ML20082G497

Midland Summary Rept

ML20082G497
Person / Time
Site:	Midland
Issue date:	09/20/1983
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML20082G480	List: ML20082G497
References
FOIA-83-452 NUDOCS 8311300224
Download: ML20082G497 (14)

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SUMMARY

REPORT Facility Data Docket Numbers 329 and 50-330 Construction Permits - CPPR-81 and CPPR-82 Permits Issued - December 14, 1972 Type Reactor - PWR; Unit 1, 492 MWe*; Unit 2, 818 MWe NSSS Supplier - Babcox & Wilcox Design / Constructor - Bechtel Power Corporation Fuel Load Dates - Unit 1, 11/81; Unit 2, 11/80 Status of Construction - Unit 1, 52%, Unit 2, 56%; Engineering 80%

• Approximately one-half the steam production for Unit 1 is dedicated, by contract, to be supplied to Dow Chemical Corporation, through appropriate isolation heat exchangers. Capability exists to alternate to Unit 2 for the steam source upon demand.

Chronological Listing of Major Events July 1970 Start of Construction under exemption 9/29-30 & Site inspection, four items of noncompliance identified, 10/1/70 extensive review during CP hearings 1971 - 1972 Plant in mothballs pending CP 12/14/72 CP issued 9/73 Inspection at Bechtel Ann Arbor offices, five items of noncompliance identified 11/73 Inspection at site, four items of noncompliance identified (cadweld problem) precipitated the Show Cause Order

., 12/29/73 Licensee answers Show Cause Order commits to improvements g on QA program and QA/QC staff 1 12/3/73 Show Cause Order issued suspending cadwelding operation 12/6-7/73 Special inspection conducted by RIII & HQ personnel a

12/17/73 ~ Show Cause order modified to allow cadwelding based on inspection findings of 12/6-7/73 khdIfop224830920 CARDEB3-452 I pyg }

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I 12/5/75 CP reported that rebar spacing out of specification 50 locations in Unit 2 containment .

3/5 & 10/75 CP reported that 63 #6 rebar were either missing or misplaced in Auxiliary Building 3/12/75 RIII held management meeting with CP p.- *.

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8/21/75 CP reported that 42 sets of #6 tie bars were missing in Auxiliary Building -

3/22/76 CP reported that 32 #8 rebar were omitted in Auxiliary Bui. ding. A stop-work order was issued by CP 3/26/76 RIII inspector requested CP to inform RIII when stop-work order to be lifted and to investigate the cause and the extent of the problem. Additional rebar problems identified during site inspection 3/31/76 CP lifted the stop-work order 4/19 thru RIII performed in-depth QA inspection at Fddland -

5/14/76 5/14/76 RIII management discussed inspection findings with site personnel 5/20/76 RIII management meeting with CP President, Vice President, and others.

6/7 & 8/76 RIII follow up meeting with CP management and discussed the CP 21 correction commitments 6/1-7/1/76 Overall rebar omission reviewed by R. E. Shewmaker 7/28/76 CP stops concrete placement work when further rebar placement errors found by their overview program.

PN-III-76-52 issued by RIII 8/2/76 RIII recommends HQ notice of violation be issued 4

8/9 - 9/9/76 Five week full-time RIII inspection conducted 8/13/76 Notice issued 10/29/76 CP responded to HQ Notice of Violations 12/10/76 CP revised Midland QA program accepted by NRR 2/28/77 Unit 2 bulge of containment liner discovered 4/19/77 Tendon sheath omissions of Unit I reported j 4/29/77 IALissuedrelativetotendonsheathplacesfnterrors 5/5/77 Management meeting at CP Corporate Office relative to IAL regarding tendon sheath problem 5

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5/24-27/77 Special inspection by RIII, RI and HQ personnel to determine adequacy of QA program implementation at l Midland site -

6/75 - 7/77 Series of meetings and letters between CP and NRR on applicability of Regulatory Guides to Midland.

Commitments by CP to the guides was responsive l 7/24/78 Construction resident inspet._an assigned  ;

8/21/78 Measurements by Bechtel indicate excessive settlement of Diesel Generator Building. officially reported to RIII on September 7, 1978 12/78 - 1/79 Special investigation / inspection conducted at Midland sites Bechtel Ann Arbor Engineeringeffices and at CP corporate

, offices relative to Midland plant fill and Diesel Generator building settlement problem l ..-

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Selected Major Events Past Problems -

1. Cadweld Splicing Problem and Show Cause Order A routine inspection, conducted on November 6-8, 1973, as a result of intervenor information, identified eleven examples 4 of four noncompliance itema relative to rebar Cadwelding j operations. These items were summarized as: (1) untrained Cadweld inspectors; (2) rejectable Chdwelds accepted by QC pf'$a inspectors; (3) records inadequate as establish cadwelds met jf requirements; and (4) inadequate procedures. f0* ,

C As a result, the licensee stopped work on cadweld operations on November 9,1973 which in turn stopped rebar installationc lI kk The licensee agreed not to resume work until the NRC reviewed and accepted their corrective action. However, Show Cause Order was issued on December 3,1973, suspending Cadwelding operations. On December 6-7, 1973 RIII and HQ personnel conducted a special inspection and determined that construction activity could be resumed in a manner consistent with quality criteria. The show cause order was modified on December 17, 1973, allowing resumption of Cadwelding operations based on the inspection results.

The licensee answered the Show Cause Order on December 29, 1973, committing to revise and improve the QA manuals and procedures and make QA/QC personnel changes.

Prehearing conferences were held on March 28 and May 30, 1974, and the hearing began on July 16, 1974. On September 25, 1974, the Hearing Board found that the licensee was implementing its QA program in compliance with regulations and that construction i should not be stopped. .

2. Rebar Omission / Placements Errors Leading to IAL i Initial identification and report of rebar nonconformances l

occurred during an NRC inspectica conducted on December 11-13, 1974. The licensee informed the inspector that an audit, had identified rebar spacing preblems at elevations 642' - 7" to 652' - 9" of Unit 2 containment. This item was subsequently reported per 10 CFR 50.55(e) and was identified as a item of l . noncompliance in report Nos. 50-329/74-11 and 50-330/74-11.

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! Additional rebar deviations and omissions were identified in l March and August 1975 and in April, May and June 1976. Inspection

report Nos. 50-329/76-04 and 50-330/76-04 identified five noncompliance items regarding reinforcement steel deficiencies.

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Licensee response dated June 18, 1976, listed 21 separate items (commitments) for corrective action. A Jane 24, 1976 letter provided a plan of action schedule for implementing the 21 items. The licensee committed not to resume concrete

- piscement work until the items addressed in licensee's June 24 letter were resolved or implemented. This commitment was documented in a RIII letter to the licensee dated June 25, 1976.

Although not stamped as an IAL, in-house memos referred to it as such.

Rebar installation and concrete placement activities were resumed in early July 1976, following completion of the items and verification by RIII.

Additional action taken is as follows:

a. By the NRC (1) Assignment of an inspector full-time on site for five weeks to observe civil work in progress (2) IE management meetings with the licensee at their corporate offices (3) Inspection and evaluation by Headquarter personnel

b. By the Licensee (1) June 18, 1976 letter committing to 21 items of corrective action (2) Establishment of an overview inspection program to provide 100% reinspection of embedments by the licensee following acceptance by the contractor i QC personnel ,

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c. By the Contractor (1) Personnel changes and retraining of personnel (2) Prepared technical evaluation'for acceptability of l each identified construction deficiency (3) Improvement in their QA/QC program coverage of civil work'(thiswasimposedbythelicensee[

3. Tendon Sheath Placement Errors and Resulting Immidiate Action Letter (IAL)

On April 19, 1977, the licensee reported, as a Part 50, Section 50.55(e) item, the inadvertent omission of two hoop tendon

, shesths from a Unit 1 containment concrete placement at l

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elevation 703' - 7". The tendon sheaths were, for the most part, located at an elevation in the next higher concrete placement lift, except that they were diverted to the lower placement lift to pass under a steam line penetration and

_ it was where they were omitted. Failure to rely on the

. proper source documents by construction and inspection personnel, contributed to the omission.

An IAL was issued to the licensee on April 29, 1977, which spelled out six licensee commitments for correction which included: (1) repairs and co>ae corrective action; (2) expansion of the licensee's QC over view program; (3) revisions to procedures and training of construction and inspection personnel.

A special QA program inspection was conducted in early iky 1977.

The inspection team was made up of personnel from RI, RIII, and HQ. Although five items of noncompliance were identified, it was the concensous of the inspectors that the licensee's program was an acceptable program and that the Midland construction activities were comparable to most other construction projects.

The licensee issued its final report on August 12, 1977. Final review on site was conducted and documented in report No.

50-329/77-08.

Current Problems

1. Plant Fill - Diesel Generator Building Settlement The licensee informed the RIII office on September 8,1978, of per requirements of 10 CFR 50.55(e) that settlement of the diesel generator foundations and structures were greater than expected. .

Fill material in this area was placed between 1975 and 1977, with construction starting on diesel ge.serator building in mid-1977. Filling of the cooling pond began in early 1978 with the spring run-off water. Over the year the water level has increased approximately 21 feet and in turn increasing the site gound water level. It is not known at this time

what effect (if any) the higher site ground water level has had on the plan fill and excessive settlement of the Diesel Generator Building. It is interesting to note however, that initially the PSAR indicated an underdrain system would be 2'

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installed to maintain the ground water at its normal (pre pond) level but that it later was deleted. '

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l The NRC activities, to date, include: .

a. Transfer of lead responsibility to NRR fronIIE by memo dated November 17, 1978 b.

Site meeting on December 3-4, 1978, between NRR, IE, Consumers Power and Bechtel to discuss the plant fill problem and proposed corrective action relative to the Diesel Generator Building settlement

c. RIII conducted an investigation / inspection relative to the plant fill and Diesel Generator Building settlement The Constructor / Designer activities include:

a. Issued NCR-1482 (August 21, 1978)

b. Issued Management Corrective Action Report (MCAR) No. 24 (September 7,1978)

c. Prepared a proposed corrective action option regarding ,

placement of sand overburden surcharge to accelerate and achieve proper compaction of diesel generator building sub soils Preliminary review of the results of the RIII investigation /

inspection into the plant fill / Diesel Generator Building settlement problem indicate many events occurred between late 1973 and early 1978 which should have alerted Bechtel and the licensee to the pending problem. These events included nonconformance reports, audit findings, field menos to engineering and problems with the administration building fill which caused modification and. replacement of the already '

poured footing and replacement of the fill material with lean concrete. .

2. Inspection and Quality Documentation to Establish Acceptability of Equipment This problem consists of two parts and has just recently been identified by RIII inspectors relative to Midland. The scopt and depth of the problem has not been determined.

The first part concerns the adequacy of engineering evaluation f of quality documentation (test reporte, etc.) to; determine if the documentation establishes that the equipment meets specification and environmental requirements. The licensee, 8

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on November 13, 1978, issued a construction deficiency report (10 CFR 53.55(e)) relative to this matter. Whether the report -

was tri Fgered by RIII inspector inquiriesfor by IE Circular i or Bulletin is not known. An interim report dated November 28, I 1978 was received and stated Consumers Power was pursuing this  !

matter not only for Bechtel procured equipment but also for I NSS supplied equipment.

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The second part of the problem concerns the adequacy of equipment acceptance inspection by Bechtel shop inspectors.

g Examples of this problem include: (1) Decay Heat Removal Pumps released by the shop inspector and shipped to the site with one pump assembled backwards, (2) electrical j penetrations inspected and released by the shop inspector for shipment to the site. Site inspections to date indicate '

about 25% of the vendor wire terminations were improperly crimped.

Inspection History i The construction inspection program for Midland Units 1 and 2 is approximately 50% complete. This is consistent with status of construction of the two units. (Unit 1 - 52%; Unit 2 - 56%) In terms of required inspection procedures approximately 25 have been completed, 33 are in progress and 36 have not been initiated.

The routine inspection program has not identified an unusual number of enforcement items. Of the selected major events described above, only one is directly attributable to RIII enforcement activity (Cadweld splicing). The other were identified by the licensee and reported l through the deficiency report system (50.55(e)). The Midland data for 1976 - 78 is tabulated below.

Number of Number of Inspector Hours Year Noncompliances Inspections On Site 1976 14 9 646 1977 5 12 648 1978 11 18 706 A resident inspector was assigned to the Midland site in July 1978.

The on site inspection hours shown above does not include his inspection time.

[. The licensee's QA program has repeatedly been subject to in-depth review 3 by IE inspectors. Included ares ,

1. July'23-26 and August 8-10, 1973, inspection report N'os. 50-329/73-06 and 50-330/73-06: A detailed review was conducted relative to the implementation of the Consumers Power Company's QA manual and Bechtel Corporation's QA program for design activities at the Bechtel Ann Arbor office. The identified cor.cerns were reported as discrepancies relative to the Part 50, Appendix B, criteria requirements.

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2. September 10-11, 1973, report Nos. 50-329/73-08 and 50-330/73-08:

A detailed review of the Bechtel Power Corporation QAcprogram for Midland was performed. Noncompliances involving three separate Appendix B criteria with five different examples, were identified.

. 3. February 6-7, 1974, reports No. 50-329/74-03 and 50-330/74-03: A followup inspection at the licensee's corporate office, relative to i the items identified during the September 1973 inspection (above) along with other followup.

4. June 16-17, 1975, report Nos. 50-329/75-05 and 50-330/75-05: Special inspection conducted at the licensee's corporate office to review the new corporate QA program manual.

5. August 9 through September 9, 1976, report Nos. 50-329/76-08 and 50-330/76-08: Special five-week inspection regarding QA program implementation on site primarily for rebar installation and other civil engineering work.

1 6. May 24-27, 1977, report Nos. 50-329/77-05 and 50-330/77-08: Special inspection conducted at the site by RIII, IE and RI personnel to examine the QA program implementation on site by Consumers Power Company and by Bechtel Corporation. Although five examples of noncompliance to Appendix B Criterion V, were identified, the consensus of the inspectors involved was that the program and its implementation for Midland was considered to be adequate.

l Although the licensee's Quality Assurance program has under gone a number of revisions to strengthen its provisions, no current concern exist regarding its adequacy. Their Topical QA Plan has been reviewed and l

accepted by NRR through revision 7. Implementation of the program has been and continues to be subject to further review with the mid-construction program review presently scheduled for March or April 1979.

Consumers Power Company expanded their QA/QC auditing and surveillance coverage to provide extensive overview inspect' ion coverage. This began in 1975 with a commitment early in their experience with rebar installation problems and was further committed by the licensee in his letter of June 18, 1976, responding to report Nos. 50-329/76-04 and 50-330/76-04.

This overview inspection activity by the licensee.has been very effective as a supplement to the construct 6r's own program. Currently, this program is functioning across all significant activities at the site.

Enforcement History Approximately 6 months after restart of construction activities (11 months after CP issuance) an inspection identified four noncomplignce items regarding cadwelding activities. This resulted in a show cause order being issued on December 3,1973. This enforcement action was aired publicly during hearings held by the Atomic Safety Licensing Board in May 1974. The hearing board issued its decision in September 1974

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that concluded that construction could proceed with adequate assurance of quality.

Identification of reinforcing bar problems began in Decemb'er of 1974 with the licensee reporting improper spacing of rebar in the Unit 2 containment wall. Further reinforcing bar spacing and/or omission of rebar was identified in August 1975 and again in May 1976 with the citations of 5 noncompliances in an inspection report. An IE:HQ notice of violation was issued regarding the citations in addition to the licensee issuing

a stop work order. The licensee issued a response letter dated June 18, 1976 committing to 21 items of corrective action. A Bechtel prepared technical assessment for each instance of rebar deficiency was submitted to and review by IE

HQ who concluded that the structures involved will satisfy the SAR criteria and that the function of these structures will be maintained during all design conditions. The RIII office of NRC performed a special five week inspection to assess the corrective action implementation without further citation.

The licensee reported that two hoop tendon sheaths were omitted in concrete placements of Unit 2 containment wall in April 1977. An Immediate Action Letter was issued to the licensee on April 29, 1977 listing six items of licensee commitments to be completed. A special inspection was performed on May 24-27, 1977 with four NRC inspectors (1-HQ, 1-RI, and 2-RIII). Although five items of noncompliance were identified, it was the consensus of the inspectors that the QA/QC program in effect was adequate. The constructors nonconformance report provided an alternate method of installation for the tendon sheaths that was accepted.

The RIII office of inspection and enforcement instituted an augmented on site inspection coverage program during 1974, this program has continued in effect ever since and is still in effect. It is noted that the noncompliance history with this program is essentially the same as the history of other RIII facilities with a comparable status of construction. Further on site inspection augmentations was accomplished with the assignment of a full time resident in'spector in August,1978.

The noncompliance history for the Midland Project is provided in the

, following table.

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Noncompliances ,"

Criteria (10 CFR 50 Appendix B)

Year i Total ( ) Number of Occurrances 1970 4 V, X, XI, XVI 1971-1972 0 Construction haulted pending CP 1973 9 II V(5) XIII, XV, XVII 1974 3 V(2) WI 1975 0 1976 10 V(4) X, XII, XV, XVI, XVII, XVIII 1977 5 V(5) 10 CFR 50.55(e) item 1978 11 V(4) VI(2), VII, IX(3), XVI criteria II QA Program V Instructions Procedures Drawing Contral Work VI Document Control VII Control of Purchased Material II Control of Special Processes X Inspection III Control Measuring - Test Equipment XIII Handling - Storage

.. IV Nonconforming P, arts ,

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XVII QA Records XVIII Audits 12.

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Summary and Conclusions Since the start of construction Midland has experienced some significant problems resulting in enforcement action. In evaluating these problems.

- they have occurred in clumps: (1) in September 1970 relative to improper

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placement, sampling and testing of concrete and failure of QA/QC to act ,

on identified deficiencies; (2) in September 1973 relative to drawing I

control and lack of or inadequate procedures for control of design and procurement activities at the Bechtel Engineering offices; (3) in November 1973 relative to inadequate training, procedures and inspection of cadweld activities; (4) in April, May and June 1976 resulting from a series of RIII in-depth QA inspections and meetings to identify underlying causes of weakness in the Midland QL program implementation ,

relative to embedments. (The noncompliance items identified involved inadequate quality inspection, corrective action, procedures and documentation, all primarily concerned with installation of reinforcement steel); (5) in April 1977 relative to tendon sheath omissions; and (6) in August 1978 concerning plant soil foundations and excessive settlement of the Diesel Generator Building.

Following each of these problem periods (excluding the last which is still under investigation), the licensee has been responsive and has taken extensive action to evaluate and correct the problem and to up-grade his QA program and QA/QC staff. The most effective of these licensee actions has been an overview program which has been steadly expanded to cover almost all safety related activities.

The evaluation both by the licensee and IE of the structures and equipment affected by these problems (again except the last) has established that they fully meet design requirements. ,

Since 1974 these problems have either been identified by the licensee's quality program or provided direction to our inspectors.

Looking at the underlying causes of these problems two common threads emerge: (1) Consumers Power historically has

• tended to over rely on Bechtel, and (2) insensitivity on the part of both Bechtel and Consumers Power,to recognize the significance of isolated events or failure to adequately evaluate possible generic application of thess events either of which would have led to early identification and avoidance of the problem including the last on plant fill and diesel generator building settlement.

"e Notwithstanding the above, it is our conclusion that the problems experienced are not indicative of a broadbreakdown in the overall quality

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^ assurance program. Admittedly, deficiencies have occurred which should have been identified earlier by quality control personnel,!but the licensee's program has been effective in the ultimate identification and

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subsequent correction of these deficiencies. While we cannot dismiss the possibility that problems may have gone undetected by the licensee's overall quality assurance program, our inspection program has not identified significant problems overlooked by the licensee -- and this inspection effort has utilized many different inspectors.

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• l The RIII project inspectors believe that continuation of: , (1) resident site coverage, (2) the licensee overview program including ~ its recent expansion into engineering design / review activities, and (3) a continuing

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inspection program by regional inspectors will provide ade uateq assurance that construction will be performed in accordance with requirements and that any significant errors and deficiencies will be identified and corrected.

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