Procedure 4.37 will also be revised by December 31, 1979, to require that calculations be annotated to reflect current design status.
Ccerective Action (Generic): This is considered an isolated case and not generic based on Quality Assurance audits of Geotechnical Services conducted in February and August 1979. The results of these audits indicate Quality that this area is effectively controlled.
Engineering surveys and Quality Assurance monitorings will verify future coordination of design documents by Geotechnical Services and Project Engineering.
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O 23-13 Eevision 4 11/79
O RESPONSE TO QUESTION 23, PART (1) (50.54(f)]
3.5 Catcoory I, item 5 Deficiency
Description:
Inadequate design ccordination in the design of the duct bank r
I&E Report
Reference:
Pages 23 and 24 CPCo Response
Reference:
Category I, Item 5 Discussion: Four vertical duct banks were designed and constructed without sufficient clearance to allow for relative vertical movementCivil between Drawings the 7220-C-1001 duct banks and and the buildi:4g footings.
7220-C-1002 (which show the footing requirements) were coordinated with Electrical Drawing 7220-E-502 (which shows the duct bank stub-up location and dimensions),
as required by Engineering Department Procedure 4.46 and Engineering Department Project Instruction 4.25.1.
Drawing 7220-E-502 refers to Drawing 7220-E-543, which shows a minimum size for the underground duct bank some distance away from the stub-up. Neither electrical nor civil drawings show how or where to accomplish the transition from the stub-up size to the underground duct size, nor do they show firm definition of duct size. The transition and final size of each duct were established by the Field Engineers during construction.
The civil design was based on the stub-up dimensions shown in Drawing 7220-E-502, and did not acknowledge that the duct bank size under the slab and/or footing was to be determined by Field Engineering.
I Instructions, Quality Assurance Program Criterion:
procedures, and drawings l
Program Element: Preparation of drawings Nuclear Quality Quality Assurance Program Policy:
Assuranct Manual,Section II, Number 2, " Design Control Proceduros" (April 1978); and Section II, Number 9,
" Design ':nterf ace" (March 1974)
Control Dc?uments: Engineering Department Procedure 4.46, Res.. ion 3, " Project Drawings" (May 1976) and Engineering Department Project Instruction 4.25.1, Revision 6, " Design Interf ace Control (Internal)"
(September 1979)
Instructions, Procedures, and Drawings: Electrical Standard Detail Drawings and Civil Standard Detail Drawings l
23-14 Revision 4 11/79 l
RESPONSE TO QUESTION 23, PART (1) (50.54 (f) ]
Root Cause: Failure of the drawings to provide Construction with the informaticn necessary to prevent interference.
Remedial Actions (Soils):
- 1. Provisions were made to allow independent vertics!
movement bet' ween the diesel generator building and the duct banks.
- 2. Bechtel Project Engineering has reviewed the design drawings for cases where ducts interface with structures to determine the possibility of the duct being enlarged over the design recuirements i and the effect this enlargement may have upon the structures' behavior. Forty-four individual or groups of similar buried electrical duct banks were reviewed. The terminations of each case were reviewed, resulting in the identification of 23 questionable vertical interfaces. Based on gecmetry, depth of vertical leg, and whether sufficient details were available on the design drawing, 11 cases were identified for detailed investigation.
Additional information was obtained from the jobsite to define how the interface was constructed and whether any unusual behavior existed.
The review concluded that several nonsafety-related transformer pads experiencing differential settlement may be exaggerated by the duct bank interface. However, in no case except the diesel generator building has settlement been completely restricted or do details, geometry, or subgrade conditions indicate that settlement would be completely restricted.
Correctite Actions (Programmatic):
- 1. Civil / Structural Design Criteria 7220-C-501 will be modified to contain the requirement that a duct bank penetration shall be designed to eliminate the possibility of the nonspecific This size action duct is interacting with the structures.
scheduled to be completed by December 31, 1979.
2.
The civil standard detail drawings will be revised to include a detail showing horizontal and vertical clearance requirements for duct bank penetrations.
The detail will address any mud mat restrictions.
This action is scheduled to be completed by December 31, 1979.
23-15 Revision 4 11/79 i ()
. _ - .-.. .- -_. . .. .- - ._- .- .= . . _ .
O RESPONSE TO QUESTION 23, PART (1) l50.54(f)1 Corrective Action (Generic): This condition is not rather an anomaly unique to considered generic, but The uniqueness arises from the electrical duct banks.
practice of not pinpointing the size or location of theduct ba during construction.
l 1
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. O Revision 4 23-16 11/7 E'
RESPONSC TO OCES*220N 23, PART (1) (50.54(f)] ,
O Category II, Item 1 3.6 Deficiency
Description:
Insufficient compactive effort used in cackfill operation I&E Report
Reference:
Not applicable CPCo Response
Reference:
Category II, Item 1 Discussion: Specifications 7220-C-210 and 7220-C-211 specifiec requirements for selection and approval of compaction equipment on the basis of demonstration.
The equipment was used on the basis of achieving either satisf actory in-place test results or satisf actory evaluation of the test r 11ts. There were no field control documents or pro..dures to define requirements There for the qualification of soils compaction equipment.
were no control documents to govern the requirements and for control measures pertaining to soils placementConstruction and Quality c compaction.on in-place soil test results, or on the evaluation of these results, to determine the acceptability of placement and compaction activities. These soil test results or their evaluations were in error in numerous cases.
Instructions,
.Ouality Assurance Procram Criterion:
procedures, and drawings Procram Element: Preparation of instructions, procedures, and drawings Nuclear Quality Assurance Ouelity Assurance Procram Policy:
Manual,Section IV, Number 1, " Construction Site Quality Program" (April 1978), and Section V, Number 13, " Procedure Control" (June 1977)
Field Procedure FPG-1.000, " Initiating Control Document: Field Procedures, Instructions, and and Processing Specifications" (January 1979)
Procedures , and Drawinos: Field Instruction Instructions, FIC 1 100, Revision 0, "Q-Listed Soils Placement Job Responsibilities Matrix" (July 1979)
Root Causes:
- 1. Reliance was placed on in-place test results, or on the evaluation of the test results, for Satisfactory evaluating soil test results, compaction equipment.
or evaluations of test results, implied that adequate compactive effort was obtained and equipment capability and fill placement methods were not questioned.
(Incorrect soils test results are addressed in Os Subsection 3.10.)
Revision 4 11/79 23-17
, - . _ . _ . ~ _
( RESPONSE TO QUESTION 23, PART (1) (50.54(f)]
to
- 2. The Ocality Assurance Program requirement establish responsibility for measures to control the placement and compaction of soils and the qualification of construction equipment was not adequately implemented.
Remedial Actions (Soils):
- 1. Compaction equipment currently in use has been qualified and Construction has been notified of the parameters governing the use of the equipment.
- 2. Project Oual.ty Control Instruction (POCI) C-1.02 was revised to include verification of the use of qualified equipment and compliance with qualified procedures.
Corrective Actions (Procrammatic):
- 1. Field Instruction FIC 1.100, "O-Listed Soils Placement Job Responsibilities Matrix," has been prepared and establishes responsibilities for performing soils placement and compaction.
- 2. Field Instruction 1.100 will be supplemented by establishing requirements for demonstrating equipment capability, including responsibility for equipment
- approval, and providing records identifying this
' capability. This action will be completed by November 15, 1979.
- 3. Quality Assurance will issue a Nuclear Quality Assurance Manual amendment to clarify the requirement that procedures include measures for qualifying equipment under specified conditions. This action 14, 1979.
is scheduled to be completed by nacember
- 4. Engineering and Construction will revise or prepare procedures governing the placement and compaction of soils and implementing the requirements of the Nuclear Quality Assurance Manual as stated This in is scheduled Corrective Action Item 1 (above).
to be completed by January 31, 1980.
Construction specifications, Corrective Action (Generic):
instructions, and procedures were reviewed to identify any other equipment requiring No qualification such equipment which was had identified.
not yet been qualified.
() 23-18 Revision 4 11/79
O RESPONSC TO QUESTION 23, PART (1) [50.54(fil 37 Category II, Item 2 Ceficiency
Description:
Insufficient technical direction in tne field I&E Report Reference Pages 24 through 26 CPCo Response Reference Category II, Item 2 Discussion: The Dames & Moore Report and"Civil /Structura' Filling Design criteria 7220-C-501 state, in part, operations shall be performed under the technicalThe supervision of a qualified Soils Engineer...." technical direction and Field Engineers and Supervisors who were assigned the responsibility for soils placement. The technical direction and supervision provided were not properly deployed to overcome the lack of documented instructions and procedural controls. Reliance on test results, or on the evalaations of test results, did not identify the need for additional direction and supervision.
Field Procedure FPG 3.000, " Job Responsibilities of Field Engineers, Superintendents, and Field Subcontract Engineers," was not intended to provide instructions for the performance of specific tasks and functions.
Instructions, Quality Assurance Program Criterion:
proceoures, and crawings Program Element: Preparation of instructions, procedures, I
and drawings Nuclear Quality Quality Assurance Program Policy: Number 1, " Construction Assurance Manual, 'Section IV, Site Quality. Program" ( April 1978); and section V, Number 13, " Procedure Control" (June 1977)
Field Procedure FPG 3.000, " Job Control Document:
Responsibilities of Field Engineers, Superintendents, and Field Subcontract Engineers" (October 1977)
Instructions, Procedures, and Drawings: None Root Cause:
Reliance on test results, or on the evaluations of test results, and surveillance by Ouality Control l
instead of providing sufficient technical direction
- through documented instructions and procedural controls.
(Incorrect Soil Test Results are addressed in Subsection 3.10).
O V Revision 4 23-19 11/79
t RESPONSE TO QUESTION 23, PART (1) (50.54(f)]
Remedial Action (Soils): One fulltime and one parttime onsite Geotechnical Soils Engineer have been assigned.
These engineers provide technical direction and monitoring of the process.
Corrective Action ( Programmatic): Field Instruction FIC 1.100, "Q-Listed Soils Placement Job Responsibilities Matrix," has been prepared and establishes responsibilities for performing soils placement and compaction.
Corrective Action (Generic): Design documents, instructions, ano procecures tor those activities requiring inprocess controls will be reviewed to assess the adequacy of existing procedural controls and technical direction.
Engineering review is scheduled for completion by December 31, 1979, and Field Engineering and Quality Control review is scheduled for completion by January 31, 1980. Any revisions required will be completed by March 14, 1980.
e e
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Revision 4 23-20 7177p
RESPONSE TO QUCSTION 23, PART (1) (50.54(f)]
3.E Category III, Item 1 Deficiency
Description:
Inadequate Quality Control inspection of placement of fill I&E Report
Reference:
Pages 25 through 29 CPCo Response
Reference:
Category III, Item 1 Discussion: The Nuclear Quality Assurance Manual Construction Quality Control Prucedures requires that" define the method for indirect control by monitoring of processing methods, equipment, and personnel, wneni Control Document SF/ PSP G-6.1, " Quality Control Inspection Plans," does not adequately include or reference this requirement in the instructions Quality for preparation of control Instruction Quality Control Instructions. adequately satisfy this requirement.
PCCIinspection The C-1.02 didofnot soils was accomplished by " surveillance,"
and did not require verification of the controls specified in Specifications 7220-C-210 and 7220-C-211. Soil test results, or the evaluations of soil test results, were used as the basis for quality verification.
Inspection instructions, Quality Assurance Procram Criterion:
procedures, and drawings Establishment of an inspection program, Program Element: instructions and procedures for accomplishing documented the inspection activity, and the preparation of instructions and procedures Nuclear Quality Ouality Assurance Program Policy: Number 5, " Field Inspection Assurance Manual,Section IV, l
and Test" (June 1977)
SF/ PSP G-6.1, Revision 4, " Quality Control Document:
Control Inspection Plans" (January 1978)
POCI C-1.02, Instructions, Procedures, and Drawings:
~ Revision 4, " Compacted Backfill" (July 1979)
Root Causes:
include
- 1. Control Document SP/ PSP G-6.1 does not sufficient specificity in its requirements for the preparation.of inspection instructions.
Revision 4 D
Q 23-21 11/79
O V
RESPONSE TO QUESTION 23, PART (1) 150.54(f)J
- 2. Too much reliance was placedsufficiently on the Ouality Control specific Inspector's ability, without inspection instructions.
- 3. Reliance was placed on soilresults, test results, whichorwere on in the evaluation error in numerous of soll test (Incorrect Soil Test cases.
Results are addressed in Subsection 3.10.)
Remedial Actions (Soils):
- 1. POCI C-1.02 has been revised to incorporate the specific characteristics to be verified by Quality Control.
- 2. An in-depth soils investigation program, which was implemented as described in our prior transmittals, provides verification of the acceptability of theroils or further remedial action.
Control Document Corrective Action (Procrammatics:
SF/ PSP G-6.1 will ce revised to provide requirementsfo of scientific sampling rather than percentage sampling. 1980.
This action is srSeduled to be completed by January 24, Corrective Actions (Generic)
- 1. OCIs in use will be reviewed to ascertain that provisions have been included Thisconsistent action andwith anythe revised control document.
required revisions are scheduled to be completed
( by March 8, 1980.
l
- 2. The impact of Corrective Action Item 1 (above) on l completed work will be evaluated, andThis appropriate action actions will be taken as necessary. 23, 1980.
is scheduled to be completed by May l ([)
23-22 Revision 4
(
11/79 l
I 1
l RESPONSE TO QUESTION 23, PART (1) (50.54 (f) }
3.9 Category III, Item 2 Deficiency
Description:
Inadequate soil moisture testing I&E Report
Reference:
Pages 14 through 16
' CPCo Response
Reference:
Category III, Item 2 Discussion: Prior to 1976, moisture content was controlled by tests performed after compaction. Few or no tests were performed on the fill during compaction, as required by Specification 7220-C-210, Section 12.6. "During compaction" was interpreted by personnel in the field as the entire process of placing, compacting, and testing. The moisture content was measured during the density test, which was performed immediately after compaction.
Reconditioning was done aftor testing.
Quality Assurance Program Criterion: Inspection instructions, procedures, and d awings Program Element: $.itablishmentofaninspectionprogram, the documented inst 2metions and procedures for accomplish,ing the inspection activity, and the preparation of instructions and procedures Quality Assurance Prohram Polity: Nuclear Quality Assurance Manual,Section IV, Number 5, " Field Inspection and Test" (June 1977) .
Control Document: SF/ PSP G-6.1, Revision 4, " Quality Crntrol Inspection Plans" (January 1978)
Instructions, Proceduras, and Drawings: PQCI, C-1.02, Revision 4, " Compacted Backfill" (July 1979)
Root Causes:
- 1. Control Document, SF/ PSP G-6.1 dUas not require sufficient specificity for establishing an inspection program and for the preparation of inspection instructions, s
- 2. Reliance was placed on the informal incorrect interpretations of the specification relative to moisture testing. This is discussed in Subsection 3.2.
- 3. Reliance was placed on Quality Control surveillances 3 of moisture testing.
23-23 Revision 4 11/79
-_ . _ _ _ . _ . . _. _ _ . _ _ _ . _ _ _ _ _ _ . . . _ _ _ _ _ . _ _ . ~ . _ . - _ _ , _ _ - .
O .
R! SPOMSC TO QUCUTION 23, PART (1) [50.54(f)) i
- 4. Reliance was placed on the incorrect results of evaluation the density tests, or on the incorrect of the results, to the exclusion of the moisture test results. (Incorrect Soil Test Results are addressed in Subsection 3.10).
Remedial qctions (Soils):
- 1. The u. ecifications were ravised to provide more definitive requirements for soil moisture testing.
- 2. POCI C-1.02 was revised to provide specific inspection requirements for verifying soil moisture content, rather an surveillance.
- 3. Field instruction FIC 1.000, "0-Listed soils Placement Job Responsibility Matrix," has been prepared, and establishes responsibilities for performing soils placement and compaction.
Corrective Actions (Procrammatic):_
- 1. Control Document SF/ PSP G-6.1 will be revised to provide requirements for inspection planning specificity and for the utilization of scientific This sampling rather than percentage sampling.
action is scheduled to be completed by January 24, 1980.
Instruction 4.49.1,
- 2. Engineering Department Project Revision 3 now states, "Under no circumstances will interof fice memoranda, memoranda, telexes, TWXs, etc be used to change the requirements of a l
This will provide controlled and specification." uniform interpretation of specification requirements.
- 3. On April 3, 1979, Midland Project Engineering Group Supervisors in all disciplines were reinstructed that the only procedurally correct methods of implementing specification changes are through the use of specification Thisrevisions or Specification was followed by an interoffice
' Change Notices.
memorandum from the Project Engineer to all Engineer-ing Group Supervisors on April 12, 1979.
23-24 Revision 4 11/79
('. '
l
~ * * ' -- .- . _ _ _ asp--- , , , .
O RESPCNSE TO 00CSTION 23, PART (1) [50.54(f)]
Corrective Actions (Generic):
- 1. OCIs in use will be reviewed to ascertsin that provisions have been included consistent with the This action and anv revised control document.recuired revisions are scheduled to be completed b3 tarch 2, 1980.
on
- 2. The impact of Corrective Action Item 1 (above) completed work will be evaluated, andThis appropriate action actions will te taken as necessary. 23, 1960.
is scheduled to be completed by May
- 3. A review of interoffice memoranda, memoranda, telexes, TWXs, and other correspondence relating to specifications for construction and selected procurements of e-Listed items will be initiated.
The purpose of the review will be to identify any clarifiestions which might reasonably have been interpreted as modifying a specification requirement and for which the specification itself was not formally changed. An evaluation will be made to determine the effect on the technical acceptability, safety implications of the potential specification modification, and any work that has been or may be affected. If it is determined that the inter-pretation may have affected any completed or future work, a formal change will be issued and remedial action necessary for product quality will be taken in accordance with approved procedures.
The foregoing procedure will be followed for all specifications applying to construction for 0-Listed items.
For specifications concerning the procurement of Q-Listed items, the foregoing procedure will The be implemented on a random sampling basis.
sample size has been established Review Lnd and the specification acceptance selection has been made. criteria for the specifications will be defin November 30, 1979.
The review of construction and selected procurement specifications is scheduled to be completed by October 1980.
the review If the acceptance criteria are not met, will be expanded to include other specificationsfor Q date will be established.
(_/
Devision 4 11/79 23-25
4 RESPONSE TO QUESTION 23, PART (1) 150.5k(fli
~
3.10 Ca tcaory III, I tem 3 Deficiency
Description:
Incorrect soil test results ISE Report
Reference:
Not applicable CPCo Response
Reference:
Category III, I tem 3 Discussion: A review of soils test reports indicates that some tes t reports contain errors and inconsistencies in data. Surveillance and test report reviews did not identify these errors and inconsistencies. The
-Quality Control surveillance and review included steps to verify that the test results were reported as either percent compaction or relative density, as appropriate; that specification requirements for compaction and moisture content were within specified limits; and that the report form was properly completed and contained the required data and authorized signature. This was in accordance wi'h the requirements of Quality Control Ins truc tf on 7 220-SC-1.05, " Material Tes ting Laboratories ,"
which includes instructions for monitoring the performance of verification testing performed by the testing laboratory.
Control of purchased Quality Assurance Program Criterion:
material, equipment, and services (subcontractors)
Program Element: Surveillance of the subcontractor's performance Quality Assurance Program Policy: Nuclear Quality Assurance Manual, Section IV, Number 11, " Field Subcon-tractor Control" (June 1977); and Section IV, Number 5,
" Field Inspection and Test" (June 1977)
Control Document: SF/ PSP G-9.1, Revision 1, " Control of Subcontractor Work" (July 1977)
Ins tructions , Procedures , and Drawings:
Quality Control Ins truc tions 7 220-SC-1.05, " Material Tes ting Services" (October 1977)
Root Cause: Technical procedures available to control the tes ting were inadequate, and the technical direction of the testing operations did not avoid or detect the incorrect soil test results.
O 23-26 Revision 4 11/79 G
,....,,.-r. - - - . _ e wm-,. --,-,,re..-.,,w.... ...,,,..,,,_.,--.,.w.,+ ...,me--, ,,---%w- - - ,_ m,ey-,-,, ,,-.,-a--, y n., g-- ,-
l O RESPONSE TO QUESTION 23, PART (1) (50. 54 (f) I Remedial Actions (Soils) :
- 1. Geotechnical Services has completed an inves tigation which includes an in-depth review of tes ting performed by U.S. Testing and the reported test resul ts . The purpose of this investigation was tc identify the type of testing errors which were made in order to f acilitate analysis by U.S. <
l Testing and to accomplish Programmatic Cerrective Action (below) and Remedial Action Item 2 (below).
- 2. Based on Item 1 above, the requirements for the control of testing were adjusted, requiring the Testing Subcontractor to check all field density tests for cohesive material against a zero-air-voids curve. A specification change has been issued. Selection of proctor curves will no longer be a problem because each field density test will be accompanied by a separate laboratory standard which will provide a direct comparisen.
This was directed by a letter to U.S. Tes ting and reflected in Specification Change Motice C-208-9004, dated April 13, 1979.
- 3. POCI-SC-1.05 was revised to add more stringent requirements for in-process inspection of U.S.
Tes ting's soil tes ting activities.
- 4. An in-depth soils investication program which was implemented as described in our prior transmittals, provides verification of the acceptability of the soils or identifies any nonconformances requiring further remedial action. This action is identical to Remedial Action Item 2 in Subsection 3.8.
Corrective Action (Programmatic): Guidelines for surveillance of testing operations will be developed j
and included in Field Instructions for the onsite Soils Engineer. Engineering / Geotechnical Services will develop the guidelines by November 30, 1979, and Field Engineering will prepare the instructions by December 31, 1979.
Corrective Actions (Generic):
- 1. U.S. Testing will be required to demons trate to the cognizant Engineering Representative that
! testing procedures, equipment, and personnel used t
l l
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Revisien 4 23-27 11/79 1
l l
RESPCNSE TO OUCSTION 23, PART (1) [50.54(f)]
for quality verification testing (for other than :::E and soils) were, and are, capable of providing accurate test results in accordance with the requirements of applicable design documents. This action is scheduled to be completed by May 1, 1980.
- 2. A sampling of U.S. Testing's test reports (for other than NDE and soils) will be reviewed by the cognizant Engineering Representative to ascertain that results evidence conformance to testing requirements and design document limits. This action is scheduled to be completed by May 1, 1980.
l i
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- Revision 4 l 23-28 :l/79 L.
V RESPONSE TO QUESTION 23, PART (1) [50.54(f)]
3.11 Category III, Item 4 Deficiency
Description:
Inadequato subcontractor test procedures I&E Report
Reference:
Not applicable CPCo Response
Reference:
Category III, Item 4 i
Discussion: The procedures used for soils testing did not cover the following activities:
- 1. Developing and updating the family of proctor curves;
- 2. Visually selecting the proper proctor curves;
- 3. Developing additional proctor curves for changing materials occurring between normal frequency curves; and
- 4. Using alternative methods of determining the proper laboratory maximum density where visual comparison is not adequate.
Bechtel Specification 7220-G-22, Revision 1 (June 22, 1973) is an attachment te Specification 7220-C-208 and specifies the requirementa for instructions, procedures, and drawings. These technical procedures were not prepared.
Control of purchased Quality Assurance Program Criterion:
material, equipment, and services (subcontractor)
Program Element: Control of supplier-generated (subcontractor-generated) documents Nuclear Quality Quality Assurance Program Poliev:
Assurance Manual,Section III, Number 9, " Supplier Document Review" (June 1977); and Section IV, Number 11, " Field Subcontractor Control" (June 1977)
Control Document: SP/ PSP G-9.1, Revision 1, " Control of Subcontractor Work" (July 1977)
Instructions, Procedures, and Drawings: Quality Control Instructions 7220/SC-1.05, " Material Testing Services" (October 1977) b m Revision 4 23-29 11/70
O v
RESPONSE TO CUESTION 23, PART (1) [50.54(f)]
P.o c t Ca use:: Adequate technical procedures for control of the tonting were not preparod.
Remedial Actions (Soils):
- 1. Geotechnical Services has completed an investigation which includes an in-depth review of testing performed by U.S. Testing and the reported test results. The purpose of this investigation was to identify the type of testing errors which were made in order to facilitate analysis by U.S.
Testing and accomplish Remedial Action Item 2.
- 2. Based on Item 1 above, the requirements for the control of testing were adjusted requiring the Testing Subcontractor to che:k all field density tests for cohesive material against a zero-air-voinn curve. A specification change has been issued. Selection of proctor curves will no lenger be a problem because each field density test will be accompanied by a separate laboratory standard which will provide a direct comparison.
This was directed by a letter to U.S. Testing and refl'ected in Specification Change Notice C-208-9004, dated April 13, 1979.
- 3. One full-time and one part-time onsiteThese Geotechnical engineers Soils Engineer have been assigned.
will review U.S. Testing's procedures and monitor their implementation.
(Procrammatic): Field Instruction Corrective Action FIC 1.100, "Q-Listed Soils Placement Job Responsibilities Matrix," has been prepared and establishes responsibilities for performing surveillance of testing operations.
Corrective Actions (Generic):
- 1. Design documents, instructions, and procedures for those activities requiring inprocess controls will be reviewed to assess the adequacy of existing procedural controls and technical direction.
Engineering review is scheduled for completion by December 31, 1979, and Field Engineering and Quality Control review is scheduled for completion by January 31, 1980. Any revisions required will be completed by March 14, 1980.
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23-30 Revisten 4 11/79 l
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l O RESPONSE TO OUCSTION 23, PART (1) [50.54(f)]
- 2. 81 . 5 . Testing will be required to demonstrate to the cognizant Engineering Representative that testing procedures, equipment, and personnel used for quality verification testing (for other than I:CE and soils) were, and are, capable of providing accurate test results in accordance with the This requirements of applicable design documents.
action is scheduled to be completed by May 1, 1980.
- 3. A sampling of U.S. Testing's test reports (for other than NDE and soils) will be reviewed by the cognizant
- Engineering Representative to ascertain that results evidence conformance to testing requirements and design document limits. This action is scheduled to be completed by May 1, 1980.
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O RESPONSE TO QUESTION 23, PART (1) [50.54(f)] ;
3.12 Category IV, Item 1 Deficiency
Description:
Inadequate corrective action for repetitive nonconforming conditions I&E Report
Reference:
Pages 17 through 20 CPCo Response
Reference:
Category IV, Item 1 Discussion: There were nonconformances reported which These include, but are considered to be repetitive.
are not limited to: CPCo Nonconformance Reports OF-29, OF-52, QF-68, QF-120, QF-130, QF-147, QF-172, OF-174, OF- 19 9, and CF-203; CPCo Audit Findings F-77-21 and F-77-32; and Bechtel Nonconformance Reports 421, 686, 698, and 1005.
The Nuclear Quality Assurance Manual,Section V, Number 10, states in Subparagraph 2.5.b, "Ncnconformances which, due to their repetition or impact (potential or actuall upon quality, should be brought to management's attention for special action."
Quality Assurance Department Procedure C-101, Revision 1,
" Project Quality Arsurance Trend Analysis" (July 1977) states in Paragrip: 1.0, "This procedure provides a mechanism for identifying quality trends and The initiatinc corrective action to prevent recurrence...."
reviews made in accordance with this procedure did not identify the significance of the repetitive nature of the nonconformances and the need for special action beyond that for the individual reports.
Control Documaat SF/ PSP G-3.2 defines the requirements for review of Management Corrective Action Requeste, (MCARs).
l I Quality Assurance Program Criterion: Corrective action Procram Element: Actions pertaining to significant conditions adverse to quality Nuclear Quality Ouality Assurance Program Policy:
Assurance Manual,Section V, Number 10, " Management Corrective Action" (March 1979)
, " Control Control Documents: SF/ PSP G-3.2, Revision of Nonconforming Items" (September 1979) and QADP C-101, Revision 1, " Project Quality Assurance Trend Analysis" (July 1977)
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O RESPONSE TO OUESTION 23, PART (1) [50.54(f)]
Root Causes:
- 1. The conditions under which nonconformances are considered to be repetitive are not adequately defined in the control documents.
- 2. The trending activity did not provide timely respenses to repetitive product nonconforming conditions.
Remedial Action (Boils): Not applicable Corrective Action (Procrammatic): Control documents are in the process of being revised to provide an improved definition of implementing requirements forThis identifying repetitive non-conforming conditions.
action is scheduled to be completed by January 24, 1980.
Corrective Action (Generic): Consistent with the intent of the programmatic change above, Quality Assurance will review nonconformance reports which are open, or will become open between this time and January 23, 1980. This review will be to identify any repetitive nonconforming conditions pertainir.g to product type or activity, or pertaining to nonconformance cause. This action is scheduled to be completed by January 24, 198'..
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.evisien t 4 23-33 11/79 i
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%./ RESPONSE TO QUESTION 23, PART (1) (50.54(f)]
3.11 Cateoory IV, Item 2 Deficiency Dencription: Bechtel Ouality identifyAssurance the problems auditing and monitoring did notThis lack of identification relating to the settlement.
of problems by the auditing and monitoring contributed to a conclusion that soils operations were adequately controlled.
I&E Report
Reference:
Pages 17 through 20 CPCo Response
Reference:
Category IV, Item 2 Discussion: Cuality Assurance auditing and monitoring is aimed at eval *:ating the adequacy of policies and procedures an( tiuating the degree of compliance It is not a quality and procedures.
verification accivity, although it may identify deficiencies with the polit in the i rformance of quality-related activities that In the could result in unsatisfactory product quality.
case of soils operations, Opality Assurance auditing and monitoring found that quality-related activities were being performed as planned, quality verification activities (primarily soil testing) were being performed, and the soil test results, or their evaluation, provided evidence of compliance with the established standards.
The auditing and monitoring did not identify the policy and procedure inadequacies.
Auditing Cuality Assurance Procram Criterion:
Auditing Procram Element:
Nuclear Quality Ouality Assurance Procram Policy: Number 1, " Quality Audit Asserance Manual,Section VI, System" (March 1979)
Quality Assurance Department Procedure, Control Documents:
Numoer 1, "Projrct Quality Monitoring" Section C, (September 1977); and Section C, Number 5, " Project Quality Audits" (September 1977)
Root Cause: Ouality Assurance audit and monitoring was oriented more toward evaluating the degree of compliance with established procedures rather than toward the i
assessment of policy and procedural adequacy or toward the assessment of product quality.
Revision 4 11/79 23-34
! Ib
RESPONSE TO QUESTION 23, PART (1) [50.54(f)]
The Quality Assurance Corrective Action (Generic): audit ano monitoring program will be revis and increase a ttention to the need for evaluating policy and procedural adequacy and assessment of product quali ty.
A specialized audit training program will be developed and implemented to ensure guidance for t December 31, 1979.
11/79
O RESPONSE TO QUESTION 23, PART (2) l I
l Revision 4 11/79 O
RESPO SE 'ID MRC CUESTICN 23, PAPT (2) (50.54(f)1 SIrTIOJ 1.0, NPC CCESTIa:
SUPPID'D:TAL Mt.CCdT EUR ADDITIGAL SOIIS .h~ verr IN",.TICH_
21, 1979 letter,
- 23. We have reviewed your response to question 1 of our March "10 FR 50.54 Pequest Pegare J g Plant Fill," including related arnenenents 10, 1979. Heor supplernents in your letters Lated May 31, July 9, and Augustfind tha revies. Accordingly, provide the following additional inforration:
(2) Regarding ycur response to question Ib:
- a. *:he first seven paragraphs do not provide sufficient infer atien to assure that contradictions do not c:rntinue to exist in the PSAR, TSAR, design docments, inplementing procedares, and as-built condi-tiens since the controls described in these m paracraphs were in effect prior to the I&E findings reported in J. Keppler's describe the letter of control March 15, 1979. Modify your response to clearl?
revisions you have instituted to prec1Me design contradictions.
- b. Itcrns 1, 2, and 3 of the eighth paragraph describe the review and update of the PSAR comitment list, the review of the inactive sections of the FSAR, and the review of procedure II)P 4.22, ' Preparation and Control of Safety Analysis Reports," without describing the extent of the review process or the qualifications of personnel involved in the review. Accordingly, describe what each of these reviews entails, including the extent to which these reviews are verified, approved, and doc.:mented. Identify the organizational unit that is, or will be, involved in these reviews and the qualifications of the invc1ved personnel.
c.
Itern 2 of the eighth paragra;h states that a review of the reraining
" ... because of the ongoing sections of the ESAR is not necessary, Describe your rationale for net review process described above."
reviewing these remaining sections of the FSAR when to issuanceit appearscfthat i
the the March original review of the FSAR was perfomed prio2 letter providi 15, 1979 I
corrective actions resulting therefrau.
- d. Describe the extent of the audit to which you have ccrnitted in item 4 of the eighth paragraph.
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RESPONSE TO QUESTION 23, PART (2) [50.54(f)!
SECTION 2.0, RESPONSE TO PART (2)a
.Mr. J. Keppler's letter of March 15, 1979 described inconsist-encies in the FSAR which occurred at the time of originatien of the FSAR.
Paragraphs 1 and 2 of the CPCo response to Questien 1,1979, descr Part b dated April 24, Paragraph 3 of that respense provides a prepare the FSAR. Paragraphs 4, brief history of the preparation of the FSAR.5, and 6 describe subsequent to the submittal of the FSAR, and to include missing information, reflect design changes, resolve identified inconsistencies between Paragraph 7 explains whythe the FSAR and project design documents.
inconsistencies 3.8.5 at the time ofcreated preparation in FSAR Section of the FSAR were2.5notand Subsection initially identified and corrected by the implementation of the original procedures.
The following supplements the response to Questio of the FSAR to preclude design contradictions.
When the FSAR was docketed in November 1977, it became the prime licensing document superseding Therefore, thevalid it is not design commitments to compare contained in the PSAR. implementing a PSAR ccT,mitment to a current design document,It is valid to compare procedure, or as-built condition.
these design documents against the licensing commitmentsPSAR contained in the FSAR. Attachment 1-1 to following into the FSAR1,when the Question Part the FSAR was b response written.
shows that the documents were considered as input in the preparation of '
I
' each FSAR subsection:
- 1. Regulatory Guide 1.70, Revision 2 NRC Standard Review Plans and Branch Technical Po
)
2.
- 3. DRL Safety Evaluation Revision 4 23-37 11/79 i
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O RESPONSE TO QUESTION 23, PART 2 [50.54(f)]
- 4. Midland PSAR
- 5. Unincorporated SAR Change Notices
- 6. Regulatory Guides and Results of Regulatory Guide Review Program
- 7. Supplemental Environmental Report
- 8. Final Environmental Report 9 Design Documents
- 10. BESSAR Attachment 23-1 compares the soils area to other areas with initial review, and rereview of respect to the preparation,The root cause of theSubsection inconsistencies the ESAR. (1), 3.3 that occurred in the soils area are addressed in PartMitigating circumstances of this response. il that contribut to the inconsistencies were the change in level of detain licensing required technical information contained in the FSAR, and the lack of change or question activity in the soils area.
that inconsistencies (other than the Additional in the FSAR are being corrected by the total Toils area) may exist rereview program that has been undertaken as described inAn additional bene Parts (2)b and c of this response. is the FSAR rereview program is that an education process occurring within all design dirciplines, making them moreaw f
Control document revisions that have been instituted to (1),
preclude design contradictions are described in Part Subsection 3.3.
Revision 4 23-38 11/79
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'^"'Wveww-,w.,
RESPONSE TO QUESTION 23, PART (2) [50.54(f)]
SECTION 3.0, RESPONSE TO PART (2)b 3.1 Review of the PSAR Commitment List Original PSAR commitments are contained in the PSAR Commitment List. This List includes the PSAR section, a statement of the commitment, the PSAR page containing the commitment, the revision number of that PSAR page, the company responsible for the commitment, the status of the commitment, and the commitment disposition document. Each PSAR commitment is either attached to an FSAR section for review or, if not applicable to any specific section, distributed for review as an individual rereview package so that all PSAR commitments are included in the FSAR rereview program. The review of the PSAR Commitment List items is described in the sequence of the rereview program activities discussed in this response. As part of the rereview program, the PSAR Commitment List will be updated by completing the columns titled " Status" and " Disposition Document" to ensure that they contain curreat information.
Our April 24, 1979, response to Question 1, part b, stated, "To assure that the PSAR design commitments were properly dispositioned through incorporation into a project design document or the FSAR, a final review I
and update of the PSAR Commitment List will be completed by January 1, 1980." It was determined that a review of the PSAR Commitment List, in lieu of reviewing the PSAR itself, was sufficient for this purpose for the following reasons.
- a. When the PSAR Commitment List was prepared, the following steps were taken:
- 1. Initial preparation by an engineer in the Mechanical discipliner (The Mechanical discipline at that time was responsible for the preparation of the SAR.)
- 2. Complete review of the Commitment List versus l
I the PSAR commitments by the Project SAR Coordinator;
- 3. Review of the Commitment List by the Nuclear Group Leader, Mechanical Group Supervisor l
(Licensing Engineer), and Project Engineer.
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23-39 ggvggion1 p
O MCSPONSE TO OUESTION 23, PART ( 2) {$0.54(f)]
These reviews were documented by reviewers initials each time the List was revised and reissued.
Thus, the PSAR Commitment List received the same level of review as other project " design documents."
- b. The PSAR and related documents were used in the preparation of the FSAR. There are existing documentation forms for the preparation of the FSAR sections that identify the PSAR sections reviewed in preparing that FSAR section. Thus, the PSAR Commitment List was not the primary document used in the preparation of the FSAR.
Significant changes that have been made in plant design since the issuance of the const uction permit are identified in FSAR Table 1.3-2.
a rereview of the FSAR against project design documents is suf ficient in itself to ensure that creas of contradiction do not exist.
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23-40 Revision 4 11/79
O RESPONSE TO QUESTION 23, PART (2) [ 50. 54 (f', ]
3.2 Rereview of the FSAR 3.2.1 Organization Personnel and organirations participating in the FSAR rereview program are as follows:
- a. The FSAR rereview program involves various disciplines within the organizations of CPCo, B&W, and Bechtel.
- b. Each company has developed or utilizes existing procedures for the conduct of this rereview as follcws:
Company Procedure No. Procedure Title CPCo MPPM-19 " Conduct of Final Safety Analysis Report Review Program"; Revision 0 Dechtcl IOM, R.L. Castleberry "FSAR Review Procedure -
to File LF 9.0, June Midland Project" 1979 NPG-0414-13 " Processing Contract B&W Engineering Licensing Documents," Revision 3
- c. The rereview program is managed by the Bechtel Licensing Group (composed of engineers), which distributes the applicable rereview documents te various disciplines within Bechtel and also forwards applicable rereview documents to CPCo and B&W.
These rereview packages are reviewed by engineers l within these organizations having cognizance in the subject matter of the rereview package, and these rereview results are evaluated by supervisory engineers, as described in the sequence of rereview activities and rereview documentation given in this response.
- d. The engineers, as well as the cognizant suTurvisory engineers in all three organizations, involved in this rereview are the same engineers currently involved in design activities.
O Fevision 4 23-41 11/79
O RESPONSE TO QUESTION 23, PART (2) 150.54(f)1 i
3.2.2 Rereview Procedure in Attachment The FSAR rereview process, as summarized 23-2, is more fully described in the following sequence of activities.
- a. The Bechtel Licensing Group prepares an FSAR rereview package for each subsection or group of consecutive subsections addressing the same subject, including FSAR NRC questions pertaining to that subsection and associated PSAR commitments from the PSAR Commitment List. Also PSAR commitments which are not specifically related to any FSAR section are distributed as separate cereview packages. Prior to distributing the rereview packages, the Bechtel Licensing Group completes Blocks 1 through 7 on the documentation form shcwn in Attachment 23-3.
the
- b. Af ter receiving an FSAR rereview package, Primary Rereviewer establishes which documentsflow diagrams, (e.g., P& IDS, relay diagrams, control logic diagrams, and various other documents in which licensing commitments are contained) the package must be rereviewed23-3. against
, and noces these in Dlcek 8 of Attachment l
c.
The Primary Rereviewer then systematically rereviews each document noted in Block 8 and indicates l whether any conflicts exist between the document The rereviewer makqs any and the PSAR section.
corrections arising from a conflict and nstesThe these in the resolution column of Block F. consis-rereviewer also rereviews the package fo*
tency of cross-referenced FSAR sections, figures,a PSAR commitments and makes appropriate corrections.
Following this, the Primary Rereviewer indicates any required interface review by a check in Block 21.
The Primary Rereviewer and the Group Supervisor (or other specitied individuals, depending uponthen sign the form in the company procedure) l d. The signature of the Group Supervisor indicates l agreement with the quality and quantity of theThe Supervisor 4
review by the Primary Rereviewer.
checks to ensure that the applicable documents areall applicable included in the review package and that The in e--face rereviews have been designated.
Q-s rereview package is then transmitted to the Bechtel Licensing Group.
Revision 4 2 ~4 11/79
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- HCSPONSU 'IU QUESTION 23, PART (2) 150.54(f)]
e.
The Bechtel Licensing Group makes a copy of the original rereview package to correspond to each interface rereview designated in Block 11 of Attachment 23-3 Prior to distributing the inter-f ace rereview packages, the Bechtel Licensing Group completes Block 10 on the documentation form to signify the date scheduledThe for original the completion rereview of the interface rereview.
package is retained in the Licensing Group files.
f.
Af ter receiving an FSAR rereview package for the Interface Rereviewer interface rereview,if determines which, any, additional documents the package must be reviewed against and adds 23-3 those to beneath the list in Block 8 of Attachment The those listed by the Primary Rerev; ewer.
Interface Rereviewer then systematically rereviews each of the documents added to Block 8 to determine if any conflicts exist betweens these documentsFor his areas of responsib and the FSAR section.
the Interface Rereviewer also rereviews the package for consistency with cr ss-referenced FSAR sections, figures, tables, chapter references, NRC questions, Following completion of the and PSAR commitments.
rereview, the Interf ace Rereviewer and Group Supervisor (or other specified individuals, then initial thedepending form upon the company procedure)The interface rereview package is in thenBlock 11.
transmitted to the Bechtel Licensing Group.
The Bechtel Licensing Group forwards the original 9 rereview package and all interface rereview Prior packages to with comments to the Prisary Rereviewer.
distributing the packages for resolution of comm v.. nts, the Bechtel Licensing Group completes Block 12 the documentation form to schedule the completion of the resolutions.
- h. Af ter receiving the original rereview package and j all interface rereview packages with comments, the Primary Rereviewer resolves all interf ace comments which have outstanding questions with the respective The Primary Rereviewer l Interface Rereviewer.
clearly indicates whether an interface comment is
( The to be incorporatid into an FSAI. change.
Primary Rereviewer is responsible for determining if any recent changes to the FSAR affect any ofThe Prima i the comments.
i O Revision 4 23-43 11/?9
b v PART (2) [SO.34(f)]
RESPONSE TO QUESTION 23, Block 13 of Attachment 23-3 if an FSAR change is required for the package and then signs, along with the Group Supervisor tor other specified individuals, depending upon the company procedure),
in Block 13 to indicate completion of the h rereview.
The entire package is then transmitted to t e Bechtel Licensing Group. ,
Upon completion of the resolution of comments by i
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the Primary Rereviewer, the Bechtel Licens ngin Group initiates an FSAR change (if required) accordance with Engineering Department ProjectThey obta Instruction 4 23.1. from CPCo, B&W (if required),
FSAR (following review) and Bechtel and then prepare the input forrevisio
- f. The original rereview packages and interf acerel Licensing Group files. i k.
Changes to the FSAR identified during the rerev ew process are incorporated into the FSAR duringChanges to i
future revisions.
identified during the rereview process are ident -
fied and are tracked by the Bechtel Licensing iGroup Attachment in the " Resolution" column ofin 23 d
accordance with the rereview procedure unt l l
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RESPONSE TO QUESTION 23, PART (2) (50.54(f)]
3.2.3 Processing Resulting Changes
- s. The revised design documents are routed to Field Engineers in accordance with the requirements of FPD-1.000, " Design Document and Correspondence Control." The Field Engineers, in accordance with FIG-3.200, " Field Engineer Responsibilities," are required to review the design documents and their resultant effect on construction with respect to
- 1) interferences and conflicts, 2) incorporation of change addenda, 3) correlation of referencas and interf acing documents, 4) clear, concise, and technical clarity, adequate
- 6) legibility, 7) details and notes, 5) changes affecting completed work and current construction planning, 8) other pertinent features. Any deficiencies or discrepancies are resolved.
- b. In accordance with Project Special Provision G-6.1, " Quality Control Inspection Plans," changes in design documents will be reflected in revisions l to the activity descriptions, inspection criteria, supplementary records, and inspection activity I
codes in the Project Quality Control Instructions and Inspection Records.
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- c. Open Inspection Records which are affected by revisions to Project Quality Control Instructions These will be revised to incorporate the changes.
revisions will be controlled by a revision to the Quality Control Inspection Record number.
- d. A design document change which physically affects completed work will require the initiation of a new Inspection Record. The new Inspection Record will be developed to cover the inspection of the work required to accomplish the design change.
Each new Inspection Record will be identified with the number of the record for the original work Each new plus an alpha suffix (a, b, c, etc).
Inspection Record, when it is completed, will The be attached to the original Inspection Record.
new Inspection Record will specify the design change that brought about the additional inspection
' work.
- e. Design changes to completed work are addressed in i
Project Special Provision G-3 2, " Control of Nonconforming Items." Completed work which has been inspected and found to be satit?actory is classified as conforming.
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Revision 4 1
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O RESPONSE TO QUESTION 23, PART 2 [50.54 (f) }
3.3 Review of Engineering Department Procedure 4.22 The following sequence of events took place relative to the review of Engineering Department Procedure 4.22, " Preparation and Control of SAR."
a.
Review of Engineering Department Procedure 4.22 was by the Project Quality Engineering, and included coordination with the Project SAR Coordinator.
- b. Primary consideration was given as to whether the originator of a SAR section had sufficuent guide-lines in which to prepara a SAR section.
the
- c. The results of the review were affirmative:
engineer had sufficient direction in the procedure.
23, 1979, This was documented in an IOM dated July R.L. Castleberry to L.A. Dreisbach.
- d. Subsequent to the completion of Item c, above, it was decided during a series of meetings to revise Engineering cation.
Department Procedure 4.22 for clarifi-(T
" Standard Format and Content of Saf ety Analysis Reports for Nuclear Power Plants," were moved from Section 2.0, " Scope" to Section 5.0, " Engineering and Administrative effort." This revision is to be completed by December 1, 1979.)
23-46 Revisien 4 11/79
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RESPONSE TO QUESTION 23, PART (2) (50. 54 (f) ] ]
l SECTION 4.0, RISPONSE TO PART (2)c !
I The FSAR rereview program has been extended from the original plan to include the entire FSAR, with certain exceptions as ,
follows:
- a. Appendixes such as 2A, 2B, and 2C contain only test data for which a rareview would be meaningless.
b.
Security Plan which is currently under review and will be completely revised when it is submitted.
- c. Technical Specifications (Chapter 16) which will be extensively reviewed prior to NRC final review 6 months to 1 year prior to the issuance of an operating license.
d.
Fire Protection Evaluation Report which will be completely reviewed and revised upon receipt of fire protection questions frcm the NRC.
e.
Site Emergency Plan which was extensively revised in Revision 18 (February 1979) to the FSAR and will be revised as necessary to meet new, additional require: rents.
The entire rereview program will be completed by July 1980, with all resulting revisions to the FSAR made by the July 1980 amendment.
Revision 4 23-47 11/79
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RESPONSE TO QUESTION 23, PART (2) [50.54(f)}
SECTION 5.0, RESPONSE TO PART (2)d The purpose of the auditThe committed to in Item 4 of theeig audit will cover two effectiveness of the rereview.
aspects as follows:
- a. Degree of compliance with rereview procedures.
b.
Technical correctness of rereview dispositions.
The audit committed to in our response to Question 1 once during the course of the FSAR rereview (commencingan January 1, 1980)
(August 1, 1980) .
An audit plan will be prepared consistent The audit with team the CPCo Bechtel will will serve comprise personnel as thefrom auditeach team of leader.
the three organizations.
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$"/me$"dOW#c'Ompany.
j FSAR REVIEW FLOW CHART BeChief Job 7220 Primary Dechtel Final Project inledace/ReWew Licensing Approval Administration Responsible Comp / Disc Group _
Comp / Disc _
l REVIEWS FSAR REVIEW PACKAGE PREPARES FSAR j AGAINST DESIGN REVIEW PACKAGES 4 DOCUMENTS. IN- '
BY FSAR SUB-DICATES REQUIRED ,
SECTION & PSAR l CHANGES. COMMITMENT LIST.
- DESIGN ATES RE.
! OUIRED INTERFACE REVIEW. -
COPIES FSAR
' REVIEW PACKAGES DISTRIBUTES REVIEW PACKAGES TO DESIGNATED INTERFACE REVIEW COMP / DISC.
REVIEWS FSAR 1
REVIEW PACKAGE a 8
{ "
ya eau em um um em as > AGAINST DESIGN DOCUMENTS. IN-s DICATES REQUIRED g CHANGES. .
SENDS ORIGINAL.
FSAR REVIEW l I PACKAGE AND
' g [. m INTERFACE REVIEW l COPIES TO PRIM ARY t
- I -
COMPIDISC FOR g RESOLUTION OF IN-TERFACE COMMENTS.
I I I FINAL REVIEWI
- APPROVAL BY CPCo, Q Y B8W (IF REQUIRED) ~ ~ ~ ~ ^
re l
d O RESOLVES PREPARES SAR CHANGE NOTICES IN m> AND DECHTEL P110 JECT ENGINCER l; {
go INTERFACE ACCORDANCE WITH T YPING 1 s COMMENTS AND EDPI 4 231. OHTAINS ' ' ' - - - - -- -- Pitt"8 l LNG
" SENDS REVIEW ? FINAL APPROVAL $lG- DIS'ottitUilON i As PACKAGE IN FINAL NATURES PREPARES &
Se> FORM TO LICENSING INPUT FOR FSAR GROUP.
i
[ REVISION
~'-' -
FS^R REVIEW DOCUMENTATION FORM I -
uio'^~o eaosect O' JOB 7220 1. REVIEW LOG NO.
- 3. PRIMARY REVIEW ~4C; PLANE -
, 2 COMP ANY C BECHTEL C B&W f' ~~CPCc 6.PSAR COMMITMENT UST ITEMS i S NRC O'JESTIO*;5 t
- .8 FSAA SUBSECTION '
l i
l 7. RETURN TO SECHTEL trCENSING SV
- 8. PHASE I. DESIGN DOCUMENT REVIEW f RESOLUTION CONFLICT ,
DESIGN DOCUMENT YES / NO YES I NO YES / No YES / ho YES I NO YES / NO
- l YES / NO _
l YES / NO YES / NO l
YES / NO YES / NO e
4 9 INiil AL REVIEW APPROV AL (INDICATE REQUIRED INTERFACE REVI LCATE7 (DATE) ISUPERviSOR:
iPaMaAv REwEniA#
l 10 RETURN TO BECHTEL UCENSING SY 11, PM ASE il INTERF ACE REVIEW C BECHTEL INTERFACING STAFF REVIEW.' C M&C5 BECHTEL D:SCIPLINE INTERF ACE REVIEW C PLANT DSN .
- 0 ARCH C MECH
' .ARCM CCML 11 NUCLE AR ,
C PCAE , , , , , , , ,
~.CML 11 CONTROL 5YSTEM siSTRESS .
l C PLANT DSN CCNTRCL Sv5 _._ _
O ELEC ELEC
'!OTHER -_ C STRESS _
D GEOTECH _
4
~ MECM NUCLEAR O saw C CPCo __
l 12 RETURN TO BECHTEL UCENS!NG SY 13 PHASE 111. RESOLUTION OF COMMENTS FSAR CHANGE REQUIRED YES I NO Group is Authonzed To trutiste A FSAR Chan0e VAthout All Interf ace Comments Resolved. Licens*0 Additionalinterface Revew (OATE:
(OATEi 46uPERvn50Ri (PAh 4ARY REv6 EWER: G-0648 Attachment 23-3
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RESPONSE TO OUESTION 23, PART (2) 150. 54 ( f ) ]
ATTACHMENT 1 TO ATTACHMENT 23-3 The form illustrated in Attachment 23-3 is used to document the various phases and steps of the rereview of the Midland plant FSAR. Thirteen numbered blocks are completed for each rereview package.
- a. The first block, " Review Log No," identifies each rereview package by a unique number assigned by the Bechtel Licensing Group.
- b. The second block, " Company," designates the primary rereview company for the rereview package as assigned by the Bechtel Licensing Group.
- c. The third block, " Primary Review Discipline," is used to designate the discipline assigned primary rereview responsibility by the Bechtel Licensing Group.
- d. The fourth block, "FSAR Subsection," is completed by the Bechtel Licensing Group to designate the FSAR subsections included in the rereview package.
- e. The fif th block, "NRC Questions," is completed by the
Bechtel Licensing Group to indicate any FSAR phase NRC questions pertaining to the subsections identified in Block 4 included in the rereview package.
- f. The sixth block, "PSAR Commitment List Items," is completed by the Bechtel Licensing Group to indicate any PSAR Commitment List items pertaining to the subsections identifiea in Block 4 included in the rereview package.
- g. The seventh block, " Return to Bechtel Licensing by," is completed by the Bechtel Licensing Group to indicate the date when the completed Phase rereview package is to be received by the Bechtel Licensing Group.
- h. The eighth block, " Phase I: Design Document Review,"
is completed by the Primary Rereviewer to indicate all documents against which the rerevie package is rereviewed, to indicate whether conflicts exist netween the rereview FSAR section and the other documents, and to indicate the necessary resolution of any conflict, as appropriate.
items, the For NRC Questions and PSAR Commitment List Primary Rereviewer verifies that no conflicts exist with the FSAR text, and that the FSAR text corresponds (gs) to the commitments in the FSAR questior.s and PSAR Commitment List and is complete and correct.
Attachment 23-3 Revision 4 11/79
O RESPONSE TO QUESTION 23, PART (2) (50. 54 (f) ]
i.
The ninth block, " Initial Review Approval," is completed by the Primary Rereviewer and the Group Supervisor (or by other specified individuals, depending Prior to signing upon the for rareview company procedure).
approval, the Primary Rereviewer designates all required interface rereview by checking the appropriate boxes in Block 11. The signature by the Group Supervisor indi-cates agreement with the quantity and quality of the review by the Primary Rereviewer. The Supervisor checks to ensure that the documents used by the Primary Rereviewer cover all applicable interfaces. The rareview package is then returned to Bechtel Licensing.
The tenth block, " Return to Bechtel Licensing by," is j.
completed by the Bechtel Licensing Group to indicate the date when the completed Phase II rereview package is to be received by the Bechtel Licensing Group following an interface rereview.
- k. The eleventh block, " Phase II: Interface Review," is completed by the individual performing the interface rareview as designated by the Primary Rereviewer (see Block 9 above). If additional documents are used by the Interface Rereviewer, these documents are listed in Block 8 in accordance with the procedures described therefor. Following satisfactory completion of the interface rereview, the Primary Reviewer and the Group Supervisor or other specified individuals (depending The upon the company proceoures) initial this block.
Supervisor's initialsindicates approval of the raraview performed by the Interface Rereviewer as discussed under Block 9, above. The interface rereview package is then returned to the Bechtel Licensing Group.
1.
The twelfth block, " Return to Bechtel Licensing by," is completed by the Bechtel Licensing Group to indicate the date when the completed Phase II rareview package is to be received by the Bechtel Licensing Group following resolution of the comments.
- m. The thirteen block, " Phase III: Resolution of Comments,"
l is completed by the Primary Rareviewer following the resolution of all interface comments resulting from the interface review. The Primary Rereviewer indicates whether each interface comment is to be incorporated into the FSAR. The Primary Rereviewer indicates whecher an PSAR change is required by designating "yes" or "no" and, following resolution of all interface comments, signs the form along with the Group Supervisor or 1
O Attachment 23-3 I Revision 4 11/79
O RESPONSE TO QUESTION 23, PART (2) [50.54(f other procedures) specified individuals (depending upon the companyto indicate c The Supervisor's signature indicates approval of the resolution of comments by the Primary Rereviewer consistent with the original rareview discussed under Block 9, above. l / l l Attachment 23-3 O Revision 4 11/79
O l l RESPONSE TO QUESTION 23, PART (3) Revision 4 11,'? 9
O RESPONSE TO QUESTION 23, PART (3) [50. 54 ( f ) ] SECTION 2.0, INTRODUCTION (3) of the question, it was requested In Subpart a of Partthat we provide our rationale for our conficence that quality assurance deficiencies do not (or will not ) exist in other areas. Our confidence stems from three factors, as follows:
- a. The recognition of the differences between soils and other work, as described in Section 3.0.
be The fact that, from the outset, a Quality Assurance implementation. Subsection 4.1 providesSubsection a list of Quality Assurance 4.2 provides more Program improvements. detail as to the extent and results of selected (3) of improvements as requested in Subpart b of Part the question.
- c. The programmatic and generic corrective actions which have been taken, or will be taken, as described in our response to Parts (1) and (2) of the question and as summarized in Section 5.0.
l l l l l O 23 30 Revision 4 11/79 l
RESPONSE TO QUESTION 23, PART (3) [50.54(f)] SECTION 3.0, DIFFERNECES BETWEEN SOILS WORK AND CTHER WOR l Prior to 1977, the major site construction activities The major specific were i in the civil and structural areas. activities were soils, rebar and embeds, concrete,Incadweld ng, structural steel erection, and liner plate erection.1977, ele became significant. i Soils and concrete are which rely, in large part, uponsimilar the testsbulk installation at a given point Additional activit es h representative of the quantity of material placed. confidence in the quality of the concrete is achieved throug Concrete several. factors that are not available to soils tion work. d work is more scientific than soils placement and compaca The physical testing of concrete (cyliner measurable. breaks) provides acceptable or unacceptable results on aWith soils, short-term basis. is the long-term monitoring to the initial acceptance test, ill. program for settlement of structures supported i ities in the f in The inspection and controls for the construction act v the quality of these items. by CPCo QA from April 1976 to September 1978 and embeds hav r had a 100% overinspection by CPCo QA from June 1972 to I September 1978. including for which welding and liner plate erection, ionareand activitiesStructu ifications there are characteristics accessible to inspect reinspectica, allowing for independent subsequent ver of the quality of these items. l and i The above is also true of most aspects of mechan caThe major improvement d ior to electrical construction activities. i l and with regard to specifications and QCIs were ma e p Electrical disciplines. d walkdown These systems will be subject to overinspections an provide additional detailed evaluation ification of the Subsequent to the construction acceptance, a syc testing activities. O ' 23-51 Revision 4 11/79 2.-..-
RESPCNSE .O QUESTION 23, PART (3) [50.54(f)] O 4.1 111 story and Chronoloov of Improvements, In General 1970
- 1. CPCo CA Program as presented in the Midland Plant PSAR was approved by the AEC Staff in the Safety l Evaluation Report. T i
1973
- 1. The Bechtel Quality Control Organization at the site was reorganized to be independent of the Bechtel Construction organization at the site.
- 2. The CPCo Quality Assurance organization was formed with a staff of five persons.
Q7j
- 1. The review and approval by CPCo Quality Assurance of Bechtel Quality Control administrative procedures and inspection instructions was initiated.
- 2. The number of CPCo Quality Assurance professional personnel overviewing the Bechtel Quality Assurance Program was increased from five to six.
- 3. The CPCo Quality Assurance program policies and proedures were significantly improved.
1975
- 1. CPCo Quality Assurance inspection or storsJ materials was instituted.
- 2. The number of CPCo Quality Assurance professional personnel overviewing the Bechtel Quality Assurance j Program was increased from six to seven'.
1976
- 1. Bechtel quality trending was instituted.
i was
- 7. The CPCo Quality Assuranca Program (Topical Report) approved by NRC.
3. CPCG Quality Assurance overinspection of rebar install-j ation was instituted.
- 4. The Bechtel Quality Control Notices Manual was prepared specifically for the Midland Project and the Bechtel Field Inspection Manual was phased out.
l
- 5. Major biennial audits of the Quality Assurance Program, utilizing outside consultants, were initiated by CPCo O- Quality Assurance.
Revision 4 23-52 11/79 l
O RESPONSE TO QUESTION 23, PART (3)(50.54(f);
- 6. The number of CPCo Quality Assurance professional personnel (excluding auditors) overviewing the Bechtel Quality Assurance Program was increased from seven to nine.
the 7. Bechtel Resident Engineering was established at jobsite. 1977
- 1. CPCo Quality Assurance overinspection of embeds was instituted.
- 2. CPCo Quality Assurance Program Procedures de cation were significantly improved.
3. CPCo Quality Assurance Program Procedures dealing with reporting to NRC and turnover were originated.
- 4.
The Bechtel quality trending activity was significantly improved.
- 5. CPCo Quality Assurance was reorganized to form Examination and Test Verification Section, the latter having emphasis on hardware evaluation.
- 6. The following five additional Regulatory Guides were1.38 implemented:
for packaging, shipping, receiving, storage, and handling; 1.39, dealing with housekeeping; 1.55, dealing with concrete placement for Category I structures; 1 and testing personnel; and 1.94, dealing with the quality assurance requirements for the installation, inspection, and testing of structural concrete and structural steel. 7. An extensive training activity was implemented for CPCo Quality Assurance personnel. 8. CPCo Quality Assurance became the overinspection organiza for 0-listed pressure tests. O Revision 4 O 11/79 23-53 i
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O RESPONSC TO QUESTION 23, PART (3)[50.54(f)]
- 9. NRC implemented an " increased inspection" program,
- 10. The number of CPCo Quality Assurance professional overviewing the Bechtel personnel (excluding auditors) !
Quality Assurance Program was increased from nine to twenty-two.
- 11. Bechtel and CPCo reviewed specifications to improve specificity.
- 12. Bechtel QC and CPCo QA reviewed Quality Control Instructions (QCIs) to improve inspection callouts in the QCIs.
- 13. The Bechtel monitoring activity was improved to conduct more product-related monitors.
- 14. Bechtel QA management audits were increased from one to two per year.
1978
- 1. CPCo Quality Assurance overinspection of all other areas, in addition to the civil area, was instituted.
- 2. Approximately 30 CPCo Quality Assurance overinspection plans were prepared and implemented.
l One hundred percent CPCo Quality Assurance review of 3. supplier radiographs being received with new deliveries was instituted. 4. The ASME Code Stamp Authorizations were extended to Bechtel for another three years.
- 5. Fif teen CPCo Quality Assurance Department Procedures were completed, revised or originated dealing with department procedures; organization; personnel training, documente; source and receiving inspection planni inspections; nonconformance reporting , corrective actions and statusing; periodic reporting; review of quality-related regulations, codes, standards, speci-fications, and other external documents; procurement quality assurance requirements; inspection stamp control; O
23-54 Revision 4 11/79
O RESPONSE TO QUESTION 23, PART (3)[50.54(f); 1 qualification audit and certification of quality assuranceteam team members; qualification, quality assurance audittraining and certification of inspection and personnel; analysis and resolution of significant quality problems; overinspection and primary inspection.
- 6. The primary responsibility for the overview of the B&W NSSS installation was given to CPCo Quality Assurance.
7. The number of CPCo Quality Assurance audits performed was doubled from the previous year.
- 8. Resident inspection was instituted by NRC.
- 9. The number of CPCo Quality Assurance professionaloverviewing personnel (excluding auditors) Quality Assurance Program "
to twenty-three. 1979 1. The rareview of qualification test data for Bechtel procured items was completed. 2. The rereview of qualification test data for B&W procured items was inititted. 3. The rereview of quality documentation for B&W procured items was completed. 4. The rereview of quality documentation for Bechtel procured items vas initiated. 5.
" Surveillance" was eliminated as a Bechtel final inspection technique.
eliminated (with minor
- 6. Nonscientific exceptions) sampling wasas a Bechtel final inspection technique.
7. ASME Code Stamp Authorizations were granted for B&W site installation work. d 8. A CPCo QuaJ ity Assurance Program Procedure was originate and implemented for processing NRC Bulletins, Circulars, and Information Notices. Revision 4 . 11/79 23-55
r _ RESPONSE TO QUESTIO'1 23, PART (3)[50.54(f)]
- 9. CPCo Quality Assurance Department Procedures were originated and implemented dealing with turnover, forms, requ
- 10. " Midterm Inspection" was performed by NRC.
I'l. LCVIP Inspection of the Bechtel Ann Arbor Office was performed by Region IV.
- 12. Review and revision of the CPCo Quality Assurance Program Procedures was completed by the Senior Vice President and his staff.
- 13. The number of CPCo Quality Assurance overviewing professional the Bechtel personnel (excluding auditors)
Quality Assurance Program was increased from twenty-three to twenty-six. I e i l l I O Revision 4 l 11/79 23-56
O RESPONSE TO QUESTION 23, PART (3)[SO.54(f)) 4.2 Specifies of Selected Improvements: , 4.2.1 Review of Specifications In September 1977, a review of specifications was initiated by Bechtel Engineering and CPCo Quality Assurance. This review was performed in association with the revie s of Quality Control Instructions (QCIs) as described in Subsection 4.2.2.
~
The specifications reviewed were selected specifications Reviewers for C-listed equipment and activities. (Quality Assurance Engineers, Quality Engineers, and cognizant discipline engineers) were to determine anyarea with other project criteria, or lacked necessary criteria, including dimensions or tolerances. A total of 50 specifications, as follows, were reviewed by CPCo Quality Assurance, and 23 of these 50 specifications 5 were also reviewed by Bechtel Project Engineering:25 civil, 11 m architectural, At that time, there was a total 8 general specifications. of 189 Q-listed specifications issued for use on the Midland project. As a result of this review, specification revisions were made in 12 instances to provide specific toleranc-or further clarity, or correction of editorial comment.
~ A review of those specifications being used for construction
, and not included in the reviews described above was initiated on May 8, I?'/9, and was completed by Project Engineering on July J 3,1979, resulting in revision to three specifications. In addition to the above specification reviews, the Bechtel Chief Engineering Staff, and CPCo QA, performed a dimensional tolerancing review of a portion of the 13, 1977. containment spray system from November 2 to December This was a review to determine if there wer9 any problems associated with tolerancing for specified quantitative parameters (dimensions, pressure, temperature, chemical content, etc). As a result of the dimensional to specifications tolerancing review, th:re ucre S revisions to provide tolerances or more clarity. l Revision 4 23-57 11/79
O RESPONSE TO QUESTION 23, PART (3)[50.54(f)] In March 1978, 95 Field Change Requests (FCRs) issued in January 1978 were reviewed to determine whether project personnel were demonstrating a concern for specificity. Eleven FCRs provided positive demonstration of project concern for specificity and improved awareness in this area. An example of revisions that were made as a result of these specificity reviews is provided by the following comment and response. Comment: It should be noted here that Specification 7220-C-42 is incomplete in that the tolerances required for fabrication are not included in this specification. Blenk spaces have been inserted in the specification where these tolerances are to be inserted at a later date. Response: The current revision of Specification 7220-C-42 is Revision 2, dated July 21, 1978, " issued for purchase." This revision is now complete and up-to-date. This review resulted in some project specifications being revised and emphasized the need for specificity to a broad spectrum of project personnel. The specification changes were processed utilizing the change control system described in the response to Part 2 to ensure consideration of impact on completed work. I l l l l
)
Revision 4 l 23-58 11/79 l i
( l RESPONSE TO QUESTION 23, PART (3) [50.54(f)] 4.2.2 Bechtel QC and CPCo CA Review of Quality control Instructions From April 1977 to August 1977, a review of all isseed Quality control Instructions (OCIs) was conducted jointly by Bechtel Quality Control (OC) and CPCoThe purpose Quality Assurance. improve the specificity cf the inspection callouts in the OCIs. 52 QCIs were reviewed in their entirety, resulting in all QCIs being revised to incorporateAs a result of this agreed upon changes.it was considered necessary to revise SF/ PSP G-6.
" Quality Control Inspection Plan". requirements to provid callouts.
24, 1979, response to Question 1, As committed by the April Part a, Section D, Pace I-18, a further review of the CCIs was completed by'Bechtel in June 1979 to ihidentify those QCIs which call for "Surveillances" and wh cca As a result(a) of this identification, revisions wereto require the initiated: activity for inspections of record, and to limit the utilization of " Surveillance" for defect preventionto clarify the activity only and (b) As of October 1979, 7 identi-of supplementary records. fied QCIs have baen revised to incorporate this and 26 identified OCIs are in the review stage with completion scheduled for December 1979. I ! The following additional actions are planned as described l in Part (1) Subsection 3.8. A. be revised to provide requirements for inspe planning specificity and f r the utilization of scientific sampling rather than percentage sampling. This action is scheduled te be completed by January 24, 1980. B. OCIs in use will be reviewed to ascertain that provisions have been Thisincluded action and consistent any required revisions with thearerevised co document. scheduled to be completed by March 8, 1980. C. The impact of B (above) on completed work will be () evaluated, necessary. and appropriate actions will be taken asT by May 23, 1980. Revision 4 23-59 11/79
O r RESPONSE TO QUESTION 23, PART (3)[50.54(f)} 4.2.3 CPCo QA Review and Approval of Bechtel CC Administrative Procedures Since January 1974 CPCo OA has reviewed and approved the administrative proceduras in the Lechtel Field Inspection Manual and Quality Control Notices Manual. The c:.,ntrolling documents have varied, but all have been CPCo CA department procedures or Midland Project QA Procedures. This activity is continuing today. i i l l !O 23-60 Revision 4 11/79
ba RESPONSE TO QUESTION 23, PART (3)(50.54(f)I 4.2.4 Bechtel Resident Engineers The Resident Engineering activity, an extension of Project Engineering, was established at the Midland Ann Arbor Of fice Project Engineering and Project Fieldjob Engineering; to provide, as needed, interpretations of design specifications and drawings; to expedite disposition of design changes resulting from Field Change Requests, Field Change Notices and Design Change Notices; to provide approvals of construction activities as required by specifications; and to expedite These Resident resolution of design Engineering and construction problems. activities allow for in-situ determinations of the root causes of design and co.istruction interface problems and provide for timely, hands-on solutions which are backed up by project Engineering reviews. The Resident Engineering activities are described in Engineering 2.14.2, Rev. 6. Department Project Instruction (EDPI)This EDPI, in a the boundaries of the authority of the Resident Engineers, establishes actions of thethe channels Resident Engineers, for control andandthereview of the follow-up activities of Ann Arbor Office Project Engineering. All Engineering Department Procedures are applicable to any design functions which may be performed by the Resident Engineers. As their benefits became apparent and their activities increased, the Resident Engineering Group was increased to the present level of 22 persons, which As includes an the nature experienced Assistant Project Engineer.of activity shifts during civil work to -echanical to electrical), the mix of disciplines in the Resident Engineering Group has been shifted correspondingly. The timeliness of Resident Engineering interpretations, responses to Field Change Requests, design changes of Field Change Notices reduces The thephysical probability of presence deficiencies and availability in construction. of Resident Engineering at the site invites and encourages consultation and discussion O . Revision 4 23-61 11/79
- - - . - - ,,-y . . .. , -..--,.y- ----- ,.,m, --m- . . ___-#,_.--,.--,,-,-____,__.,-_.-_.,_,,,,mr.-,e., -
,-,...-.-_m- - - ..m-
_ - . - - = _ _ _ . _ . .. - O RESPONSE TO QUESTION 23, PART (3)[50.54(f)] The Resident Engineers thus serve during construction.as the focal point and channel for the exchange of information between construction and Engineering, thereby improving the level of confidence that SAR and design requirements are met. It is the intent of the Project Management to continue the supportive and beneficial activities of the Resident Engineers at a level commensurate with the construction activities. O . Revision 4 11/79 23-62
() RESPONSE TO QUESTION 23, PART (3)[30.54(f)] during construction. The Resident Engineers thus serve as the focal point and channel for the exchange of information between Construction and Engineering, thereby improving the level of confidence that SAR and design requirements are met. It is the intent of the Project Management to continue the supportive and beneficial activities of the Resident Engineers at a level commensurate with the construction activities. i l O Revision 4 11/79 l 23-62 l
O RESPONSE TO OUESTION 23, PART (3) (50.54(f)] 4.2.5 Bechtel Monitoring Activity Improvements The standard monitoring activity, as described in Quality Assurance Department Procedure C-1, was amended September 15, 1977, to provide a more representative ascessment of Quality Assurance Program effectiveness. The amended mor.itoring procedure was structured to use of a product to the essential requirements of projectsyste documents specifying quality. i The effect of the amended procedure was to increaseexp specifications, calculations, etc) that wereItto beIt caused addit monitored. to completed work, as well as to inprocess work. required preparation of a list of potential monitoring subjects to be developed from the Quality Assurance Program elements and it required the preparation of checklists which were extracted from the various project procedures and manuals. The revised monitoring activity has enabled a more thorough assessment of the Quality Assurance Program, and permitted the early identification and correction of potential problems before they could become repetitive. The first year of activity following the amended proced and project audit activities with 76 findings, as compared to the performance of approximately 100 combined monitoring and project audit activities with 42 findings performed during the previous year. l l l O Revision 4 23-63 11/79
O RESPONSE TO QUESTION 23, PART (3) [50.54(f)] 4.2.6 Quality Assurance Engineering Staffing Levels The site Bechtel Quality Assurance staffing level was increased from five to eight during 1977 to 1979 to accomodate the increase in the number of aforementioned monitors and to be responsive in resolving CPCo overview findings. l l l O Revision 4 23-64 11/79
O [50.54(f)] RESPONSE TO QUESTION 23, PART (3) 4.2.7 Bechtel Quality Assurance Management Audits h In an effort Quality Assurance to better assess Program the effectiveness requirements, the numberof of t e Quality Assurance management audits was increased from one to two per year. 1 i Revision 4 23-65 11/79 r
....,,,,,g,,w.., . - - - - , - , , , , , , - - - , -- .
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O RESPONSE TO QUESTION 23, PART (3) [50.54(f)] 4.2.8 Bechtel Quality Trending Activity The Bechtel quality trending activity, as described in Procedure C-101, was put into effect in July 1976 as a Trending Quality Assurance Program improvement. provides a working tool for Quality Assurance Engineering and its output is used to identify repetitive nonconformances Repetitive requiring more effective corrective action. nonconformances warranting corrective action are processed to the responsible organizations via a Quality Action Request, corrective actions are negotiated, and Quality Assurance follows up to assure the adequacy and timeliness of the actions. Publishing of quality trend data was initiated in July 1976 in the Monthly Project Quality Assurance Activity Report addressed to Bechtel and CPCo key project personnel. In April 1978, Bechtel Quality Assurance initiated supplementary guidelines for the trending. These guidelines provided criteria for initiating graphic trend charts. Prior to this time, trends were identified and charted based upon the judgement of the reviewer. The nonconformances for approximately 120 repetitive construction processes or portions thercof, are tracked monthly and issued to CPCo and Bechtel Quality Assurance Management. Since April 1978, 14 Quality Action Requests have been issued. As a result of a suggestion made during the NRC's Midterm Inspection of the Midland Project in May 1979, a revision is in process to group certain construction activity and noncontbrmance The categories revision wastoimplemented provide on increased sensitivity. The revised procedure a trial basis in September 1979. is scheduled to be issued in November 1979. l l l O Revision 4 23-66 11/79 f l- - vy , ,, _
O
\
RESPCNSE TO QUESTION 23, PART (3)[50.54(f)]
\
4.2.9 Bechtel Topical Report, BO-TOP-1A In November 1976, in order to update the QA Program the from that which was committed to in the PSAR, Bechtel QA Program was revised to incorporate the Bechtel Topical Report, which committed the project to the following ANSI Standards and Regulatory Guides (Only those marked with an asterisk were a carry over from the PSAR.) Regulatory Guide-Revision Date ANSI Standard 1.28 - June 7, 1972
*N45.2-1971
" Quality Assurance Program Requirements for Nuclear Facilities" 1.30 - August 11, 1972 N45.2.4-1972
" Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations" 1.37 - March 16, 1973 N45.2.1-1972
" Cleaning af Fluid Systems and Associated Components During the Construction Phase of Nuclear Power Plants" 1.38 - March 16, 1973 N45.2.2-1972 l " Packaging, Snipping,d Receivir.3, Storage an Handlirg of Items for Nuclear Power Plants During the Construction Phase" 1 39 - March 16, 1973 N45.2.3-1973
" Housekeeping During the Construction Phase of Nuclear Power Plants" 1.54 - June 1973 N101.4-1972
" Quality Assurance for Protective Coatings Applied to Nuclear Fack11 tits
- O Revision 4 11/79 23-67
RESPONSE TO QUESTION 23, PART (3)[50.54(f)] 1.55 - June 1973 N/A 1.58 - August 1973 N45.2.6-1973
" Qualifications of Inspection, Examination and Testing Personnel for Nuclear Power Plants" ,
1 64 - Rev.1, Feb.1973 N45.2.11-1974
" Quality Assurance Requirements for the Design of Nuclear Power Plants" 1.74 - February 1974 N45.2.10-1973
" Quality Assurance Terms and Definitions" 1.88 - August 1974 N45.2.9-1974
" Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants" 1.94 - April 1975 N45.2.5-1974
" Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants" N45.?. 8-Draf t 3, Rev 4 N/A
" Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants."
N4 5. 2.12-Draf t 4, Rev 1 N/A "Rr 'irements for Auditing of vaality Assurance Programs for Nuclear Power Plants" Revision 4 11# 9 23-68 N'
, p. m n - ~ n, - * , ,. -. , -,--,----,e , - - - - , - w-a,,- -,,--n----- , ,-- , ,---- - -v~-,
O RESPONSE TO QUESTION 23, PART (3)[50.54(f)] N45.2.13-Draft 3, Rev 3 N/A
" Quality Assurance requirements for Control of Procurement of Items and Services for Natclear Power Plants" Examples of implementing procedures that were either originated or revised in response to these QA Program improvements were:
MED 2.13
" Project Engineering Team Organization Responsibilities" EDPI 4.55.1 " Project Material Requisitions, Midland Project"
" Storage and Storage Maintenance of FPG-4.00 Equipment and Materials"
" Housekeeping and Cleanliness Control FPG-7.000 During Construction"
" Documentation, Records and Correspondence PSP-G-7.1 Control" l
l Revision 4 11/79 23-69
l RESPONSE TO QUESTION 23, PART (3)[50.54(f)] i 4.2.10 CPCo QA Inspection of Stored Materials As a result of the construction slowdown in 1975, CPCo QA began the inspection of stored materials to assureItems inspected that those materials were not degraded. included NSSS components, miscellaneous mechanical and electrical equipment, cadweld materials, tendon sheathing and trumplates, reactor building liner plate, carbon steel and stainless steel pipe, rebar, and structural steel. After resumption of normal work activities, these operations were phased out with the exception of surveillance of NSSS storage which continued until August 1977. Inspection was done in accordance with Midland Project QA Procedure M-2, " Surveillance of Material During Prolonged Storage at the Midland Site." (This procedure no longer exists.) l O 23-70 Revision 4 11/79 l f i e _ - _ _ . . _ _ , . _ . _ _ _ . - . . - . _ . _ . - - - . ~ _ - . . - _ - -
O f RESPONSE TO QUESTION 23, PART (3) [50.54(f)] l 4.2.11 CPCo Biennial QA Audits Audits CPCo Biennial Audits were instituted in 1976. were performed of the CPCo Design and Construction Nuclear Quality Assurance Program. included l In 1976, the Biennial Quality Assurance Audit l 24 man-days of audit effort. The audit involved 15 man-days of auditing for adequacy and implementation of the at CPCo Quality Assurance Program Procedures (OAP man-days of auditing for the adequacy and implementation of the CPCo QAPPs and Bechtel Nuclear Quality Assurance Manual (NOAM) Ec the Midland Site. The 1978 Biennial Audit included 2070 man-days man-days of audit of auditing effort. The audit included: for adequacy and implementation of the CPCo QAPPS, CPCo QA Department Procedures the CPCo and the Midland General Testing Office Program in Jackson, Manual Michigan; Procedures at20 man-days of auditing for adequacy and implementation of the E*chtel NOAM, Bechtel Field Procedures Ann Arbor, Michigan; and Bechtel 5 mar-days Q?ofNotices auditing Manual for adequacy at Bechtel in and implementation of CPCo Department Procedures, including the Midland Management Organization and Service Departments; and 25 man-days of auditing for implementation of these procedures by CPCo,Bechtel, and B&'d at the Midland Site. All 1976 and 1978 Biennial Audit Findings have been closed. O Revision 4 23-71 11/79
RESPONSE TO QUESTION 23, PART (3)[50.54(f)] 4.2.12 CPCo OA overview The CPCo QA overview activities started For in April 1976 all other for rebar and in June 1977 for embeds. civil, mechanical, welding, NDE, electrical, and instru-mentation and controls, the overview activities started at the end of June 1978 and was fully implemented by the end of March 1979 for activities then in progress. The overview activities implemented between June 1978 and March 1979 was improved over that which was utilized in 1976 and 1977. The improvement consisted of review of Becthel drawings, specificatf o~;, field procedures, and quality control instruction far specificity, and of CPCo QA's utilization of specific overinspection plans. CPCo QA performed overinspection of rebar installation in accordance with Midland Project Quality Assurance Procedure M-8, " Inspection of Rebar Placement." From its inception thru December 1978, this overinspection was performed on a 100% basis for Q-listed concrete placements and, thereafter, on less than a 1004 basis. Based on CPCo QA records of Bechtel's inspection results and the simplicity of the remaining concrete pours, there was sufficient confidence that 100% overinspection was no longer necessary. CPCo QA performed overinspection of embed installation in Q-listed concrete placements in accordance with Midland Project Quality Assurance Procedure M-12, From its inception
" Inspection of Embedded Items."
through September 1978, this overinspection was performed on a 100% basis. Based on CPCo QA records of Bechtel's inspection results, there was sufficient confidence to warrant the discontinuance of the overinspection at ~ that time. With regard to mechanical activities, from November 1978 to October 19, 1979, Bechtel completed 1,382 Quality control inspections, whereas in the same time Bechtel period CPCo QA performed 57 overinspections. t l inspection in the mechanical area was well underway when the CPCo QA overview activity was started; therefore, there was little opportunity for a corresponding CPCo QA overinspection. Thus, there is not a direct correlation between the 1,382 inspections completed by Bechtel from November 1978 to date and the 57 CPCo QA overinspections Revision 4 23-72 11/79
O RESPONSE TO QUESTION 23, PART (3)[50.54(f)] Furthermore, the pcrformed most during the same period.significant Since October 1977, aspects of the mec hydrostatic and pneumatic tests. all of the hydrostatic and pneumatic tests have beenThe majority witnessed by QA-PE&C. not reflected in the CPCo QA overinspection figura of 57 because CPCO Quality Assurance's overinspection of hydrostatic and pneumatic tests are accomplished as a witnes; point in the Bechtel procedures. With regard to welding, from November The 1978 to date,B same period CPCo QA performed 56 overinspectiors. preceeding discussion regarding the correlation between Bechtel inspection and CPCo overinspection equallyFurthermore, for all applies to the welding area. Class 1 and Class 2 component and pip examination is required with minor exceptions and th indicated below. Bechtel originated 4951 From June 1978 to the present, For field radiographs and CPCo QA has reviewed 902. the same period, B&W originated 304 primary systemCPCo field radiographs and CPCo QA has reviewed 100%. j QA will Atcontinue toB&W present, 1,045 review 100% nonprimary of B&W's systemFor all other field radio-graphs. j radiographs were made and 670 reviewed. vendors, over 1,560 vendor radiographs received since December 1978 have been reviewed by CPCo QA. The electrical area can be further categorized as indicated in the following paragraphs. mately 200 inspections, whereas CPCo QA has 13 overinspections. For cable tray installations, Bechtel has completed approximately 200 inspections, whereas CPCo QA has performed 26 overinspections. For conduit, junction boxes, and their supports, Bechtel has completed approximately 500 inspections, whereas CPCo QA has performed 26 overinspections. O 23-73 Re?ision 4 11/79 \
.. #'**=*--wwm_,.,_ ,
" "NmWW s gy m, , , ,
O RESPONSE TO QUESTION 23, PART (3) [50.54 (f)] For electrical penetration asse=blies, Bechtel has completed 5 inspections, whereas CPCo QA has performed 1 overinspection. For the pulling of power cables, control cables, and mately 200 inspections, whereas CPCo QA has pe 114 corresponding overinspections (including 20 ove Of the 114 CPCo QA cable pulling overinspections, 14 were for instrumentation cables.
- For cable terminations, Bechtel has completed approxi-mately 200 inspections, whereas CPCo QA has performed 153 corresponding overinspections.
The higher CPCo QA emphasis on cable pulling in com-parison to cable termination is attributable to the recognition that the cables essentially becomeinaccessi terminations are accessible and any defects are more detectable during checkout and preoperational testing. For equipment installation, Bechtel has completed approximately 24 inspections, whereas CPCo QA has performed 24 overinspections.
- For the electrical aspects of I&C, Bechtel has notNevertheless, CPCo completed any inspections.
performed 14 overinspections (the same 14 cable pulling overinspections mentioned above) and 5 instrument overinspections (motor-operated valves that are already included in the 24 overinspections for electrical For the equipment installation mentioned above). mechanical aspects of I&C, the figures are included in the mechanical overinspection figures. O Re' vision 4 23-74 11/79 _ . _ _ . . ~ . _ _ _ _ . _ _ _ _ . _ . . - . _ _ _ . . . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . .
O RESPONSE TO QUESTION 23, PART (3) [50.54(f)} l l SECTION 5.0, ACTION ITEM FOLOW-UP In this table, the action items which provide programmatic and generic corrective actions are arrayed chronologically by scheduled completion dates. The following abbreviations are used in the table: NA - Not Applicable PE - Project Engineering FE - Field Engineering QC - Quality Control QA - Quality Assurance GT - Geotechnical Service f( Revision 4 23-75 11/79
i O O ACTIOl3 ITEM:, PROGRAMMATIC AND GENERIC CORRECTIVE 1, PART (a) ACTIONS COMMITTED TO Ill Tile RESPONSE TO QUESTION AND IN Tile RESPONSE TO OtIESTIOtt 23, PARTS (1) AND (2) Scheduled Actual Action Item Responsible Completion Completion Action Description Date Date Item Organization < Number and Reference Consultant reports other than Dames & Moore were consideredin in accordance with the guidelines 1 l prov ided NRC Regulatory Guide 1.70, Revision l 2. Consultant reports were not attached to the l FSAR, but portions of consultant reports were l extracted and incorporated into the PSAR text itself. Those portions incorporated into the J Therefore, disposition FSAR become commitments. of recommendations in consulting reports has l been adequately accounted for in the prepara-w 4 y,s tion of the FSAR. l<
- Verification that those portions of consultant reports determined to be commitments and incorporated into the FSAR have been adequately is being reflected in project design documents l' accomplished via the FSAR rereview program described in the response to Question 23, part (2). - Complete in PE i The two Dechtel Oh audit findings reported our Apell 24, 1979, response (Paragraph D.1, l Page I-8) have been closed out. The results l of this audit are being utilized in the PSAR control system study committed to in Subsection
- sw 3.3 of this response to Part (1).
, t[ $ Page I-8 U$r (Question 1, Appe nd ix I , Section 0.1, Question 23, subsection 3.1, Page 7) l 8 i i 1 r
O O Scheduled Actual Action Action Item Hesponsible Completion Completion Description Organization Date Date Item Number and Reference PE
- Complete 2 On April 3, 1979, Midland Project Engineering Group Supervisors in all disciplines were reinstructed that the only procedurally j
correct methods of implementing specification changes are through the use of specificationThis revisions or Specification Change Notices. i was followed by an interof f ice memorandum f rom the Project Engineer to all Engineering Group Supervisors on April 12, 1979. 1 (Question 23, Subsection 3.2, Page 8; and l Subsection 3.9, Page 24) i PE
- Complete b 3 Engineering Department Project Instruction 4 4.49.1 was revised in Revision 2 to state, l
"Under no circumstances will interoffice l memoranda, memoranda, telexes, TWxs, etc l be used to change the requirements of a i
specification." l i (Question 23, Subsection 3.2, Page 9, and Subsection 3.9, Page 24) i i l 4 i WN l 4 l 0;
- o
, a k
O O Scheduled Actual Action Item Responsible Completion Completion I Action Description Date Date Organization item and Heference _ Number 4 A of interof reviewTWXs, telexes, fice memoranda, memoranda, and other correspondence relating to specifications for construction items willand beselected initiated. procurements of Q-listed The purpose of the review will be to identify any clarifications which might reasonably have been interpretedfor as modifying a specification which the specification requirement andforma]Iy changed. An evaluation I itself was not I will be made technical to determinesafety acceptabil?ty, the effect on the implications ' of the potential specification modification, and any work that has been or may be affected. If it is determined that the interpretation 1 0 may have affected any completed work or future ! $ work, a formal change will be issued and
= remedial action necessary for product quality i' will be taken in accordance with approved procedures.
for all The foregoing procedure will be followed j specifications applying to construction of i O-Listed items. For specifications concerning the procurement the foregoing procedure will - Complete ' of 0-Listed items, be implemented on a random sampling basis. PE the The sample size has been established and ww specification selected has been made. l ($ PE 11/30/79 I d5r Review and acceptance criteria for the specifi-t (21) cations will be defined by November 30; 1979. f @ PE 10/80
" The review of construction and selected (47) procurement specifications is scheduled to be
) completed by October 1980. i
! (:) C) , i 4 Scheduled Actual Action Action Item itesponsible Completion Completion Description Date Date Item Organization Number and Reference 4 4 If the acceptance criteria are not met, the (con't) review will be expanded-to include other f . specifications for 0-listed items. At that time, a revised completion date will be established. l ' (Question 23, Subsection 3.2, Page 9, and } Subsection 3.9, Page 25) l l PE. - Complete i 5 A study was completed which examined current current procedures and practices for the prepar9 tion and control of the FSAR ' in view of these experiences. Procedural j i changes will be initiated by the revision of or u y addition to the Engineering Department 1 4 Procedures. This action is scheduled to be
- completed by January 31, 1980.
l (Question 23, Subsection 3.3, Page 11) Complete CT - 6 An interof fice memorandum dated April 12, 1979, was issued by Geotechnical Services to alert i i personnel of the need to revise or annotate ! calculations to reflect current design status. j (Question 23, Subsection 3.4, Page 13) Complete j FE - 7 Field Instruction FIC 1.100, "Q-bisted Soils UE Placement Job Responsibilities Matrix," hasfor been 2;$ prepared and establishes responsibilities l- em performing soils placement and compaction. o (Question 23, Subsection 3.6, Page lar and 3 Subsection 3.7, Page 20; 8
- Subsection ~3.11, Page 30) i i
4 8 4
O O i Action Item Responsible Completion Completion Action Description Date _, Item Organization Date Number and Reference l FE - Complete i ! 8 Construction specifications,identify instructions, and any other . procedurea were reviewed to equipment requiring qualification which had not yet been qualified. No such equipment was identified. Page I-8 (Question 1, Appendix I, Section D.2.e, Question 23, subsection 3.6, Page 18) PE
- Complete 9
A dimensional tolerance study was completed using the reactor building spray pump and ancillary system as the study mechanism. (Question 1, Append'1x I, Section D.2.b, Page I-8) I I w PE
- Complete Y 10 Engineertag reviewed specifications not l @ previcusly reviewed for the specificity or 1 to3crance studies l
(Question 1, Appendix I, Section D.2.c, Page I-D) PE
- Complete i
11 A specific review of the FSAR and specification i requirements for the qualification of electrical and mechanical components has been made as part I of the corrective action relating to CPCo's l 50.55(e) report on component qualification. } Seccion D.2.e, Page I-8) I (Ouestion 1, Appendix , I, OA - Complete [g 12 Quality Assurance will schedule yearly audits N< of the design calculational process for technt d7 quos and ::tual analysis, in each of the design l disciplines.
- g o Section D.4, Page I-8)
(Question 1, Appendix I, l . i l i
ex Scheduled Actual Action Action Item Responstole Completion Completion Description Organization Date Date Item Number and Reference QA - Complete I 13 Aud its of ITT Grinnell hanger design and CPCo relay setting calculation have been conducted. (Question 1, Appendix I, Section D.4, Page I-8) PE
- Complete 14 Dechtel Project Engineering will review design l
drawings for cases where ducts penetrate { vertically through foundations. The possibility , of the duct being enlarged over the design i requirements and the ef fect this enlargement may have upon the structure's behavior will be l evaluated by June 1, 1979. Proper remedial measures will be taken if the investigation 3 w shows potential problems. j .g e (Question 1, Appendix I, Section 'C.S.b, Page I-7)
- Complete QA 15 An in-depth audit of U.S. Testing operations, covering testing and implementation of their QA program will be conducted in late April or early May 1979, by Bechtel Project QA and Enganeering.
Section C.4.b, Page I-133 and (Question 1, Appendix I, Section D.3.c, Page I-18) 1
- Complete QA 16 An in-depth training session will be given to Midland QA Engineers covering the settlement j
problem and methods to identify similar i s conditions in the future. !$< Section D.I.b, Page I-22) 4r (Question 1, Appendix I, em ) g i a i I k 1 2
Scheduled Actual Completion Completion Action A ' ion Item Responsible Date D- cription Organization Date Item a- Reference Number - Complete QA i 17 An in-depth training session will be given to all CPCo and Dechtel QA Engineers and Auditors the settlement to increase their awareness of l problem and discuss auditing and monitoring j techniques to increase audit effectiveness. Page I-22) j (Question 1, Appendix I, Section D.2, - Complete QA 18 An in-depth review of the Bechtel trend program data will be undertaken by Bechtel identification of QA i management to assure the ,' any other similar areas that were notin sufficient depth in the past reviewc. analyzed (Question 1, Appendix I, Section D.I.a, Page I-22) - Complete OC
" 19 Quality Control Instcuctions will be evaluated to ensure that the documentation characteristics l which are to be inspected (i.e., review callouts) are clearly specified.
(Question 1, Appendix I, Section D.3.a, Page I-18) FE 11/15/79 20 Field Instruction 1.100 will be for supplemented demonstrating by establishing requirementsincluding responsibility equipment capability, j for equipment approval, and providing records j 1 identifying this capability. p, (Question 23, Subsection 3.6, Page 18)
! PE 11/30/79 (E
wr 21 See Action Item Number 4 1 og
]
1
)
O O Scheduled Actual Action Action Item Hesponsible Completion Completion Description Organization Date Date Item and Reference Number PE/GT 11/30/79 22 Guidelines for surveillance of testing operations will be developed and included in Field In-structions for the onsite Soils Engineer. Engineering /Geotechnical Services will develop the guidelines by November 30, 1979. (Question 23, Subsection 3.10, Page 27) PE 12/1/79 23 Engineering will revise Engineering Depart-ment Procedure 4.22 by December 1, 1979, to clarify that Engineering personnel preparing the FSAR will follow the requirements of Regulatory Guide 1.70, Revision 2, " Standard
- y us Format and Content of Safety Analysis Reports j
ce for Nuclear Power Plants" (September 1975).
Specifically, Regulatoryrequires Guide 1.70 that(Pages iv and such consul-j v of the Introduction) tant reports only be referenced with the informa-applicable commitments and supporting i
tion included in the text (third paragraph, Page v). Such a requirement would preclude l
. repetition of this circumstance.
1 j (Question 23, Subsection 3.1, Page 7) PE 12/1/79 i 24 To preclude any future inconsistencies between l ' the PSAR and specifications, Engineering Depart ~ ment Project Instruction 4.1.1 will be revised to state that all specification changes, rather for sw than just " major changes," will be reviewed (*j consistency with the FSAR. 4 ta-
*U (Question 23, Subsection 3.3, Page 11) 0
! O O Scheduled Actual ' Action Action Item Responsible Completion Completion Description Organization Date Date
! Item Number and Reference l OA 12/14/79 25 Quality Assurance will issue a Nuclear Quality 2 Assurance Manual amendment to clarify the l requirement that procedures include measures for qualifying equipment number specified conditions. (Question 23, Subsection 3.6, Page 18) GT 12/31/79 26 In view of Action Item 6, Geotechnical Services1979, will revise Procedure FP-6437 by December 31, to to require that calculations be annotated
- reflect current design status.
j (Question 23, subsection 3.4, Page 13) PE 12/3E/79 4 27 Engineering Department Procedure 4.37 will also i j u y be revised by December 31, 1979, to require that i os calculations be annotated to reflect current
- design status.
l (Question 23, Subsection 3.4, Page 13) f PE 12/31/79 28 Civil / Structural Design Criteria 7220-C-501
.will be modified to contain the requirements that a duct bank penetration shall be designed j to eliminate the possibility of the nonspeci fic i
i size duct interacting with the structures. i i (Question 23, subsection 3.5, Page 15) 12/31/79 I UE 29 The civil standard detail drawings will be revised PE l 2;$ to include a detail showing horizontsi and l wa vertical clearance requirements for duct bank I penetrations. The detail will address any mud 3 mat restrictions.
- a
' (Question 23, Subsection 3.5, Page 15) 4 l 4
O Scheduled Actual Action Item Responsible Completion Completion ! Action Description Date Date Item Organization and Reference Number 12/31/79 PC 30 Fngineering and Construction will revise or prepare procedures governing the p1~acement and (39) compaction of soils and implementing the require-ments of the Nuclear Quality Assurance Manual as
- stated in Action Item 25 (Question 23, Subsection 3.6, Page 18)
PE 12/31/79 31 Design documents, instructions, and procedures for those activities requiring inprocess controls ! will be reviewed to assess the adequacy of existing . ' procedural controls and technical direction. Engineering review is scheduled for completion ] by Decemoar 31, 1979. l Page I-11; and ! (Question 1, Appendix I, Section D.2, a nd l
= Question 23, Subsection Subsection 3.7, 3.11,Page Page203 30) 32 Guidelines for surveillance of testing operations will be developed and included in Field Instructions tor the onsite Soils Engineer. Engineering /
, Geotechnical Services will develop the guidelines FE 12/31/79 l by November 30, 1979, and Field Engineering will 1979. i prepare the instructions by December 31, (Question 23, Subsection 3.10, Page 27) l QA 12/31/79 33 The Quality Assurance audit and monitoring programincrease attention will be revised to emphasize and j [g to the need for evaluating policy and procedural A N< adequacy and assessment of product quality. d5 specialized audit training program will be. g developed and implemen;ed to ensure guidance for [ 3 this revised approach. 1 $ (Question 23, Subsection 3.13, Page 35) l i
i , i O O l 4 Sched:aled Actual I; Action Item Completion Completion Action Deccription Itecponsible Item Organization Date Date Number and Reference ! QC 1/24/80 ! 34 Control Document SF/ PSP G-6.1 will be revised ' to provide reouirements for inspection planning specificity and for the utilization of scientific l sampling rather than percentage sampling. (Question 1, Appendix I, Section D.5.f, Page I-20; and I Question 23, Subsection 3.8, Page 22 and Subsection 3.9, Page 24) r 4' 35 Control documents: i OC 1/24/80 ' SP/ PSP G-3.2, " Control of Noncos; forming Items" QA 1/24/80
- 36 OADP C-101, " Project Quality Assurance Trend 1 Analysis
! U$ are in the process of being revised to provide ! 4m an improved definition of implementing require-ments for identifying repetitive nonconforming j cond itions. ! (Question 23, Subsection 3.12, Page 3,l l OA 1/24/80 I 37 Consistent with the intent of Action Item Numbers I 35 and 36, Quality Assurance will review will 2 nonconformance reports which are open, c-become open between this time and Januar) 23, ' 1980. This review will be to identify any repetitive nonconforming conditions pertaining to product type or activity, or pertaining to l g, nonconformance cause. l g;g ar 4 i ** (Question 23, Subsection 3.12, Page 33) ! o i a u l
O V O Scheduled Actual Action Action Item Responsible Comple tion Completion Description Date Date Item Organization _ Number and Reference 38 A study was completed by October 31, 1979, to examine current procedures and practicesinforview i the preparation and control of the PSAR Procedural changes will PE 1/31/80 of these experiences. be initiated by the revision of or addition to the Engineering Department Procedures. (Question 23, Subsection 3.3, Page 11) FE 1/31/80 39 Engineering and Construction will revise or (30) prepare procedures governing the placement and i compaction of soils and implementing the 4 requirements of the Nuclear Quality Assurance Manual as stated in Action Item 25. U$ s (Question 23, Subsection 3.6, Page 18) 5 Design documents, instructions, nd procedures 40 for those activities requiring inprocess controls will be reviewed to assess the adequacy of existing procedural controls and technical d i rect ion. Engineering review is scheduled for i l (31) completion by December 31, 1979, and Fleid FE & OC 1/31/80 Engineering and Quality Control review is l ' scheduled for completion by January 31, 1980. (Ouestion 1, Appendix I, Section D.2, Page I-113 Question 23, subsection 3.7, Page 20, and Subsection 3.11, Page 30) M s< o a b l i I
1 O Scheduled Actual Action Action Item Itesponsible Completion Completion Description Organization Date Date Item and Reference Number _ QC 3/8/80 41 QCIs in use will be reviewed to ascertain that provisions have been included consistent wit 8 3 the revised control document, SF/ PSP G-6 '
" Quality Cont rol Inspection Plans."
D.1, Page I-18; (Question 1, Appendix I, Section Question 23, Subsection 3.8, Page 22; and l Subsection 3.9, Page 24) I 42 Design documents, instructions, and procedures i for those activities requiring inprocess controls J will be reviewed to assess v ne adequacy of existing procedural controls and technical (31) direction. Engineering review is scheduled for U completion by December 31, 1979, and Field (40) Engineering and Quality Control review is PE, FE & QC 3/14/80 m scheduled for completion by January 31, 1980. Any revisions required will be completed by
' March 14, 1980.
Section D.2, Page I-113 (Ques r. ion 1, Appendix I, Question 23, subsection 3.7, Page 203 and , Subsectf.n 3.11, Page 30) 4' OC 5/23/80 i 43 The impact of Action Item 41 on completed work - l will be evaluated, and appropriate actions will be taken as necessary. I (Question 23, Subsection 3.8, Page 223 a nd Subsection 3 9, Page 25) f UI ! Did FSAR sections are being rereviewed as discussed PE 7/80 em 44 4 o in the Respvase to Question 21, Part (2). .i s a (Question 23, Sebsection 3.1, Page 73 and Subsection 3.3, Page 11) 4
O . Scheduled Actual Action Item Responsible Completion Completion Action Description Date Date Item Organization j Number and Reference PE 10/1/80 45 U.S. Testing will be required to demonstrate that to the cognizant Engineering Representative i testing procedures, equipment, and personnel i used for quality verification testing (forcapable and are, other than HDE and soils) were, of providing accurate test results in accordance with the requirements of applicable design documents, i Page I-18; (Question 1, Appendix I, Section D.3.b, Question 23, Subsection 3.10, Page 27; and i' Subsection 3.11, Page 31) PE 10/1/80 ' 46 A sampling of U.S. Testing's test reports (for other than NDE and soils) will be reviewed by the y cognizant Engineering Representative to ascertain i e that results evidence conformance to testing ! @ requirements and design document limits. i (Question 23, subsection 3.10, Page 283 and l Subsection 3.11, Page 31) l PE 10/90 i l 47 See Action Item Number 4 - Compacte . ( soils CPCo-OA 48 CPCo will implement overinspection for l placement, utilizing a specific overinspection i plan. (Question 1, Appendix I, Section C.2.b, Page I-113 and 1 l Section C.I.c, Page I-16) Fw NA NA f CPCo-OA l ($ 49 CPCo will perform overinspection of the U.S. i ar
* [.o Testing soils testing activities and reports, l
j utilizing a specific overinspection plan. Section C.3.c, Page I-17)
* (Question 1, Appendix I, I
i
() O . Scheduled Actual Action Item Completion Completion . Action Description Responsible Item Organication Date cate - Number and Reference OC HA NA j 50 CPCo Project Management and QA review field procedures (new and revised) and CPCo QA reviews QCIs (new and revised) in line with Bechtel before ! release. ' (Question 1, Appendix I, Section D.5.b, Page I-19) CPCo-QA HA NA 51 In 1978, CPCo implemented an overinspection plan to independently verify the adequacy of con-j struction and the Bechtel inspection process, with the exception of civil activities. Re-J[ inforcing steel and embeds were covered in the 1 overinspection. 'u Section D.S.c, Page I-19) !Y (Question 1, Appendix I, ,E CPCo-QA NA NA 52 CPCo reviews onsite subcontractor QA manuals and covers their work in the audit process. i (Question 1, Appendix I, Section D.S.d, Page I-19) ! QC HA NA 53 An ongoing effort is improving the " surveillance" l mode called for in the QCIs by causing more l specific accountabilitv as to what character-j 1stics are inspected on what specific hardware and in some ceses changing " surveillance" to 1l " inspection." i Section D.S.e, Page I-19) (Question 1, Append ix I, !w:e )N idE o
- i. -
l i 4
1
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IISPONSE TO QUESTION 23, PART (4) l l Revision 4 11/79 O
...-___.,,~.-,_,m_ . - ...._...._._,..____._m.__ _ _ - _ _ , ,_ ~ _ , . . _ . . - _ . - _ , . . _ _ , . _ . . . , - , ,- . , _ _ _ , _ . , _ _ . - - - _ _ . . . . .
O RE:SPCNSE TO QUESTICE 23, PARr (4) (50.54(f)] SIX: TIN 1.0, !GC 02:STICN SCPPIRC7IAL ITOLnT EUR AII)ITICNAL SOIIS SEIILEME ?? INEVEML" 21, 1979 letter, l
- 23. We have revised your regi.e to question 110,of1979. ourWeMarch"10 CFR '
supplements in your lettan dated May 31, July 9, and Augustfin review. Aco:rlingly, provide the fo11 ming additional infomaticn: (4) Considering the results of your investigaticn reqasted in our qs.stien ic, questien ld asked that you describe your positicn Your overall as to the overall effectiveness of the QA program for the Midland Plant.sw sMuld be had on y assessment of the effectiveness of your We rmrisai response to our questien Ic (see aleve qm.stien 23(3)). results of this assessment, incitsiing a descripci:n of the scope and extent of the assessment effcet and the identificatice and qualifications of the individuals involved in this assessment, should be e i to us. ( l O 23-91 Revision 4
' 1./79 l
_ , ~ _ _ _ _ _ _ """**M=--
,. . .- -- ._. .. - .. -= -
l l l O g RESPONSE TO OUESTION 23, PART 4 [50.54(f)] SECTION 2.0 ASSESSMENT In providing our assessment of theit effectiveness of the Quality Assurance Program, first should be noted that: a. There are significant differences between soils work and other work;
- b. From the outset of the project, a Quality Assurance Program has been implemented which meets regulatory requirements and national standards; c.
The Quality Assurance Program has been improved significantly from its initial implementation;
- d. Appropriate programmatic and generic corrective actions have been or are being taken as a result of this investigation; e.
The Quality Assurance Program has been subjected to frequent and extensive external evaluations and our responses to the findings from these evaluations have been timely and adequate; and e f. The diesel generator building settlement was detected, at the outset of the settlement, by the Quality Assurance Program. Based on the major points listed above (and on a number of lesser points which are not enumerated here), we are confident that the Quality Assurance Program has been and will continue to be effective. From its complexity and extensiveness, the reader may recognize that literally thousands of hours went into the preparation of the investigative response and assessment. The following organizations and their Bechtel managers participated Quality Assurance, l extensively in this' investigation: Project Engineering, l Ouality Control,and Project Management,CPCo Quality Assurance, Construction; Engineering, and Project Engineering Services; and U.S. Project Management, In addition, there was extensive Testing Quality Assurance. personal participation by the appropriate officers of each company. O Revision 4 23-92 11/79
.~ , _ _ _ _ _ _ . . _ . _ ~ . _ _ _ . _ . _ _ _ _
7 68
~
m) I assurance program via the 50.54 (f) questions that 1 2 are currently being reviewed. 3 0 Now, are the 50.54 (f) questions with 4 regard to QA reviewed by NRR, the answers? 5 A They will be reviewed by both NRR, as well 6 as IE. 7 Q And is there any interfacing between NRR 8 and IE with regard to the review of the 50.54(f) 9 responses? 10 A Yes. We will report to them what our 11 findings are when we review the particular questions 12 regarding quality assurance, and they s'uld inform l i 13 us of their findings of their review as well. l l 14 Q Has IE performed any review to date of the 15 responses to questions 1 and 23 of the 50.54 (f) l l 16 quest. ions? l 17 A .Not that I am aware of. 18 Q Has anyone at NRR, to.,youg,k.nowledge, 19 Performed any review of the responses to questions i 20 1 and,23 of the - 50 : 54 (f) questions? A I believe they are currently.being 21 g reviewed by the quality assurance branch. 1 ((,,) 23 0 Who in the quality assurance branch of NRR 24 is conducting that review,-to your knowledge? l l gm.f.v.4i .D 'Kw
~
b
~
htt *h '"t 7 GVo[ft, Sosen[
E%Mhh- - - . _ _ . f l
.O.-
34
- i 01 1
Q,. The second, corrective actions have not been
'2 sufficiently described so that one would have confidence ,
l l 3 that we would not have poor performance related to the soils ; i- ! !^ 4 area. Is that-correct?
- g l
8, 5 A Correct, and also other areas. g 8 O And finally the description was not provided with t 7 respect to the significance of stated corrective actions - 8 and how it will improve the quality of construction work at ( ' 8 Midland. Is that correct? 10 A Yes.
- 11 Q All right.
I 12 You then went on to state you had a meeting and 13 aninspectionatAnnArbor,IfImightgustuseacollo-14 quialism, you then had a somewhat warmer feeling about the 15 response or the substance of the quality assurance effort 16 at Midland. Is that correct? 17 A That's correct. I'd go so far as to say that I 18 would find it acceptable if the right information was pro-19 vided in Question 23. I see the implementation there, the
# organizational elements, and it just hasn't been properly
]
21 reflected and described in the respons,e. 22 . Q Now you're scheduled to have or to receive further
,,,,.,.. . . . . g- - -+ -* ~ {
[ MM Attachment 8 .
i 1 0 49 1 questions and have them come in with responses. I thought 2 it wise to express my There was also my review at Ann Arbor, 3 and if they saw fit they could update this packet accordingly. 4 I said if they wanted to come in and talk it over 5 with me, draft responses, I will go over in detail, spend e 6 time with them to update this. I think the latter is ruore 7 prudent. 8 Okay. Q 8 A So I haven't detailed a series of questions.
'O It's at this stage right tow.
" Q I see.
I I 12 Can you tell us approximately how long ago you l 13 created these portions of Gilray Deposi$ ion Exhibit 1 that-I guecs they start five pages from the back of the exhibit is and the heading is " Question 23, Part 3." 16 A August and September of 1980.
'I Q All right, sir. ,
' I'd like to call your attention to that page that i
19 starts with " Question 23, Part 3" under Section 2-A, the - to recognition of the differences between soils and other work,
""" ***" """*" *** ** **r":
lO 22 -
" Action: Write letters requesting Al
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o . = : . , w , ca. .:c:n ua:n = u ,u- m.n = ,.: = , , ou aa -- _a. .x -~ . - . . _ I 1 O- 48 5 1 Heller and R. Lipinski to comment on whether suffi- ! 2 cient differences exist between soils and other 3 work." 4 A Right. 5 Q Do you know whether Mr. Lipinski is still a re-6 viewer for Midland? 7 A No. No. These are notes to me. 8 Q I understand that. 9 Did you ever write those letters? 10 A No, I didn't. 11 Q Did you satisfy yourself other than by writing 1 12 the letters, one way or the other, uith respect to the 13 differentiation between soils and the opter work? 14 A No. 15 Q So.that is still an open item as far as you are 16 concerned? Is that right? 17 A Right. 18 I have gotten verbal indicators from the technical l 18 people that indeed there is sufficient unique features to 20 soils work that -- state of the art, for instance, that make 21 that response valid. 22 All right, sir. Q MdMh* Oas-
g g , - -- . - - _ . . . . _ . . . _ O 49 i
- . 1 I take it that these handwrit' ten notes were pre-2 pared by you prior to the time you had your Ann Arbor meeting.
3 A Yes, I suppose so. It must be. l 4 Q And just so we don't have to go through this long 5 Gilray Deposition Exhibit 3, am I correct that the portions 6 of. Gilray Exhibit Number 1.that we've been looking at are 7 in effect your review of the responses to Question 23 and a your comments on them? . 9 A Right. l 10 And in fact these are really a synthesis of your Q
" handwritten notes on Gilray Deposition Exhibit 3. Is that 12 correct?
13 A Yes. y, 14 That doesn't box me in e hope to maybe generate 15 I think my review is essentially 90-additional concerns. 18 some percent complete but, you know, . . . . U What further review effort do you anticipate? Q 18 Let ne say to the witness your answers MR. PATON: 18 are as of today. If you develop information tomorrow that's
# something else.
O. . 2' - WI m ss, my review consises of this If 22 i Midland is going to meet with me, like on the 13th I guess of i O
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5-50 1 March, then I'll go through this again to sharpen my pencil i 2 and make sure that indeed I have done the job right. : l
.3 MR. MILLER: Okay.
4 BY MR. MT m R: 5 Q Do you recall how much time you spent going through 6 that answer to Question 23 at the times that you reviewed it 7 prior to today?
~8 A A couple of weeks.
e Q And didi,fou have before you any of the ANSI 10 standards or Reg. Guides to compare the answers against? . 11 A I have them on my desk. But there is no need to It 12 compare these against the ANSI standards or Reg. Guides. 13 doesn't fit. % 14 Q Why? Because the questions asked or information 15 really go beyond the requirements -of the ANSI standards? 16 A No. The ANSI standards or Reg. Guides are essen-17 tially commitments by the utility to me, and in preparing 18 this they don't have to follow any guidelines that are con-18 tained in those ANSI standards, and there's no criteria that.. .. - 20 I don't know if I'm saying that right. There are 21 no descriptions that I would have to match against the ANSI O. 22 standards.
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'{ 8 ~~* UNeTED STATF.S
[ gig 1f[ *} G, NUCLEAR REGULATORY CoMMisSloN wASnincrou. o. c.2csss [Y*.... JU!i 13 $9 Docket No. 50-329/330 I l MEMORA'0UM FOR: Dudley Thompson, Exe'cutive Officre for Operations Support, IE i FROM: Harold D. Thornburg, Director 4 Division of Reactor Construction Inspection, iE
SUBJECT:
j COMMEhTS ON RIII ENFORCEMENT PACKAGE ON MIOLA!O SETTLEMENT PROBLEMS DATED APRIL 3, 1979 15
*I I We have reviewed the above referenced package which uncer J. Davis's l memorandum of Parch 21, 1979 was forwarded to X005 as the responsible j coordinating group within IE. These corcents are provided to t,a con- . sistent with this memorandum and the follow-up memorandum you provided t
to your enforcement personnel also on March 21, 1979. In sunnary, it is our opinion that four of the five false statements ( identified by the Region will probably be substantiated to be raterial false statements and that they were made in careless disregarc of the facts'. Therefore, it would follow that there woald probably be four instances civil penalty ofofa $5,000 raterial imposed false statement each of which would have a for it. The opinion, a material false statement. fifth item is not, in our
.1
. The enclosure presents our detailed recomendatios.s on this matter. 11 you have questions please ccntact us.
l
/p L8 IMt Et Harold D. Thornburg, Direetcr Division of Reactor Construction Inspection, IE y
h : Enclosu3:" Coments on Midland Enforcement Package. CONTACT: R. E. Shewmaker. IE
.49-27551 ,
I _ wpp7?b2 a-&_a Attachment 10
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- COPF.ENTS ON MIDLAND ENFORCEMENT PACKAGE TRANSMITT FROM KEPPLER, DATED 4/3/79 1.
Appendix a civil penalty.A entitled, " Notice of Violation," and will be th of Civil Penalties" should be prepared.An Appendix B entitled, " Notice of Pr should be addressed in an Appendix C, " Notice of Violation." "The other item 2. identified by amendment number and/or revision number an 3.
,pM is apparently from the original version ofRevision the FSAR.A check of S 1, 11/22/77 .
h,.p4[- has a different statement and is the current version. Some of the other statements referenced have been revised now after the investigation. This must be reexamined. If the statements quoted in the RIII draft can be utilized in an enfortcent action then we judge the statement to be a , raterial false statement. In reaching this c+nclusion we note that there is a need to quote or provide a copy of the text from construction drawings C-45 stating that Zone 2 material is to be used as Class I fiil if the citation is to be properly supported. Y h 4. Statement f2 can probably be classed as a material falsa statement if
. 3o5+kMthe results of the interview with the cognizant engineer and/cr the calcu ,
J lation sheet prove that 3.0 ksf was used in the settlement calculations. t 5. a need Statement to full f3 is viewed to be a 'raterial false statement, but there is W 'Ig calculations. y document what was actually done in the execution of the Again a copy of the calculation sheet and/or a statement 4f the cognizant engineer is needed to properly support the finding. :, 6. H Statement #4 can proaably be classed as a material false statement
'* $ n if the results of the interview and/or the calculations are provided to support the finding.
- 7. .i Stetement f 5 is judged to not be a material false statement. This is due to the fact that the statement quoted is written as a predicted future value for settlement. !
~ -
- 8.
. For those statements which will become raterial false statements with "I a civil pi aalty, remove them from the draft Appendix A and move the remainder *.o the new Appendix C. .
E 9. All statements judged to be material false statements must be examined k to thesee in what " state of mind" or in what circumstances the licensee rade statement.
"second chance."
This is. relevant to the question of " civil penalty" vs. .
.i In our judgment these instances appear to be situations
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of "creless disregard" of the facts which would warrant civil penalty. ? gM._ *
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GLEN E LLYN. 4LLINol$ 60137 h April 3, 1979 MDIORANDDi 70R: Harold D. Thornburg, Director, Division of Reactor Ccnstrue: ion Inspection, IE TKOM: Ja:es G. Keppler, Director SUEJECT: 1 ENIORCEMENT ACTION RE: MIDLAND DIESEL GENERATOR
! BUILDING AND PLANT FILL AREA
- As you are aware, we have sent to Censumers Power Co:pany a report on our two =eetings held with the= and a report of the investigation in:o the causes of the diesel generator building settle:ent. In my ce=or-l andu= to you dated Parch 12, 1979, I st==ari:ed our findings and our concerns resulting fro: this investigation. .
In view of NRR's involve ent in the technical issues in :his case, and ( the need for a deter:ination as to the cateriality of FSAR state:ents we consider to be false, we are not in a position at this ti=e to recon =end specific enforce: cat action which should be taken.
/
Attached to this =ecorandu: are the specific TSAR statements and the l basis for our conclusion that they are false. Also attached are copies j - of our letter dated March 22, 1979, which transmitted.tae Investigatier.
! , repor: to the licensee and a draft Notice of Violation setting forth j the ite=s of nonco:pliance based on the inves:igation' findings. The j draft Notice of Violation includes all of the FSAR discrepancies . ! described in Attachment 1 as exa:ples of nonco=pliance kith Cri:erion l III of 10 CFR 50, Appendix 3. If it is deter =ined that any of these j ratters constitute =aterial false statements, we assu=e they would ,
j then be trea:ed separately, and removed as exa:ples of noncompliance i with this criteria. W C hL ~ [], Y .h k . O
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- F.arold D. Thornburg April 3, 1979 tie recues: that the ite:s of nonco:pliance be given :echnical and legal reviete and that a deter ination be cade of the ta:eriality of FSAS. dis-crepancies so that upon resolution of the technical issues, we will be in a position to cove more promptly tu.iard taking enforce:ent ac:icn.
2 .~....:. .k+ T # Db -
.'/ James G. Keppler Direc:or A::achEn:s:
- 1. FSAR False State:ents
. . 2. Draf: No:1ce of Violatica
- 3. L:r d:d 2/22/79, with Invest:ga:icn Repor:
cc w/at:achments: D. Thompson, IE I l . M e* * . e O
W fidland FSAR Statenents
- 1. Statenen:
Sde: ion 2.5.4.5.3, Fill, states: "All fill and backfill vere placed according to Table 2.5-9." Table 2.5-9, Mini =u: Cc: pac': ion Criteric, centains the fellowing: Co= cacti:n Criteria Zone (1) Soil
" Functio: Designation Type Degree ASTM Desirr.ation Support of Clay 95%
structures ASTM 3155{3j6-(=:dified) (1)For :ene designation see Table 2.5-10. (2)The = ethos was =odified to ge: 20,000 foot-pounds of cc=pae:1ve energy per cubic foot of seil." Section 2.5.4.10.1, Bearing Capaci:y, sta:es: " Table 2. 5-14 shovs
, 'the contact stress beneath foo:ings subjec: :o s:a:ic and s:a:ic plus dyna =ic loadings, the foundation elevation, and :he :ype of supporting mediu= for various plan structures." '
Table 2.5-14, Su==ary of Centact Stresses and U1:i= ate 3 earing Capacity for Mat Foundations Supporting Seis=ic Ca:escry I a:d II Structures, contains, in par:; the following:
" Unit Sueportine Soils Diesel Generator Con: rolled c'e=pacted Building cohesive fill.
Finding , Construc: ion Drawing C-45, Class I fill =aterial areas, specifies the foundation catorial for Class I structures to be Zone 2 na:erial __...which is identified in FSAR Table 2.5-10, Gradation Rang'es for Fill Material, as Rando: Fill and is described as "Any =aterial f:ec of hu=us, organic or other deleterious ca:erial." I: vas ascer:ained that =ater,ials other than " clay" or " controlled co= pac:ed cohesive fill" were used for support of strue:ures. A :ach=en: 1
Midland FSAR Statements . .
- 2. Sta:eren:
Se'ction 2.5.4.10.3.1, Plan: Layou and Loads, sta:es: "The building loads superi= posed by the structures on undisturbed soil or cc: pac:ed fill are given in the soil pressure plan, Figure 2.5-47." Figure 2.5-47, Soil Pressure Diagra: Category I and II scrue:ures, shows the superi: posed load densi:y for the Diesel Genera:or Building to be 4.0 KSF (4000 lbs. per sq. f t.).
,' finding
, , It was ascertained through a review of the se::le en: calculations and an interview of the individual who perforced these calcula: ions that 3.0 KSF was used.
- 3. S:atemen:
See:1on 2.5.4.10.3.3, Soil para e:ers, s:a:es: "The soil co=- .
, pressibility parace:ers used in the settle:ent calculation are presented toge:her wi:h soil profile in Table 2.5-16."
Table 2.5-16, Idealized Soil Profile and Parace ers for Elas:ic
, Half-space Settle =ent and Heave Analysis, contains the folleving:
Averacy Elevation C ' \ *
' c Ideali:ed In:erval Thickness 1+e Layer Soil Type (ft)
(f:) A Fill (CL) 634-609 25 0.003 B Fill (CL) 609-603 6 0.003 NOTE: Final groundwater table is taken at elevation 627.
---'(1) Values were esti:sted fro = the =athe=a:ical rela:ionship between Young's Modulus and Co:pression and rebound indexes and averaged with those obtained from consolidation tes:s. Young's Modulus was esticated fro = e=pirical relationship with shear strength.
( llI
Midland FSAR Staterent . . Finding It was ascertained through a review of the s:ste:en: calculations for the Diesel Generator Building and an interview wi:h the indi-vidual who perfor:ed these calculations :ha: an index of ec press-ibility of 0.001 not 0.003, was used for the eleva:icn in:erval 603-634.
- 4. State =en:
Section 2.5.4.10.3.5, Analysis, states: "For se :leren: cc:pu-tations, a total of 41 settle ent points are established on a grid and at selected structure loca:icns as show: in Figure 2.5-48.
. . . . . To account for possible ti=e-dependen: relationship, :he estimated total settle =ents at each of the 'l points were obtained respectively by adding 257. of the calcula:ed set:lemen: values of
. loading Case A to the calculated ulti ate se: leren values of loading Case 3. These values are presented in Figure 2.5-48."
Section 3.8.4.1.2, Diesel Genera:or Building, sta:es: "The walls are supported by continuous footings with bases at eleva: ion 628'-0". Each diesel generator rests on a 6'-6" chick reinforged concrete pedestal which is not structurally connected to the building founc'acion for purposes of vibra:icn isolation."
'/
Finding
. It was ascertained through a review of :he settle en: calculations for the Diesel Generator Building and an in:erview with :he indi-vidual who perfor:ed these calcula'tions that the data in Figure 2.5-48 regarding the Diesel Generator Building are based on calculations perforced on the erroneous assu=ption that the Diesel Generator Building was constructed on a =at founda: ion.
- 5. Statement
,__ .Section 3.8.5.5, Strue: ural Acceptance Criteria, s:ates.: "Se::le-ments of shallow spread footings founded on cc pacted fills are
. esti=ated to be on the order of 1/2 inch or less. These se::le-
=ents are ssentially elas:1c and occur as the loads are applied."
O
_ l
- 1 1
1
. 1
. Midland FSAR State:en: .
Findine It was ascertained through an in:ervien vi:h :he individual who wro:e this section of :he FSAR that the above statement was :aken frc: the Danes and Moore report submitted as par: of the ?SAR. He assuned :he state =en: vas valid for inclusion in :he FSAR. He said there was no o:her basis to support the s: ate:ent. In this regard the licensee has subsequec.:ly sta:ed :his (NOTE: state =en: ". . . is no: applicable :o the as-buil: confi;;ura:icns and condi: ions of the diesel genera:or building and has been eli - inated from the FSAR in Revision 18.")
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Appendix A NOTICE OF VIOLATION Consusers Power Docket No. 50-329
- Conpany Docket No. 30-330 Based on the results of an NRC investiga: ion conducted on December 11-13, 18-20, 197S, and January 4-5, 9-11, 22-25, 1979, 1:
appears,that certain of your ac:ivities were no: conducted in full 7 co=pliance with NRC requirenen:s as noted below. These 1:e=s are infractions.
- 1. 10 CFR 50, Appendix 3, Criterion III requires, in par:, tha: .
measures shall be established and executed to assure tha: regula-
. tory require =ents and the design basis as specified in :he license
' applica: ion for structures are correctly transla:ed into specifi- ,
cations, drawings, procedures and instructions. Also, i: provides
, that ceasures shall be es:ablished for the iden:ification and control of design interfaces and for coordinates a=ong partici-pating design organizations.
-- - CPCo Topical Report CPC-1-A policy No. 3, Section 3.4 s:a:es, in part, "the assigned lead design group or organi:ation (i.e., the 5555suphlier,ASE,supplierorCPCo)assurethat designs and caterials are s'uitable and that they co= ply vi:h design cri:eria and regulatory requirements."
A::achmen: 2
l em l l 1 (j CPCo is con =itted to A::SI N45.2 (1971), See:icn 1.1, whi:h s:a:es,
'in part, " measures shall be established and docu:ented := assure that the applicable specified design require:en:s, su:h as a design basis, regulatory requirenents . . . are correctly transla:ed into specifi-cations, drawings, procedures, or instructicas."
Con: ary to the above, ceasures did not assure tha: fesign basis were included in drawings and specifications n:: did : hey previde fer the identification and control of design in:erfaces. As a result, several inconsistencies were identified in the license application and in other design basis docu=ents. Specific ext:ples are se: forth below: -
+ a. Construction Drawieg C-45 (Class I fill =a:erial areas)
-' specifies the founda: ion =aterial for Class I struc:ures to ,
be Zone 2 =aterial, defined as any ca:erial free of h :us,
. organic or other deleterious. material with no restric: ions or gradation while FSAR Tables 2.5-9 and 2.5-14, indicate the f:und? tion material for support of Class I structures :o be controlled co=pacted cohesive (clay) caterial.
f . _a!
Appendix A .
- b. The FSAR is internally inconsisten: in : hat FSAR Figure 2.5-48 indicates settlenen: of the Diesel Generato: Building to be
~
on the order of 3" while FSAR Sec: ion 3.S.5.5 (strue: ural acceptance criteria) indica:es set:lenents on shallow spread footings founded on conpacted fill :o be on the order of 1/2" or less. The Diesel Generator Building is suppor:ed by a continuous shallow spread footing.
- c. The ' design se::lenent calculations for the diesel generator and borated v=*s: storage tanks were perforned on :he assenp: ion of uniforn =at founda: ions while these foundations were
(~, designed ani crenstructed as spread foo:ing foundations.
/ '
- d. The settlemen: calculations for the Diesel Generator Building indicate a load intensity of.3000 PSF while the FSAR, Figure 2.5-47, shows a load intensity of 4000 PSF, as actually constructed.
._. - e. The settle =ent calculations for the diesel generator building were based on an index of compressibility of the plant fill bet een elevations 603 and 634 of 0.001. These se::lencat e
W values were shown in FSAR Figure 2.5-45. However, FSA2, Table 2.5-16, indicates an index of cc pressibili:y of :he sa e plan: fill to be 0.003.
- f. PSAR, Amendment 3, indicated tha: if filli.cg and backfilling operations are discon:inued during periods of cold wea:her, all frozen soil vould bc re=oved or reco:pa::ed prior to the resu=p icn of operations. Bech:el specifica: ion C-210 does not specifically include instruction's for removal cf frozen /
thaved co:pacted =aterial upon resu p: ion of work af ter vinter periods. g. ( , PSAR Amend en: 3 indicates that cohesionless soil (sand) would be compacted to S57. relative density according :o ASTM D-2049.
/
. However, Bechtel specification C-210, See:1on 13.7. 2 required
- cohesionless soil to be co:pacted to no: less than 50%
~
relative density. l
- 2. 10 CFR 50, Appendix B, Criterion V requires, in part, : hat activities affecting quality shall be prescribed and acco:plished in accordance with documented instructions, procedures or drawings.
C?Co Topical Report CPC-1-A Policy No. 5 Section 1.0 states, in
. part, that,, " Instructions for controlling and perfor=ing a::ivi:ies affecting quality of equip =en: or opera:1on during design, cens:ruction kj and operations phase of the nuclear power plan: such as pro:urement,
s*~ . ,j Appendix A . .
=anufacturing, construction, installation, inspection, testing
. . . are docu=ented in instruction, procedures, sepcifica: ions
. . . these documents provide qualitative and quan:1:ive acceptance criteria for de:er=ining 1 ptr:an: activities have been sa:isfac:orily acco=plished.
CPCo is co==itted to ANSI 545.2 (1971), Section 6 which s:a:es, in part, " activities af fect!,g quality shall' be prescribed by documen:ed instructions,. procedures, or drawings, of a type appropriate to the circu= stances and shall be accomplished in accordance with these instrue: ions, procedures or drawings."
- a. Contrary to the above, instructions provided to field construction for subs:1:uting lean concre:e for Zone 2 =a:erial did not address the differing founda:1on proper:ies which would result in differential settle:ent of'the Diesel Generator
~
Building.
- b. Also, contrary to the above, certain activites werc not acco:-
plished according to instruction and procedures, in tha:: (1) The co=paction criteria used for fill caterial was 20,000 f t-lbs (Bechtel codified prcctor :est) ra:hcr than a ( . O
e s
's cocpactive energy of 56,000 f:-lbs as specified in 3ech:el Specification C-210, Section 13.7.
(2) Soils activites were not acco:plished under the con:inuous supervision of a qualified soils engineer who would perform in-place density tests in the co:pacted fill :o verify tha: all ra:erials are placed and cerpacted in accordance with specification criteria. This is required
- . by Bech:e1 Specification C-501 as well as ?SAI, A=nend-cent 3 (Da:es and Moore Report, page 16) .
- 3. 10 CFR 50, Appendix 3, criterion X requires, in Par:, that a pro'gra=
for inspection of act. vites af f ecting quali:y shall be es:abli,shed and executed to verify confor:ance with the docu ented ins: uction, proce-
./
dures and drawings for acco:plishing the ac:ivi:y.
- CPCo Topical Repor: CpC-1-A Policy No. 10, Section 3.1, s ta:es , in part, that " work activities are acco=plished according :o approved procedures or instructions which include inspee: ion hold points beyond which work does not proceed until the inspec: ion is conplete or written consent for bypassing the inspec: ion has been received I from the.organica: ion au:hori:cd to perfor: the inspec: ions." i 1
l l
Appendix A . CPCo is co==1::ed to A5SI N45.2 (1971), which s:a:es, in par:,
'!A program for inspection of ac:ivities affecting quality shall be established and executed by or for the organization perf or=ing the activi:y to verify conforcance :o the docu=ented ins:ruc: ions, procedures, and drawings for accc:plishing the ac:ivity."
Con:rary to che abeve, Quality Con:rol Instruction C-1.02 :he progra: for inspection of co=pacted backfill issued on Oc:ober 18, 1976, did not' provide for inspection hold points to verify tha:
, soil work was satisf actorily acconplished according :o docu=en:ed ,
instructions. 10 CFR 50, Appendix E, Criterion XVI requires, in par:, that =easures 3 shall be established to assure that conditions adverse :o quali:y such as failures, deficiencies, defective caterial and nonconfor:ances are pro ptly identified and corrected. In case of significant conditions adverse to quality, =easures shall assure tha: corree:ive action is taken to preclude repetition. CPCo Topical Repor: CPC-1-A Policy No. 16, Section 1.0 states, in part, " corrective action is that action taken to correct and preclude recurrence of significant conditions adverse to the quality of 1: ens
~
or operations. Correc:ive action includes an evaluation of the
e*' .. condi: ions that led to a nonconfor:ance, tha: dispositica cf :he nonconfor=ance and completions of the actions necessary :o prevent or reduce the possibility of recurrence." Contrary to the above, measures did no: assure that soils cc:ditions of adverse quality were pro:p:1y cc:re;:ed :o preclufe repe:1:icn. For example:
~ .
- a. As of January 25,1979, oisture con::al in fill ca:erial had not been established nor adequate direc: ion given :o 1:plement this specification require:ent. The f *.ndit : tha:
the field was no: performing ois:ure con::al .s:s as required by s:ecification C-210 was iden:ified in cuality ,
- Action Reques: SD-40, da:ed July 22, 1977.
*/ .
. b. Cerrective action regarding nonconfor ance repo::s rela:ed to
. plant fill was insufficient or inadequate :o preclude repe:1-tion as evidenced by repeated deviations fro = specification
. requirements. For example, nonconfor:ance reports No. CPCo QF-29, QF-52, QF-68, QF-147, QF-174, QF-172 and QF-199
~~* contain nucerous exa ples of repes:cd nonconfornances . ' the saue areas of plan fill construction.
13 ll ll l I could have attended that meeting or discussion, I r's
> L s
La 2 whatever you want to call the form in which they a i 3 talked about Midland. 1
. 4 0 Ilave you talked with anyone subsequently 5 that attended that meeting as to what occurred at that .I 6 meeting? 'a 7 A No, I did not. .Q 8 Q At the first day mee?ing, what was I & E A' 9 management's position regarding what should be done 10 about the soils issues?
11 A Well, I don't think any definite position 12 had bee- reached. As I said, we talked about options 13 and a strong contender was in order, but the final
. 14 decision had not been reached.
15 Q What was the order they were considering 4 ,, 16 at that time as an option?
. i LD ! 17 A Well, the general characterization of it t i 1
l ta was that work should not proceed until certain l l^ ' 19 technical information was received by the Commission i 20 and evaluated before construction be resumed so that 21 the fix, if you will, of the soils problem was at l
- least acceptable by the Commission before construction l
l . n be resumed, soil construction be resumed. l
-s 24 MR. JONES: Off the record.
l l (m-) 1 1 g Vmm 't mllb l 0 Vo[ft, hosenbzQ _ ( dicago, Bilinoh Attachment 11 l
14 ) 1 (WIIE REU PON , discussion was had off the l (, ') L/ 2 record.)
! 3 MR. FARNELL: Would you read back the last 4 question.
5 (WIIE REU PON , the record was read by the
- . 6 reporter as requerted.)
~
7 BY MR. FARNELL: i a Q Do you recall Darl Hood stating at that
- 9 meeting that the proposed fixes are such that if i
10 they are implemented properly, they should be
' adequate?
11 12 A No, I don't recall that. 13 MR. FARNELL: Can you read that question back. i 14 (WHEREUPON, the recoro was read by the 15 . reporter as requested.) 16 BY MR. FARNELL: 17 Q Do you recall Darl llood stating anything l
. is about the proposed fixes and their adequacy?
19 a I honestly can't remember any comments that 2o he made with respect to the fixes. I just don't 21 recall.
.. 22 Q I now show you a document that has been 23 marked as Shewmaker Deposition Exhibit No. 13. It is
() 24 a set of notes, a two-page set of notes in f a~- om-,. . ,s,.~s,
15
, ,\
1 Mr. Shewmaker's handwriting dated 11/28/79. (G 2 I ask you if you have ever seen this 3 document previously?
. 4 (UIIE REU PON , the document was tandered 5 to the witness.)
6 BY THE WITNESS:
. 7 A No, I don't recall seeing that.
8 BY MR. FARNELL: 9 0 Could you read this document over, and 10 particularly the sentence with Mr. Hood's name prior 11 to it, and see if that refreshes your recollection.
- 12 You can also read the entire document.
i; 13 A I am sorry. Did you ask me a question? 14 0 I asked you if this document refreshes your is recollection concerning what Mr. Hood stated at the
.; 16 meeting?
,n 17 A No, it does not. i i-; la O Do these notes generally comport with your
- s. 19 :'ecollection of the meeting, what was said at the 20 meeting?
21 A I guess, without acknowledging specific n statements. You know, as I indicated, we talked n about performance, QA, soils, enforcement options, (J,
^'t 24 that sort of thing, and I would say they address
_MW -- n,_ an-,. . , . . . ~ ,
~
16 I i 1
,x 1 those general topics.
N] \ l 2 O Does this comport with the general 1 3 uubstance of what you recall being said at the 4 meeting? I l 3 A I guess I would say yes. My memory isn't 6 all that great. They do address the topics that we I i 7 talked about. Without recognizirg specific statements
'l l 8 that were made, they reflect tha general conversation 9 or the communications during that meeting.
I 10 0 You indicated that there was a discussion l 11 there that work should not proceed until certain 12 technical information is received and evaluated? 13 A Yes. 14 0 Do you recall what technical information
; 15 was felt had to be received?
i 16 A Not in a specific sense, but the intent 17 was that the corrected actions in terms of the
, 33 engineering that had to be done should be obtained 19 from the licensee so that the technical evaluation n could be made as to whether that would meet the 21 various design criteria. Because the problem was e a substantial problem, there was the thought that n if Consumer Power proceeded with the corrective
( }) 24 action and the corrective action was not proper and (1Mfa, &mGeg and c41soaates n,- . . .,- . . , . ~ ,
17 b gs I acceptable by the NRC, we would be faced with a (-) 2 r.ituation that would be difficult to deal with at 3 the end point. , t What were the engineering changes? What 5 were the design changes? What were the basis for 6 them? Would they withstand the scismic forces? 7 What were these matters so that the NRC could evaluate 8 them? In that context, the discussion with respect 9 to the order was held, and that would prevent the 10 continued construction work in the soils area. 11 Q You just mentioned seismic forces. Could 12 you tell me what discussion was held regarding 13 seismic forces? . 14 A No. I am not a -- I am not qualified to 15 talk about seismic matters as an expert. There are 16 certain design criteria that address the ability i
. 17 of structures to withstand certain seismic forces.
I 18 If the FSAR, in fact, described the property of the 19 soil or design of a foundation and that design was m substantially changed, what did that mean in terms of
. 21 the s ti: c.c t u r e ' s ability to sustain the seismic n forces required by the criteria?
3 I don't want to get out of my area. This I"'I
%j 24 is a NRR concern and NRR consideration. We, in the O E, OSE!! E Q SSOCb2bES n,_ a,-,. . . ~ ,
18
,. g 1 field, do not deal with those technical matters, but V I am trying to give you the flavor of the discusJion 2 / 3 that occurred at that time.
4 0 Was the discussion on the seismic forces 5 concerning the seismic criteria set forth in the
. 6 FSAR?
i 7 A I can't answer that question. I am not 8 knowledgeable enough to know where the criteria are 9 established. That is something that you will want to 10 ask the experts, so-called experts in NRR about that. 11 I cannot comment on your question. I am just trying 12 to give you the general concern as I understood the 13 situation. , 14 0 Did anyone at that meeting indicate that 15 seismic criteria should be higher or more rigid than 16 that set forth in the FSAR?
,g 17 A I don't recall that. I mean, it may have,
;; 18 but I don't recall any statements to that effect.
19 0 At the time of this meeting, were you aware i 20 that the NRC had issued 50.54(f) information requests 21 to ConJumers Power? n A Yes. n Q Was anything said at that meeting regarding () 24 those requests? l G Vo[fe, cRosenbey and 811ocialz1 0$leaac, $((inois e 7Sz-FOS 7
19 1 A I am sure something was said. I am trying , [m..h ;
\s ,
2 to recall the context of the discussion. I think i f 3 questions were asked with respect to fol, low-up of 4 the information in the 50.54 (f) correspondence. 5 I think with respect to I & E, I am trying to recall 6 now, the discussion had to do with Consumers Power's 7 implementation of the information they had in the a 50.54(f). Beyond that, I have difficulty recalling, 9 but I feel quite sure that subject was talked about. 10 0 During that meeting, did anyone discuss
. 11 the term " acceptance criteria"? -
12 A I don't recall. I 13 Q Have you heard of the term " acceptance 14 criteria"? 15 A Yes. 16 -Q Can you tell me what your understanding
~. 17 is with regard to that term?
, 18 A In what context? 19 Q In regard to the soils settlement matters? M A I can't comment on the acceptance criteria 21 with respect to the soils because I don't know what 5 it is. I have heard of the term used in the general u quality assurance / quality control field; criteria ({') 24 that defines the acceptability of design or the 0Vo[fe, dosenbey and 81sociales CRi=aao. Olli,wis e ,sz-sos ,
20 I acceptability of a system to function, criteria that (_),' b ; 2 defines the acceptability of a product quality in 3 that general sense. I can't comment on it with 4 respect to soils. I don't know. 5 Q During this meeting, it was brought to 6 your attention that the NRC had retained outside L 7 consultants to look into the soils problem? 3 A That the NRC had retained consultants? 9 Q Specifically the Corps of Engineers, ETEC?
. 10 A I heard that, but I can't recall whether 11 it was in the meeting I heard it or subsequent to it 12 I heard it. I just don't recall if it was in the 13 meeting where I heard it.
14 Q Did anyone during that meeting make the 15 observation that the NRC had not been able yet to 16 review all the information that Consumers Power had
'. 17 submitted pursuant to 50.54(f) requests?
l : la A I don't recall whether that was made in i 19 the meeting or in subsequent discussions. I know 2 that I & E had not pursued the follow-up of the 21 information in the 5 0.54 ( f) , information for which
. n i. t had responsibility for follow-up, namely the l . n QA stuff, the information of .he QA. This was 1
{} 2 because basically there wasn't much soils were going 0 Vo[fe, Sosenbetg and 811ociales Giease. D(finais e ,sr. sos,
21
'9 l
en 1 on and also because I think our assessment was that b ' 2 there wasn't a heck of a lot of it, namely because 3 I think our assessment at the time was that 4 Consumers Power hadn't put into effect the
i 5 implementation of the information they had in the 6 50.54 (f) .
~
7 So in that sense, I think the question you 8 raise was whether the NRC had an opportunity to
- 9 review the information in the 5 0. 54 (f) communication.
10 I am not sure whether you understand what I said. 11 I sort of rantbled on there. We, speaking for I & E, 12 had a chance to confirm the implementation of the 4 13 information in the 50.54 (f) letter that dealt with 14 the matters thtt I & E normally would follow up on. 15 I can't speak to NRR. 16 .Q Is that I & E Region 3 or I & E headquarters ? 17 A That would be I & E -- it would be both, d 18 but the lead would rest with I & E Region 3. l 19 MR. JONES: Off the record -- can we take a m five-minute break? l 21 MR. ZAHARIN: Can we ask one question that
- n follows that beforehand?
23 BY MR. FARNELL: O Apart from QA impicmentation, had anyone [v) 24 l 0Vo[fe, Sosenbey and 81sociales Mi~,~, din..,s. . ,x,.sas,
22 [ 1 j I within I & E, to your knowledge, made a review of s ('.sN.s) j e 2 the concepts, QA concepts, that Consumers Power had l 3 set forth in its response to 50. 54 (f) qu.estions? i
! 4 A Well, yes. When you talk about concepts, l 5 I am not sure what you mean, but we had reviewed the s
l 6 50.54(f) information,specifically Gene Gallagher, as
] 7 I recall, and he had provided some input to NRR with 8 respect to the comprehensiveness of the information.
9 Obviously NRR reviewed the QA portion of it, and 10 I believe that's what led to requesting Consumers l 11 Power to provide additional information on quality 12 assurance matters. 13 I don't know if I have answered your 14 question or not. 15 Q Do you recall what Gene Gallagher's input 16 to NRR was?
, t 17 A No, I don't'. I am sure he had telephone 18 conversations with people back there. He may have 19 even had some, and I am talking now -- and I suppose M he even had some questions with respect to the 21 technical mattcrs, the technical response that he n forwarded back to NRR. The nature of them, I don't n know.
l'T x/ 24 Q Had Gene Gallagher or anyone else at I & E G Vo[fe, cRosenbey and 811ociales Guaao. Dllinou o ,suscs,
d 4 32 p'O l 1 staff as well as for Consumers Power Company -- is that 2 right -- the issuance of the order? 3 A- I didn't set out to put pressure on the staff, or 4 I don't think we set out to put pressure on the staff 5 necessarily but we did want the whole issue resolved. 6 Q Okay. Let's go on. 7 The next day tnere was a meeting at noontime, 8 Mr. Stello, Mr. Case, and some others. Were you present at 9 that meeting? 10 A Yes, and Mr. Keppler was also. 11' Q And what was the purpose of now including Mr. Case 12 in the meeting? 13 A Well, as I remember, this was a jointly signed 14 order. 15 Yes, sir. Q 16 A And you have to start discussing the matter with 17 the other party at some point. We had all along, but I'm not 13 sure it had been elevated to that level previously. 19 Q Now do you recall Mr. Ilood or Mr. Rubenstein, 20 who was also at that meeting, stating that that applicant -- 21 one approach, one possible approach could be that the appli-22 cant could proceed with the remedial work on the understanding p), y
$ceSlcral $porim, Sne.
g u ,~ .
. . _. - g Attachment 12
i ,
,~~., 33
() 53 0 1 that it was strictly at its own risk? 2 A I don ' t think that that is-- That's no different 3 than the situation that evolved when the order was issued. 4 Q Yes, sir. 5 But my question was do you recall Mr. Hood and 6 Mr. Rubenstein-- 7 A I recall someone making that statement. It may 8 well have been one of those. 9 Q Do you recall what th, response was to that comment 10 from ar.yone else in the meeting? 11 A No, I don't. I recall that the statement was 12 made. 13 O And at that point in time of course was it the 14 position of the I&E Branch that a suspension order should be 15 issued? 16 A It was our position that the order that was -- you 17 know, essentially the order that was issued should be issued. IU Q All right. 19 Did Mr. Case disagree with that in any way? 20 A I don't believe so. We talked-- As I remember, 21 we talked several options but he ultimately agreed to do it. 22 Q Right. Ha signed it. (D xs'
$ccSl.~ral $ porters, $c.
-- s - . + , - - w w- w + , m -e-*---y-- - - - e- y e-
i i 7- 34 i (3 / 1 1 A And he signed the thing. And you don't push
-2 Mr. Case around; at least I've never been able to.
2 O Well, what I'm trying to determine, Mr. Thornburg, 0 4 is whether or not anyone expressed the opinion t6at the : 5 escalated enforcement action represented by the December 6th, 6 1979 order was not appropriate or not necessary.
, 7 A I honestly don't remember anyone saying that. I 8 So as far as you know, everybody was together, Q
8 both at the meeting on November 28th with Mr. Stello, and 10 the meeting on November 29th with Mr. Case, with respect to , I 11 the advisability of issuing this escalated enforcement action t 12 represented by the December 6th order? l'f I 13 A Well, I didn't hear anybody make, you know, a - 14 significant disagreement that sticks in my mind. I haven't 15 gone back and talked to the parties or anything else. 16 O Now on your log sheet which is Shewmaker Deposition II Exhibit 17 you show December 5th-- Well, let's just carry on with it. l 19 ' ,l Item number nine on that is a November 29th 20 meeting with Mr. Lieberman. Mr. Lieberman is an attorney, 21 is he not? 22 A Yes, with Enforcement. p V heebderal $ porters, Sne.
;i
(~) 35 \~J 1 Q And was that to discuss the mechanics of preparing 2 the order? 3 A Yes. 4 Q Was he given the assignment to draft up the order 5 and circulate it? ; 6 A Well, I think my staff had worked with lawyers 7 ! to draft the thing up, and Jim and I were going over scme of j 8 i the -- cleaning the thing up and doing the final writing, " 9 nearly the final writing. 10 I see that we were still working on it the 5th and , 11 6th of December. 12 Q Is that what the meetings on December 5th and 10 December 6th involved? 14 A Basically finishing the order. And you see we 15 met with Mr. Ingraham on the 5th. I think we wrote the press 16 release and-- 17 O Mr. Ingraham is in the Public Information Office? 5 IU I A Yes. 19 And I think on the 6th I got the signature of -- 20 the Licensing signature and the lawyers' concurrence. 21 Q At the meeting on December 5th, was there anyone 22
.who expressed any opinion that perhaps the order ought not be (v
GLEL.ILLp,,, 67,,c.
l a r 22
}3
- f. N ,
held in 197- -- was it or '5? f l .
'4
{'>) + , I - fl 0 I think it is '4. ~
. q i i i j' 1 3 MR. PATON: The decision was '4.
- I 1 t 1 s TY TIIE WITNESS:
ff " I 3 A. (Continuine) -- there were two k) t: o considerations that were involved in that hearing. fk - The first consideration was whether or not the 4 LU 6 q' i 4 s licensee had taken sufficient action to achieve I q" l 4
} p; 9 compliance with respect to specific problems that l'
it i I to had been identified by the NRC. And the second issue, which was a much ff 11 eI broader issue, was whether there was reasonable 12
, 13 assurance that the quality assurance program would r
} 14 be effective in the future to assure compliance 4
f.:l . 15 with applicable requirements. I 16 At that hearing the staff concluded 1- positive answers to both cases, but I left a 18 message to the IIcaring Bonrd that if I felt the 19 quality assurance program was inadequate in the 20 future, I would not hesitate to shut down the 21 project. n Now, subsequent to that hearing there n were a number of problems associated with the
/
(O> 24 Midland project that had, to varying degrees, gn , s , .. .u.
. m m qy,[ gg Attachment 13
@, . " ;'U ; fv. tt 5 ic. /
iv k d f (f tcu5 ) UNITEO STATES l [gaa mICg% p y~ *$ NUCLEAR REGULATORY COMMISSION \j , j WASHINGTON. D. C. 20556 { s . JAN 121979
%,.....,f DOCKET NOS. 50-329 50-330 Consumers Power Company APPLICANT:
FACILITY: Midland Plant, Units 1 & 2
SUMMARY
OF DECEMBER 4,1978 MEETING ON. STRUCTURAL
SUBJECT:
SETTLEPINTS On December 4, 1978, the NRC staff met in Midland, Michigan with Consumers Power Company (CPC0), Bechtel Associates, and consultants in geotechnical engineering to discuss excessive settlement of the Diesel Generator (DG) Building and pedestals, and settlement of other seismic Category I structures. These technical discussions followed a site tour on December 3, 1978 during which the NRC st each of these structures. Enclosure 2 is the agenda used
.- cussions are listed in Enclosure 1.
during the technical discussion.
- 1. Backaround_
Pursuant to 10 CFR 50.55(e), CPC0 notified Region III of the f Office of Inspection and Enforcement (I&E) on pedestals was greater than expected and tha An interim status report was provided 1&E by the problem. CPC0's letter of September 29, 1978. I&E conducted inspections on this matter on October 24-27,1978 and issued inspection report number 50-329/78-12; 50-330/78-12. History
,2.
The Bechtel representative identified the Category I structures and the type of material supporting the structure:
- a. Containment - Glacial Till
)
s
- b. Borate,d Water Storage Tank - Plant Fill Diesel Generator Building and Pedestal - Plant Fill
,;. c.
- 4. Auxiliary Building - Part Glacial Till & Part Plant Fill htiononly)
- e. Service Water Intake - Glacial Till (Completed- Plant Fill (Sm bq constructed)
~
p yP a- * *******'* M na
]ql).L9.6h _
Attachment 14
0
)
O V JAN 121979 (
)
d The settlement monitoring program began in June 1978; to date the measured settlements are as follows: Containment - 1/4" to 5/8" over last 1-1/2 years
- Auxiliary Building - Approximately 1/8" (central portion)
Service Water Pump House - O to 1/8" Diesel Generator Building - 3 to 4" since footing was poured October 1977 and walls in Spring 1978. The four electrical duct banks rising into the DG Building, and which extend downward into the glacial till, were cut loose to remove the settlement restriction on the north side of the DG Building. When the duct banks were cut loose, settlement on the order of 2" occurred on the north side of th? DG Building at a rapid rate. The east wall exhibited rapid settlement (1/8" in
. one week), but the west wall showed very little subsequent settle-ment. This indicates that the east wall was being held up by the duct pedestal.
3.. Soils Exploration s Bechtel discussed the soil exploration program, including the
/ boring program and laboratory testing of the foundation materials.
The conclusion that was made by Bechtel is that the material varies across the site in strength properties, i.e., unconfined compressive strength from 200 PSF to 4000 PSF and shear strength from 100 PSF to 2000 PSF. The soils classification ranged from Cl to M1. Bechtel also discussed possible causes based on input from a con-l sultant, Dr. R. Peck. Some of these causes were: j (1) Variable quality of material used in the plant fill, however, the quality control records do not indicate the variation.
.-(2) Fill may have been placed on the dry side of optimum moisture, and then when the water table rose inundating the fill, the material may have become " soft."
I (3) InitiaI' fill may have been placed satisfactorily but after 4 installing pipe trenches and duct banks, the fill may have l . been disturbed. l 3 ' . j l lO . I
.- .l . - --_.. ._, _ _ . . _ _ _ _ _ _ _ _ _ _ , . _ , _ ___ __ _
l 2 a
.. .. - . .- . . . 1 JAN 121979 nv ,
- 4. Consultants Perspective Dr. R. B. Peck stated the following:
- a. The compacted fill is comprised mainly of glacial till and was excavated from the cooling pond area.
- b. Evidence exists from the Dutch cone curve that the looser and i
softer areas are limited to local zones or lenses.
- c. Water content is higher than at the time the fill was placed.
Settlement of the till has been occurring since original placement of fill, accelerated by increased moisture content resulting from filling of the discharge cooling pond. Soil settlement is occurring under its own weight and the added weight of the building is believed to be insignificant.
- d. The DG Building would probably not have settled as much if the material had not been so wet (moisture content is high).
- e. Bearing capacity is not a p'.oblem for the footings.
- f. Short of removing all the fill above the hard glacial till, a "preload" program would be the best approach. The preload purpose would be to consolidate the fill materials.
- g. The settlement with the preload would tend to be rapid (a few weeks to a few months),
- h. The preload is a necessary first step even though other measures might be necessary.
- 1. The main unknown is what might happen to the rate of settlement as the water table rises and saturates the fill, J. Preloading would occur in early 1979 and the sand used as the surcharge would be removed in mid-1979 Mr. C. J. Dunnicliff of Goldberg, Zoino, Dunnicliff & Associates described the instrumentation program to monitor the settlement c.f the foundation material and structures during the preload, The purpose of the instrumentation is to determine if the surcharge is doing its job of consolidation and if it is causing any harm to the structurps or utility lines under and around the building, L .
g O
- i (v '; JAN 121979
- a. Instrumentation for the structure will include optical survey measurements as well as monitoring af cracks using electrical devices. Foar locations for the electrical devices have been chosen; two on the exterior of the east wall of the DG Building i and two on tne west wall of bay number four in the DG Building.
A mapping of cracks will be developed.
- b. Foundation monitoring will include devices to measure settlement and pore water pressure. A total of 60 anchors will be installed (20 groups of 3 at different' elevations). A total of 40 piezameters are to be installed to measure the pore water pressure.
The consultants indicated that 6" settlement would not be a surprise and that up to as much as 18" could occur. The preload will be made up of 15 to 20 feet of sand piled in and around the DG Building. No more than a 5-foot differential in the sand level between bays would be pemitted. The NRC questioned the effect of settlement and preloading on the condensate lines located under the DG Building. Fixed points for the piping, such as the Turbine Building wall, are also of interest for the potential of cantilever effects. Bechtel explained s that the 20-inch condensate lines are encased in 24-inch lines surrounded by concrete and resting in well compacted sand. I Instrumentation will be included to monitor the condensate lines. The possibility of cutting the lines loose at the DG Building and the Turbine Building is also being studied. The condensate lines have no safety-related function for the Midland design. The NRC also expressed concern for the effect of settlement on the fuel oil lines under the building. CPC0 stated that re-routing l of lines can be readily accommodated if necessary. This matter is j also under review. The NRC Resident Inspector asked for a list of the equipment, with a discussion of the compacting capability and limitations of each, urett for compacting the fill for the DG Building from elevation
- 618 to 628 feet. Bechtel will provide this information, l
- 5. Program Status Bechtel sumarized the activities completed, in progress, and k planned for the future:
, C)v
JAN 121979
- a. Activities Comoleted (1) Boring program (2) Isolation of the electrical duct banks on the north side i
of the DG Building
- b. Activities in Proaress (or soon to be initiated)
(1) Foundation settlement monitoring program (2) Preload instrumentation program (3) Actual preload of the structure and foundation (4) Filling the cooling pond to maximum elevation (Elevation 627) (5) Complete construction of the rest of the DG Building
. structure
- c. Activities Planned
\
./ (1) After removal of the surcharge, assure contact between footings and soil foundation material (2) Verify utilities and structure integrity
- 6. Project Schedule Bechtel presented the following project schedule information:
l l
. Construction is 58% sompleted as of November 1978 Engineering is 80% complete Structural concrete is 97% complete l
l Fuel load tarcet date is November 1980 l " Earliest regulrement for one diesel generator is January 1980
- Current completion date for one diesel generator is January 1980 Latest date for one diesel generator is June 1980
- S a .
1 E . n o
JAN 121979 ts V - f Bechtel emphasized that the installed instrumentation will show when the preload surcharge may be removed and therefore the present schedule is somewhat tentative. Most settlement is predicted to occur rapidly as the area is being preloaded and frequent readings I will be taken during this period and used as a basis for further ' projections. The rate of settlement will decrease thereafter i and the total settlement is expected to be reached within a few months. - CPC0 stated that if necessary, temporary diesels could be used during preoperational testing prior to fuel loading and that this matter is presently under study,
- 7. Resconse to Open Items in NRC Insoection Report Bechtel addressed the open items included in NRC inspection report Nos. 50-329/78-12 and 50-330/78-12. CPC0 stated that a written response would be sent to I&E Region III to resolve the conflict between the FSAR and site implementing procedures:
- a. Conflict between FSAR Table 2.5-14 and Table 2.5-10 regarding the description of fill material and what was actually used in the random fill: Bechtel stated that this conflict was an oversight and that an FSAR amendment would be issued.
. The NRC staff stated that any such amendment should address both the previous and the adjusted entries such that the
, /' basis for the previous staff review is not obscured in the documentation.
- b. Conflict between FSAR Table 2.5-21 and Bechtel Specification C-210 regarding number of passes for compaction: Bechtel stated that FSAR Table 2.5-21 is for the embankments for the cooling pond dikes.
- c. FSAR Section 3.8.5.5 regarding expected settlement: Bechtel stated that 1/2-inch indicated in the FSAR was a mistake and that the FSAR would be amended to correct this mistake.
d Conflict between FSAR Figure 2.5-47 and project drawing
~
regarding foundation elevation: Bechtel stated the elevations in the FSAR was also a mistake and would be corrected. I -
- e. Conflict ib Bechtel Specification C-210 regarding compactive I effort: Bechtel stated that Field Change Request C-302
{a dated 10/31/75 clarified this conflict and permitted the
."Bechtel Mod,ified Protector" using 20,000 ft-lbs comgactive effortratherthantheASTMstandardof56,000ft-Ig O
V
-n g
--~
_ _ , , a- ----,cg -- m- --- ,,---,-.--mw-,- - . - - - ,--,--->~m -,- ---
2 . .... -- M 121979 gy f f-g f. Conflict between Dames & Moore recomendation regarding lift p(g thickness of 6 to 8 inches and the Bechtel specification permitting
, up to 12 inches: Bechtel stated that the greater depth per-f mitted by their specification should not matter because of
.4 perfomance qualification tests. However, the NRC was then informed that the test qtlifications performed were for Zone 1 I clay only, and that no test qualifications on the random fill
} material using 12 inches was perfomed to qualify such lift thicknesses. Dr. Peck stated that the thicker the layer, the more differences in compaction through the thickness of
- l the layer would occur.
- g. Tolerance of t 2% in moisture content permitted in Bechtel Specification C-210: Bechtel stated that this tolerance is in line with industry practice.
Dr. Peck was asked his view on this t 2% tolerance. He stated that the important question is "t 2% of what material." Since the material used in the fill was variable, the t 2%
. tolerance could cause a problem if the material is not consistent.
- h. Cracks in the building structure: Bechtel stated that all cracks greater than the ACI 318-71 limit would be identified and repaired after the preload program.
J. FSAR question 362.2: Bechtel stated that the answer had been sent to NRr. via FSAR revision 15 in November 1978. CPC0 stated that the reply to the inspection report is in process.
- and that,the reply will include copies of all data, slides, and drawings presented during this meeting.
1 In concluding remarks,.CPC0 stated its intent to proceed with the preloading program as described during the meeting. l In its closing coments, the NRC staff stated that the proposed solu-l tion is at the risk of the applicant and that NRC intends to review and evaluate this matter in accordance with the original compaction requirements as set forth in the commitments in the PSAR. The staff
. also stated that while attention to remedial action is important, determination of the exact cc ne is also quite important for verifying the adequacy of tfie remedial action, assessing the extent of the matter I relative to other structures, and .in precluding repetition of such matters in the future.
psalw c> g
~
Darl Hood, Project 2 tanager q light Water Reactors Branch 4 l O Division of Project Management l
Enclosures:
As stated ,
- y. . . - , - - , , _ ,-
tonsumers Power Company EAII 121979 [' ccs: Michael I. Miller, Esq. Isham, Lincoln & Beale Suite 4200 One First National Plaza Chicago, Illinois 60670 Judd L. Bacon, Esq. Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Mr. Paul A. Perry Secretary Consumers Power Company 212 W. Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esq. Une IBM Plaza Chicago, Illinois 60611 Mary Sinclair 5711 Summerset Orive Midland, Michigan 48640 Frank,J. Kelley, Esq. Attorney General State of Mi:higan Environmental Protection Division 720 Law Building I Lansing, Michigan 48913 1 Mr. Windell Marshall ! Route 10 - ! Midland, Michigan 48640 l . Mr. S. H. Howell Vice President ConsdEer's Power Company
- 212 West Michigan Avenue '
Jackson, Michigan 49201 t. hL w l cJ . l l l l
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'..i' . .. .. 'U 3 ENCLOSURE 1 JAN 121979 , r ATTENDEES DECEMBER 4, 1978 MEETING P. A. Martinez, Bechtel Karl Wiedner, Bechtel
- S. S. Afifi, Bechtel R. B. Peck, Bechtel Consultant
- W. R. Ferris, Bechtel 3
M. O. Rothwell, Bechtel
- D. B. Miller, CPC0 - Project
- J. P. Betts, Bechtel W. L. Barclay, Bechtel
- A. J. Boos, Bechtel G. L. Richardson, Bechtel
- D. E. Horn, CPC0 - QA W. R. Bird, CPC0-QA
- R. M. Wheeler, CPC0 - PM0
- C. A. Hunt, CPC0 - Engineering Services D. E. Sibbald, CPC0 Project John Dunnicliff, Bechtel Consultant
- Austin Marshall, Bechtel - Geotech
*'Y , K. Lin, Bechtel - Geotech
- B. C. McConnel, Gechtel - Geotech
- B. Dhar, Bechtel
- N. Swanberg, Bechtel
- Darl Hood, NRC LPM
- Gene Gallagher, NRC Region III (I&E)
- Daniel Gillen, NRC/NRC Geosciences
- Lyman Hiller, NRC/NRR Geosciences
- Ronald Cook, NRC Resident Inspector
*Present during both the 12/3/78 site tour ar.d the 12/4/78 meeting.
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SUBJECT:
CPCo Midland Plant Units 1 & 2
-l Diesel Generator Building 9,' jag 1 3 )g7g i
, Meeting with NRC at Midland y
a, - DATE: December 4, 1978 h AGENDA . I. , Introduction by CPCo II. History by Bechtel (N. Swanberg)
- a. Plant description
- b. Settlement monitoring program
- c. Brief history of site fill placement
- d. Settlement of Category 1 structure
- e. Settlement of diesel generator building and pedestals
- f. Review settlement data and drawings (SK-C-620/623)
.g . Consultants III. Soil Exploration by Bechtel (S. Afifi)
, a. Soil borings L. Dutch cone penetrations
- c. Laboratory tests
- d. Possible causes IV. Consultant's Recommendation by Dr. R.B. Peck and
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C.J. Dunnicliff
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! a. ,Preload
- b. Instrumentation V. Status report by Bechtel (B.C. h-Connell)
- a. Activities completed
- b. Activities in progress
- c. Activitics planned for future
- 1) Corrective action
- 2) FSAR conformance VI. - - - -
Schedule by Ecchtel (P. Martinez)
- a. Overall project j y b. Impact on project schedule L c. Schedulu for remedial measures l
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. (' A VII. Responses to open items in NRC Inspector's report b) [ dated 11/17/78 by Bechtel (B. Dhar) JM 121979
- a. . Responses to Callaghar'r concerns:
- 1) Conflict between FSAR Table 2.5-14 and
. Table 2.5-10 regarding fil) material description
- 2) Conflict betueen FSAR Table 2.5-21 and Specification C-210 regarding required number of passes for compaction
- 3) ISAR Section 3.8.5.5 - expected settlement
- 4) Conflict between FSAR Figure 2.5-47 and
, project drawing regarding foundation elevation
- 5) Conflict in Specification C-210 regarding compactive effort in test method
- 6) Conflict between consultant's recommendation and Specification C-210 regarding lift thickness
- 7) + 2% tolerance in moisture content permitted
.in Specification C-210
- 8) Cracks in the building structure
- b. FSAR Question 362.2 (Section 2.5.4.5.1)
VIII. Closing Comments by CPCo ( .
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