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NUCLEAR REGULATORY COMMISSION
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March 12, 1979 e
MIMORANDUM FOR:
H. D. Thornburg, Director, Divisien of Reactor Construction Inspection Office of Inspection and Enforce =ent FROM:
Ja=es G. Keppler, Director SGJECT:
MIDLAND DIESEL GENERATOR BUILDING Ah"J PLANT AREA FILL Meetings on this subject were held on February 23, 1979 and March 5, 1979, between Consumers Power Company, Bechtel Corporation and NRC. These meetings were a continuation of the investigation conducted by our inspectors during December 11-13, 18-20, 1978 and January 4-5, 9-11, 22-25, 1979.
During the February 23, 1979 meeting we presented to Consumers Power Company our preliminary investigation findings, a copy of which was previously forwarded to you.
During the March 5, 1979' meeting Consumers Power Company provided 4
their responses to those findings, copies of which are enclosed.
Our sw==ary findings with regard to this matter are ss follows:
1.
The quality assurance program for obtaining proper soil compaction of the Midland site was deficient in a number of areas.
2.
Soil of the type used in the foundation of the diesel generator building is also located, to varying degrees, under other Class 1 structures. Whereas excessive settlement has been observed with the diesel generator building, the settlement of other Class I structures has not exceeded predicted values.
3.
Several incorrect statements are contained in the FSAR with respect to the soil foundation.
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In addition to these findings, ve have compiled a list of technical questions which bear.on the resolution of this problem. These are enclosed for your use in working with NRR.
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r H. D. Thornburg March 12, 1979 As previously discussed with you, one of our concerns is related to why construction activities at the Midland site, which could be af4ected by a Class I structure settlement should be continued while the total cause of the diesel generator settlement has not yet been d e t e r=ined. During the meeting on Marc) 5,1979, this question was posed to the licensee. Their response was that continuing scheduled construction work would not compromise the coc=itted evaluations or-re=edial actions nor make irrevocable any conditions which do n.ot fully. satisfy TSAR or licensing requirements. Based on this, they are villing to accept the. risk of continued construction.
In tha+. we have questioned the licensee's intent to continue construction, we consider that the matter also warrants examination by HQ. This examination we feel also involves NRR for the following reasons:
1.
If one assumes the foundation settlement place =ent was in accordance with design, then the matter of design adequacy becomes questionable.
2.
If one assumes foundation placement did not meet design specification, one must question acceptability of the soils condition under the affected structures. It should be pointed out again, that the
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type of. soils placed under the diesel generator building were also the type placed under other Class I structures and associated pipes and utility lines.
4 3.
In light of ite=s a and b above, the matter of, seismic design'also becomes one of concern.
4.
Because of the licensee's total evaluation of the specific cause for the diesel generator and plant area fill settlement is not yet complete, the question of FSAR design ~ review and its acceptability may warrant further attention by NRR.
As an alternate approach to the issue, consideration should be given to an NRC Directive or Show Cause Order which could expedite the licensee's confirmation to the NRC that continued construction vill.
not compromise the design function of the involved structures for the life-time of the plant.
It may also expedite the licensee's investigation into the basic cause of the diesel generator settlement and its relationship (or absence) to other Class I structures.
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3-March 12, 1979 E. D. Thornburg We vill continue to follovup on.this matter and keep you inferned of new infomation.
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j James G. Keppler Director 4
j Enclosuresi As stated 4
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MIDLAND QUESTIONS 1._ The licensee has stated that the fill has settled under its own weight. What assurance is provided that the fill has not settled locally under:
e a." ' Structures-with rigid mat foundations as portions of the auxiliary building or service water pu=p structure.
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Class I piping in the fill resulting in lack of continuous support causing additional stress not accounted for in design.
2.
How has the lack of compaction and the increase in soil compressibility affected the seis=ic response spectra used in design and therefore, the soil-structure interaction during seismic loading?
3.
Af ter current preloading material is removed vill additional borings be taken to ascertain that the material has been I
co=pacted to the original requirements set forth in.the PSAR and construction license application?
4.
Since the foundation material is variable as described in 50.55(e) g interim report nu=ber 4, how can long term dif f erential settlement 7(
be predicted to assure reliable startup of the D/G in the event of emergency?
5.
What tolerance does the D/G manufacturer require on the alignment of the D/G for reliable operation and startup?
i 6.
Preliminary information indicates that the piping in fill under l
and in the vicinity of the D/G building have gross deformations induced either prior to or during the preload progra=. What is the extent of the deformation. Is this deformation beyond predicted?
If so, what plans are being taken-to correct the condition?
I 7.
The borated water storage tanks and diesel fuel oil tanks have not yet -been constructed and are oto be located in questionable plant fill of varying quality. Why should those Class it structures b'e constructed prior to assuring the foundation material is capable of supporting such structures for the plant life?
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MIDLAND OUESTIONS 8.
FSAR Figure 2.5-48 shows estimated ultimate settlements which
- indicate a differential settle =ent across individual mat foundation and within individual structures. Was this differential accounted for in the o;iginal design of the mat foundation and in the design of structural me=ber within the structure.
If not, what ef f ect does this differential settlement have on additional stresses induced in the mat or in structure me=bers such as slab-beac-colu=n connections?
9.
Based on the information provided in CPCo interi= report number 4, it appears that the tests performed on the exploratory borings indicate soil properties that do not meet the original co=paction criteria set forth in the PSAR and specification for soils work.
i What assurance is there that the soil under other Class I structures not accessible to exploratory boring meet the control ce=paction requirements?
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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
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50-330 OM & OL (Midland Plant, Units 1 and 2
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NRC STAFF TESTIMONY OF DARL S.' HOOD, JEFFREY K. KIMBALL AND EUGENE GALLAGHER ON STAMIRIS CONTENTION 1 Q. 1.
Please state your names and positions with the NRC.
A.
My name is Darl S. Hood.
I am a Senior Project Manager in the Division of Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.
My name is Jeffrey K. Kimball.
I am a Seismologist /Geophysi-cist reviewer within the Geosciences Branch, Division of Engineering, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission.
I My name is Eugene J. Gallagher.
I am a civil engineer with the 1
U.S. Nuclear Regulatory Commission.
Since February,1981, I have been assigned to the Reactor Engineering Branch, Division of Resident and Regional Reactor Inspection, Office of Inspection and Enforcement.
Prior to February,1981, I was a reactor l
inspector assigned to the Region III, Reactor Construction and Engineering Support Branch, Office of Inspection and Enforcement.
.Q. 2.
Have you prepared statements of professional qualifications?
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Yes.
Copies of these statements are Attachment 1.
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Q. 3.
Please state the duration and nature of your responsibilities with respect to the Midland Plant, Units 1 and 2.
A.
[I, Darl Hood, am the Project Manager for the Midland Plant application for operating licenses.
I have served in that position from August 29, 1977, when the application for operating licenses was tendered to the NRC for acceptance review, up to the present time.
My responsibilities include management of the Staff's environmental and radiological safety reviews.
I am responsible for the Staff testimony on the following parts of Stamiris' Contention 1: (a);
Supplemental Items 2, 3, 4 and 6; and portions of Supplemental Items 1 and 5.
I, Jeffrey Kimball, have served 'in the position of Seismologist /
Geophysicist reviewer for the Midland Plant since July 1980. I am responsible for i
the Staff testimony on part 1 (b) of. Stamiris Contention 1.
I, Eugene Gallagher, was assigned to the Midland Plant (among others) from October,1978 until January,1981. Since October of 1978, I have spent approximately one year of effort performing inspections, reviewing quality control records and procedures, observing work activities, reviewing Consumers Power Company (hereafter'CPC or Applicant) responses to 10 CFR 50.54(f) questions I and 23, and attending meetings and presentations by CPC and Bechtel regarding the soil settlement matter at the Midland Plant.
I am e ponsible for the Staff q
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testimony for@ portion / of Supplemental Item 1 and 5 o Stamiris' Contention 1.
t Q. 4.
Please state the purpose of this testimony.
A.
The purpose of this testimony is to address Contention 1 of the Contentions of Barbara Stamiris as. identified in the Appendix to Prehearing Conference s
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(I Order Ruling on Contentions and on Consolidation of Proceedings, dated October 24, 1.980, and as supplemented by Intervenor Answer To Applicant's Interrogatories, dated April 20, 1981.
This testimony does not address Stamiris Contention 1 (d) since this relates to matters to be addressed at a later time.
Stamiris' Contention 1 reads as follows:
Consumers Power Company statements and responses to NRC regarding soil settlement issues reflect a less than complete and candid dedication to providing information relevant to health and safety standards witn respect to resolving the soil settlement problems, as seen in:
a) the material false statement in the FSAR (Order of Modification, Appendix B);
b) the failure to provide information resolving geologic classification of the site which is pertinent to the seismic design input on soil settlement issues (Responses to FSAR Questions 361.4, 361.5, 361.7 and 362.9);
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d) the failure to provide adequate acceptance criteria L
for remedial actions in response to 10 CFR 550.54(f) requests (as set forth in part II of the Order of Modification);
and this managerial attitude necessitates stricter than usual regulatory supervision ( ALAB-106) to assure appropriate implementation of the remedial steps required by the Order Modifying Construction Permits, dated December 6,1979.
April 20,1981 Supplement to Contention 1 Examples of CPCo. reluctance to provide requested information 1.
3/31/80 NRC meeting notation of Applicant's reluctance to provide HRC consultants with requested information.
2.
Vol. III, tab 65 50-54f,' 8/6/79 meeting, attitude that
" needlessly conservative decisions may be formulated on the 'what if' type questions" by the NRC on dewatering.
- 3. 'The 11/24/80 S.A.L.P. assessment on CPCo - NRR interface as presented by D. Hood in the following statements regarding
, soil settlement issues:
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"A big contributor to the inability to make meaningful progress in this matter _ is the quality of responses gotten. We have set some kind of record on the number of questions re-asked, which speaks poorly for CPCo-NRR interface....The bottomline is there seems to be a lack of appreciation or support of Staff review necessities and a tendency to push ahead despite the lack,of proper assurances."
4...The perfunctory manner in which CPCo. deponents answered questions 1. (I will tabulate examples from the depositions I attended.)
Examples of information withheld or incorrectly given:
5.
The failure of CPCo. to discuss the Administration Building settlement problem with the NRC, as they did with their consultants, in the. early meetings on the DGB settlement.
6.
The false FSAR statements beyond the one cited as a
" material false statement" in the Dec. 6 Order, as discussed in the 4/3/79 Keppler-Thornburg memo, and the 6/13/79 Thornburg - Thompson memo.
Q. 5.
What is the NRC Staff response to Contention 1(a)?
A.
Information submitted as part of an application for licenses in accordance with 10 CFR 50.30 is " material" if that information. should or could have an influence upon a safety conclusion of the NRR Staff. A material statement which is false is of concern if it could have resulted in an improper finding or a less probing analysis by the NRR Staff.
The material false statement referred to in Contention 1(a) is described in Appendix B to the Order Modifying Construction Permits, dated December 6, 1979. Specifically, the material false statement was made in Section 2.5.4.5.3 of the FSAR. That section provided that "all fill and backfill were placed according to Table 2.5-9".
Had the Staff relied on this statement, it would or could have erroneously concluded that the fill and q
. l backfill placed for the support of structures and the Diesel Generator Building consisted of " clay" (Table 2.5-9 under " Soil Types") or " controlled compacted cohesive fill" (Table 2.5-14 under " Supporting Soils") which had been compacted, as a minimum, to"95% of ASTM D 1557-66 T modified to get 20,000 foot-pounds of compactive energy per-cubic foot of soil (see Table 2.5-9 under " Compaction Criteria"). The reality of the situation is that the fill and backfill beneath the structures and the Diesel Generator Building are neither " clay" nor a " controlled compacted cohesive fill", but consist of a heterogeneous mixture of sand, clay, silt and lean concrete, and the minimum compaction criterion implied as having been achieved by the quoted statement from FSAR Section 2.5.4.5.3 was not achieved.
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Therefore, a conclusion by the Staff that the fills and backfills were of a different type or had been compacted to known minimum standards would have been eroneous and would or could have precluded a more probing analysis or further questioning. Based upon the FSAR information, the Staff would or could have concluded that the structure was adequately supported, that it would not experience detrimental settlement, that its foundations would remain stable under both static and earthquake loading, and that the fill properties would be at least equal to design values provided in the FSAR. The Staff's conclusion would have been relevant to the NRC findings pursuant to 10 CFR 50.57 (3) for issuance of operating licenses and would have contributed to, a finding that there is. reasonable assurance that the activities authorized by th: operating license can be conducted without endangering the health and safety of the public.
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. I do not agree with Contention 1(a) to the extent that the material s
false statement is a reflection of "a less than complete and candid dedication to providing information relevant to health and safety standards with respect to resolving the, soil settlement problems." In my opinion the material false statement in the FSAR 15 a reflection of the breakdown in quality assurance and quality control that existed for the Midland plant prior to December 6,1979 for requirements such as design control (Criterion III of 10 CFR Part 50, Appendix B) and document control (Criterion VI of 10 CFR Part 50, Appendix B). I have no reason to believe, nor do I believe, that this material false statement was intentional.
Similarly, I have heard no one else express this view that the was intentional.
Q. 6.
What is the NRC Staff response to Contention 1(b)?
A.
FSAR Questions 361.4, 361.5 and 361.7 referred to in
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Contention 1(b) were asked by the NRC's Geosciences Branch as part of its review of the Midland Plant application for operating licenses. Question 361.4 was issued on June 20, 1978; the Applicant's latest response prior to issuance of the December 6,1979 Order on Modification was by FSAR Revision 15 (Amendment 54) dated November 27,1978, ( Attachment 2) and the current response was by FSAR Revision 30 ( Amendment
- 83) dated October 21,1980 ( Attachment 3).
Question 361.5 was also issued on June 20, 1978; the Applicant's latest response prior to December 6,1979 was by FSAR Revision 14 ( Amendment 51) dated October 17,1978 ( Attachment 4),
and the current response was by FSAR Revision 30 ( Amendment 83) dated October 21, 1980 ( Attachment 5). Question 361.7 was issued on February 14, 1979; the Applicant.
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s 7-r responded by FSAR Revision 24 (Amendment 69) dated September 28, 1979
( Attachment 6).
Question 362.9 was asked by the NRC's Geotechnical Engineering section
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on August 30,19 8; the Applicant's latest response prior to December 6,1979 was by FSAR Revision 24 ( Amendment 69) dated September 28, 1979 (Attachment 7) and the current response is by FSAR Revision 26 (Amendment 73) dated January 30, 1980
( Attachment 8).
The Applicant did not fail to provide information in responding to Questions 361.4, 361.5 and 361.7 as alleged in Contention 1(b); however, the information contained in the responses to these three questions did not resolve the open issue involving which tectonic province the Midland site is in.
f Specifically, the Applicant had used the Michigan Basin tectonic province whereas
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the NRC staff has been reluctant to accept subdivision of the whole Central Stable
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Region tectonic province.
Question 362.9 inquired about structural settlement measurements from certain benchmark numbers. The relationship, if any, of this subject to information resolving geologic classification of the site as alleged in Contention 1(b) is not understood, and Question 362.9 was not asked for such a purpose.
The Staff does not view the tectonic province disagreement between itself and CPC as any reflection of "a less than complete and candid dedication" to providing information relevent to resolving the open issue which is nec'essary for approval of the remedial actions associated with the soil settlement matter.
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. 'Q. 7.
What is the NRC Staff response to Item i in Stamiris' supplement to Contention l?
A.
Ite:n 1 refers to a March 31,1980 " meeting notation".
This is a reference to the " Summary of February 27 & 28, 1980 Meeting and Site Tour with Consultants to Review Soil Settlement" (Attachment 9). The statement of interest is the first paragraph on page 3 of this meeting summary:
The staff noted that such documents as above are needed by its consultants for their independent assessment of the adequacy of the proposed remedial measures and requested that these be made publicly available. The applicant indicated a reluctance to this end, and noted that these were available through the I&E audit mechanism.
The staff will issue a formal request for these documents.
The above statement refers to a discussion by the Applicant during the meeting in response to our request for documents. The Applicant replied, as best I can recall, that 'many of these documents are of a type not normally found within the docketed material of an application for licenses, and that the documents requested would be quite volumnious. The purpose of the comment, I believe, was to explore the possibility that the Staff's need for the documents might be accomplished through a less burdensome and expensive mechanism, such as the audit mechanism which would provide for NRC review at a local record center such as Bechtel, in Ann Arbor, Michigan.
The Staff, in fact, formally requested the documents by letter dated April 1,1980 ( Attachment 10). The Applicant replied initially by coverletter dated May 5,1980 forwarding Amendment 77 and copies of Revision 7 to the document 9
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entitled " Responses to NRC Requests Regarding Plant Fill." This coverletter acknowledged that five of the requested reports were not being forwarded at that time; two of the five had been superseded and the two replacement documents, also named in the staff request, would be forwarded as they became available.
These four reports discuss the Sondex system and Borros Anchor procedures.
The fifth document identified for submittal at a later time in the Applicant's May 5,1980 coverletter discussed qualification of compaction equipment. The documentation for qualification of compaction equipment had been previously requested by the Office of Inspection and Enforcement (IE) on December 4, 1978 as described by "Sunmary of December.4,1978 meeting on Structural Settlements" ( Attachment 11), page 4, which states in part:
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The NRC Resident Inspector asked for a list of the equipment, with a discussion of the compaction capability and limitations of each, used for compacting the fill for the DG Building from elevation 618 to 628 feet.
Bechtel will provide this information.
ebe s9edon" dacgcs This documentat' was again requested unsuccessfully during IE site visits Ggt aroun mid 1979 a in May 1980 ( Attachment 12). The Applicant's reply of August
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15, I arded, in part, a report on the Test Fill Program (tab 150 in " Responses to NRC Requests Regarding Plant Fill") which was conducted between May 1979 and October 1979 to requalify various compactors for structural and pit run sands.
The August 15, 1980 reply also noted that "further testing is being conducted in i
j order to substantiate qualification of certain equipment."
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s While the difficulty and delay associated with acquiring documentation
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with respect to qualification of soils compaction equipment represents an instance of poor cooperation with NRC,-the Staff does not believe that the discussions during the meetings of Febru'ary 27 and 28,1980, nor the subs'equent actions of the Applicant to comply with the Staff request for documents other than those documents on qualification of soils compaction equipment, reflect an overall a deficiency in i
atti tude.
d However, this poor cooperation reflected adversely upon the responsible officials involved in execution of CPC's quality assurance program.
Q. 8.
What is the NRC Staff response to Item 2 in Stamiris' supplement to Contention 17
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A.
The statement referreo to in Item 2 is found in tab 66 of the document " Responses to NRC Requests Regarding Plant Fill".
It specifically appears in the last paragraph of an internal correspondence by T. C. Cooke/RMW (R.M. Wheeler) which was prepared either on August 6 or 7,1979 to summarize a pre-meeting of June 27, 1979 between CPC, Bechtel and Bechtel's consultants (Attachment 13).
The meeting sumary is somewhat ambiguous as to the source of this statement. The entire last paragraph of the meeting summary, including this statement, appears to indicate the views of the consultants.
From my reading of this paragraph, I believe the intent is to reflect the expressions of the cons'ultants.
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. I am unable to conclude that the cited example reflects the view of any member of CPC. Views expressed by Bechtel's consultants on their own behalf, as may possibly be the case here, would not be a reflection on the Applicant's -dedication to providing information nor the Applicant's managerial attitude. Furthermore, this cited example has nothing to do with CPC's alleged reluctance to provide requested information. Similarly, the statement does not demonstrate one way or the other whether CPC has a "less than complete and candid dedication to providing information."
Q. 9.
What is the NRC Staff response to Item 3 in Stamiris' supplement to Contention I?
A.
Item 3 refers to the SALP assessment of CPC.
SALP, or Systematic Assessment of Licensee Performance, is an NRC program for the comprehensive overview of licensee or applicant performance.
The program was included as Task I.B.2 in the " Action Plans for Implementing Recommendations of the President's Commission and Other Studies of TMI-2 Accident", NUREG-0660.
The program is.also discussed in House Report No. 96-1452, by the Committee on Government Operations, entitled, " Evaluating Nuclear Utilities Performance: Nuclear Regulatory Commission O ve rsi ght. " The objectives -of SALP are:
(1) Identification of unacceptable licensee performance; (2) Improvement of licensee performance; (3) Improvement of IE Inspection Program;
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Providing a basis for NRC management's allocation of resources; and (5)
Achieving regional consistency by appraising licensee performance from a national perspective.
Further description of SALP is provided in SECY 80-83 (Attachment 14).
Performance reviews and evaluations for SALP are conducted semiannually by a board consisting of NRC individuals who are involved in the inspection and licensing activities of the applicant or licensee such as resident inspectors, regional inspectors, regional managers, and NRR Project Managers. As Project Manager for the Midland plant, I, Darl Hood, am a member of the SALP Board responsible for the review and evaluation of the Midland Plant, Units 1 and 2. I participated in a meeting on November 24, 1980 between the SALP Board and CPC which was held to advise CPC of the results of the SALP evaluation for its nuclear plants, including Midland Plant, Units 1 and 2. During this meeting I made the statement:
A big contributor to the inability to make meaningful progress in this matter is the quality of responses gotten.'We have set some kind of recora on the number of questions re-asked, which speaks poorly for CPCo - NRR interface.
...The bottomline is there seems to be a lack of appreciation or support of Staff review necessities and a tendency to push ahead despite the lack of proper assurance.
Two examples that I had in mind when I made the above bottomline statement were associated with the Applicant's decision (1) to place and remove the surcharge for the Diesel Generator Building without first providing an adequate response to 50.54(f) Request 4, and (2) to proceed with construction of the Borated Water Storage Tanks without first performing the analyses for variable foundation properties and cracks as discussed in the response to 50.54(f) Request
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_j The statement cited above notes my agreement with Ms. Stamiris' contention that CPC has exhibited a reluctance to provide requested information.
Q. 10.
What 'is the NRC Staff response to item 4 in Stamiris' supplement to Contention l?
A.
Without the tabulated examples of "the perfunctory manner in which CPCo deponents answered questions" promised by Ms. Stamiris in her contention, the Staff is unable to evaluate or address this contention.
Q. 11.
What is the NRC Staff response to Item 5 in Stamiris' supplement to Contention 17 A.
This contention lists an example which claims to represent information
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withheld by the Applicant from the NRC. The specific example cited is, "The failure of CPCo. to discuss the Administration Building settlement problem with the NRC, as they [ CPCo ] did with their consultants, in the early meetings on h
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the DGB settlement."
Ms. Stamiris is correct in her statement that CPC did not discuss the settlement of the Administration Building grade beam with the NRC during early meetings on the Diesel Generator Building settlementearenciated site, s
visit of lata 1078. Although the Administration Building is not a safety related strvcture and CPC was not bound by 10 CFR 50.55(e) to report such a problem, the existance of that earlier problem was clearly of relevance to the 50.55(e) reports and reviews regarding Dies.el Generator Building settlement.
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The-NRC first learned of the Acmin stration Building grade beam problem during the NR.C investigation into t Diesel Generator Building settlement while at Bechtel's Ann Arbor. of fice nJ
. At that time, the Bechtel civil design supervisor, Hr'. G. Tuveson, informed the NRC of a similiar problem with the Administration Building and provided the NRC with a December 1977 report on the issue.
The NRC documented this information in pages 21-23 of NRC investigation report 78-20 (see Attachment 2 of St'aff Testimony on Stamirls' Contentic$n13), which describes variou s ariti tween the Administration Building settlement and d
the Diesel Generator Building ttlement.
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'vtf y.~ Y The Staff agrees with the contention that the Adminstration Building example represents information initially withheld from NRC. This information was known to the Applicant and was clearly relevant to the full understanding of the Diesel Generator Building settlement.
Q. 12.
What is the NRC Staff resoonse to Item 6 of-Stamiris' supplement to Contention I?
A.
Item 6 refers to " false statements" dLcussed in the April 3,1979 Keppler - Thornburg memorandum (A,ttachment 15) and the June 13, 1979 Thornburg - Thompson memorandum ( Attachment 16)
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The si nificance or " materiality" of these FSAR statements to NR's 9
review is described in D. Hood's memorandum to file dated August 9, 1979,
. (Attachment 17). As indicated therein, these other statemer'.s would not or could not have had an. influence upon a. safety conclusion of the NRR staff. Rather, these
.other statements were viewed.as an indicator of poor quality assurance performance.
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i DARL S. HOOD OFFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COMMISSION PROFESSIONAL 00ALIFICATIONS I am a Senior-Project Manhger in the Division of Licensing, Office of Nuclear Reactor Regulation.
I am responsible for nanaging licensing activities by the. Commission with respect to Hidland Plant, Units 1 and 2.
I have served in the position of Project Manager with the Commission since August 1976. This position provides for the managing of radiological safety reviews of applications for licenses and authorization to construct or operate light water nuclear power plants.
As of April 1980, the position also provides for the managing of the environmental reviews of such applications.
I assuned responsibility for Itidiand Plant, Units 1 and 2, when the application for operating licenses was tendered in August 1977.
Other nuclear plants for which I have previously served in this capacity are the standardization design of Westinghouse which is designated RESAR-414 (Docket STN50-572), Catawaba Nuclear Station, Units 1 and 2 (Dockets 50-413 and 50-414), and River p
Bend Station, Units 1 and 2 (Dockets 50-458 and 50-459).
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Between June 1959 and August 1976 I held two sequential positions within "c
the fluclear Power Systems Division of Combustion Engineering, Inc.
(Cx i) at Windsor, Connecticut.
Af ter itarch,1973, I was Assistant Project 11anager for the Duke Power Project. This position provided assistance in directing all efforts by C-E to design, fabricate, purchase and license the nuclear steam supply systems, reactor core, and associated auxiliary systems for Cherokee Units 1, 2 & 3 and Thomas L.
Perkins Units 1, 2 & 3.
The position assured that all aspects of the contracts were met and that safe and reliable systems were provided to the required schedule and at a reasonable profit to C-E.
I assisted Duke Power in preparing the Preliminary Safety Analysis Report (PSAR) and provided for all C-E licensing support for these units.
I also provided coordination of all other nuclear plants referencing the C-E Standard Safety Analysis Report to assure compatibility with C-E standard reference design.
Until tiarch,1973, I was a Project Engineer in C-E's Safety and Licensing Department and was responsible for licensing of nuclear power' plants.
I coordinated the preparation of the !!illstone Unit 2 PSAR and FSAR and the Calvert Cliffs Units 1 & 2 FSAR and interfaced with ilRC, the utility, architect engineer and all C-E functional departments on licensing support matters.
I ensured that NRC criteria, standards, and guides were incorporated into the nuclear steam supply system design.
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Setween August 1966 and June 1969, I was a Nuclear Safety.cnd Radiation e
Analysis Engineer in the Nuclear Safety Unit, Nuclear Division of the
- Martin Marietta Corporation at Baltimore, Maryland.
The purpose of this position was to perform hazard evaluations for nuclear power sources applied in space missions.
My primary duty was to determine public exposure to radiation for malfunctions occurring during the intended mission.
I also determined means by which the hazard potential for nuclear space systems could be mitigated to the extent that nuclear safety criter.ia were met. ~ I conducted research with regards to the development of suitable. criteria for permissable exposure levels and their probabilities, taking.into account the dependence of acceptable risk on the benefit to be derived. My primary ass ~f gnment was with the e
SNAP 29 (Systems for Nuclear Auxiliary Power) project.
My evaluations of this nuclear power source included the formulation and application of computerized models for the transport of fuel released at high altitudes, in deep ocean and in shallow waters.
I-derived models for these release areas to incorporate the activity into human food chains and determined the expected ingestion dose, the number of people involved and the exposure probabilities.
Inhalation dose was determined for radioactive fallout from the high-altitude release.
Between February 1965 and August 1966 I was a Nuclear Quality Control Engineer within the Electric Boat Division of General Dynamics at Groton, Connecticut. The purpose of this position was to provide control of quality for naval reactor systems, components, and shielding during the construction or overhaul of submarines by this shipyard.
My primary area
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of responsibility was shielding. Duties included establishing procedures for the inspection of fabrication and installation of lead and
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polyethylene shielding, and resolving problems in complying with these or
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other shielding procedures.
The pos tion required a knowledge of nuclear theory, 55W systems -design, Bureau of Ships contract and design requirements, non-destructive testing techniques, and quality control requirements.
Between November 1963 and February 1965, I was an Aeronautidal Engineer for Nuclear-Propulsion and power at the George C. Marshall Space Flight Center, National Aeronautics and Space Administration in Huntsville, Alabama.
I performed investigations of the nature and nagnitude of the nuclear radiation environment, shielding systems and safety systems associated with proposed nuclear space ' vehicles for candidate space missions.
Between Novembe'r 1963 and college graduation in 1962, 'I held various positions including chief of a missile electronics training unit at Redstone ' Arsenal, Alabama;. student at the U.S. Arqy Signal Officer's Orientation Course at Fort Gordon,~ Georgia; and.Harine Engineer for:
ordinance andLspecial weapons within.the Design Division of'the Norfolk Naval Shipyard,.Portsmouth, Virginia.
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r I received a Sachelor of Science Degree in Nuclear Engineering from North J
Carolina State 'Jniversity in 1962.
I am a member. of the Health Physics 4-Society.-
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EUGENE J. GALLAGHER
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OFFICE OF INSPECTION AND EUFORCEMENT U.S. h) CLEAR REGULATORY COMMISSION PROFESSIGNAL OUALIFICATIONS I am a Civil Engineer in the Division of Resident and Regional Reactor Inspection, Reactor Engineering Branch, Office of Inspection and Enforcement.
I received a Bachelor of Engineering Degree in Civil Engineering from Villanova University in 1973 and a Master of Science Degree in Civil / Structural Engineering from Polytechnical Institute of New York in 1974.
I am a registered Professional Engineer in the States of Illinois (#37828), Florida (!29114) and Louisiana (f16376).
I am a member of the American Society of Civil Engineers American Concrete Institute and Tau Beta Pi National Engineering Honor Scciety.
In my present work at the NRC, I provide technical assistance in the area of civil engineering to Regional offices and resident inspectors with particular enphasis on the design and construction of reinforced and prestressed concrete structures, foundations, structural steel buildings and in structural testing and surveillance.
In addition, I provide technical input for the development and interpretation of industry codes, standards and regulatory requirements relating to inspection activities.
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From 1978 to 1981 I was a member of the NRC Region 3 inspection staff responsible fer the inspections of civil engineering aspects of plants under construction and in operation. This included the Inspection of laboratory and field testing of concrete, steel and soils caterials, earth embankments and dams, material sources, piping systers and reinforced and prestressed concrete structures.
In addition, a review of management controls and quality assurance programs were performed at plants under construction.
I participated in approximately 90 inspections of reactor facilities.
l Prior to joining the NRC Staff I was empicyed by EBASCO Services, Inc. in New York City from 1973 to 1978.
I performed designs of reinforced concrete and steel structures, design of hydraulic and water supply systens and preparation of specifications for construction. Frca 1976 to 1978, I was the civil resident engineer at the Waterford 3 Nuclear Plant site responstble for providing technical assistance to construction.
During 1972 and 1973 I was employed by Valley Forge Laboratory in Devon, PA performing inspection and testing on concrete, steel and soil naterials.
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2 ADDITIONAL NRC TRAINING Fundamentals of Inspection, NR'C, February 1973 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)
BWR Fundamentals ~ Course, NRC, March 1978 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)
' Concrete Technology and Codes, Portland Cement Assoc., liay 1978 (80-hours)
Quality Assurance Course, NRC, August 1978 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)
Nondestructive Examination and Codes Rockwell Int'l., August 1978 (120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />)
PWR Fundamentals Course, NRC, November 1973 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)
Welding Metallurgy, Ohio State University, September 1980 (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />)
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NUCLEAR REGULATORY COf.it.ilSSION U
RECION lli
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ATTACHMENT 3 4
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9AN 121981 0
h0'3 Docket No. 50-329 g<p Docket No. 50-330 Consumers Power Company ATTN:
Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 Centlemen:
This refers to a special announced inspection conducted by Messrs. E. J. Gallagher and R. B. Landsman of this office and Mr. J. W. Gilray of the Office of Nuclear Reactor Regulation, Quality Assurance Branch on December 8-11, 1980, of activities at.the Midland Nuclear Power Plant, Units 1 and 2, authorized by h3C Construction Permits No. CPPR-81 and No. CPPR-82 and to the discussion of our findings with you and others of your staff at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. The inspection consisted of a review of the Consumers Power Company response and implementation of corrective actions regarding the 10 CFR 50.54(f), Question 1 of NRC letter dated March 21, 1979 and Question 23, request for additional information dated September 11, 1979.
During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as described in the enclosed Appendix A, and a written response is required.
In addition to the above, the unresolved items described in Paragraph 3(c) and 3(d) requires your attention.
Please provide a written response to each individual part of the unresolved items for our review along with your response to the identified items of noncompliance.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room, except as follows.
If the enclosures contain information that you or i
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your contractors believe to be proprietary, you must apply in writing to this office, within twenty-five days of the date of this letter, to withhold such information from public disclosure. The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the
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application is contained in an enclosure to the application.
We will gladly discuss'any questions you have concerning this inspection.
1 Sincerely, James G. Keppler Director
Enclosures:
1.
Appendix A, Notice of Violation' 2.
IE Inspection Reports No. 50-329/80-32 and No. 50-330/80-33 cc w/encls:
Central Files Reproduction Unit NRC 20b PDR Local PDR NSIC TIC Ronald Callen, Michigan Public Service Commission Myron M. Cherry E
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RIII II RIII < ON RIID RII RI,I 4 IA l
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o I~,gy Hayes Knop Sutphin Fiorelli pfigf Kepp er m
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9 Ayycndix A NOTICE OF VI0I.ATION c
Consumers Power Co.
Docket No. 50-329 l.
Docket No. 50-330 As a result of the inspection conducted on December 8 - 11, 1980, and in accordance with the Interim Enforcement-Policy, 45 FR 66754 (October 7,1980), the following violations were identified:
1.
10 CFR 50, Appendix B, criterion XVI states, in part, that " Measures shall be established to assure,that conditions adverse to quality such 1-as...Geficiencies...are promptly... corrected. The measures shall assure that the cause...is determined and corrective action taken to i
preclude repetition."
Consumers Power Co. QA Program, Policy No. 16, corrective action states, 1
in part, that " corrective action is that action taken to correct and pre-clude recurrence of significant recurrence of significant conditions i
adverse to the quality of items... Conditions or trends observed or identified which are adverse to quality are considered for corrective action..."
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Tle "FSAR Re-review Procedure". instructions for Block 8 requires that i
"t he engineering design documents against which the FSAR review package
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is to be reviewed are listed by the primary review engineer."
i CPCO Audit No. H-01-53-0 states, in part, "the following significant items were revealed by this audit...in many instances not all of the j
design documents were listed as required by the instructions for per-forming the re-review."
Contrary to the above, CPC0 did not initiate preventive action to pre-clude repetition of not identifying design documents for the remaining re-review packages as evidenced by the inspectors review of other FSAR re-review packages which did not include all of the design' documents.
In addition, interviews with some of the primary reviewers indicated j
that they were not reviewing the FSAR for technical accuracy against j
references at the end of the FSAR chapter as required by the procedure.
j Based on the above,~the adequacy-of the FSAR re-review is in question.
This is a Severity Level IV violation (Supplement II).
2.
10 CFR 50, Appendix B, Criteria III, states, in part, that " Measures shall be established to assure that... design bases...are correctly translated into specifications...and for the identification and control of design interfaces...these' measures shall include the establishment of procedures...for the review of. documents involving design interfaces."
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Consumers Power Co. QA Program, Policy No. 3 states,'in part that "Each group... performing detailed design translates the applicable regulatory
..ifica-i requirements... design criteria into design documents, such as '
t i ons... p ro.cedu res. The design organization... establishes and controls the interface with other-design organizations.
Bechtel EDPI 4.25-1, Section 6.1, states, in part "Each originating a.
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design group shall-maintain a log of all documents which are routed l
to personnel external to the design group. These logs shall be re-tained...providing visibilft,y of the projects design interface control.
3, Contrary to the above, Bechtel Civil Project Engineering group.did l
not maintain a coordination log of specification and specification change notices as evidenced by our review of soils related specifica-tions C-211 and C-210.
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b.
ANSI N45.2.11,~ Paragraph 4.1 requires that applicable design inputs are correctly translated into specifications drawings, procedures or instructions.
In addition, Paragraph 7.0 requires that documents I
including changes are reviewed for adequacy.
Consumers Power Co.'s.50.54(f) response, Page I-17, Paragraph 4(a) 5 required that specification change notice (SCN)-9004 be issued to f
require a laboratory compaction test to be performed for each field 1
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density test.
SCN-9004 was initiated on 4/13/79.
i Contrary to the above, Revision 16, dated 8/24/79, to the present Revision 20 of specification C-208 did not correctly translate l
SCN-9004 as a requirement into the specification. Revision 16 permitted laboratory density tests to be~ performed at a frequency as determined by the geotechnical engineer rather than for each.
l field density test performed.
ANSI N45.2.11, Paragraph 8.2 requires that' design changes be reviewed c.
I and approved by the same groups or organizations which reviewed and approved the original design documents.
consumers Power Co. 50.54(f) response, Page 23-11 committed to revise existing design control measures and require design ' interfaces on design changes. EDPI 4.25.1, Revision 7 added Section 4.2 which states, "It is the responsibility of the originator of a design change to effect -
coordination 'of the change with all groups which reviewed and/or used g
i the original or subsequent revisions of that_ design document."
Contrary to the above, Revision 8 to EDPI 4.25.1 permits the group
-supervisor to waive the design. interface requirement by adding to l
Section 4.2, "as determined by the group supervisor of-the discipline l
which originated the document.'? Revision 8 does not establish adequate, j/
measures as required by ANSI N45.2.11 or as committed per 50.54(f)
R' response.
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.o Appendix A.
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1 This is a Severity Level IV violation (Suppicment II).
Pursuant to the provisions of 10 CTR 2.201, you are required to submit to this office within twenty-five days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance:
(1) correc-tive action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be
~
achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or af firmation.
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Dated 3. a,,w p:3 o.H!
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James G. Keppleru
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U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT
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REGION III Reports No. 50-329/80-32; 50-330/80-33 Docket Nos. 50-329'; 50-330 Licenses No. CPPR-81; CPPR-82
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Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant, Units 1 and 2 Inspection At: Bechtel Power Co., Ann Arbor, Michigan Inspection Conducted: December 8-11, 1980
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Inspectors:
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. Gal g r, Region III 4 Landsman,RegionIII f' fiI R. B
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Qua ity Assurance Branch R. C. gnop, &
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Reviewed By:
Projects Section No. 1 Approved By:
G. Fiore111, Chief Reactor Construction and Engineering Support Branch Inspection Summary Inspection on December 8-11, 1980 (Reports No. 50-329/80-32; 50-330/80-33)
Areas Inspected:, Consumers Power Company response and implementation of corrective actions regarding the 10 CFR 50.54(f) request of Question 1 of NRC' letter dated March 21, 1979 and Question 23, request for additional information dated September 11, 1979. The inspection involved 106 inspector-hours at the Bechtel Ann Arbor office by three NRC staff.
In addition, approximately 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of review of the licensee response was performed prior l
to the inspection.
Results: Two items of noncompliance were identified in the above areas inspected - Severity Level IV, Inadequate Design Control with three examples; Severity Level IV, Inadequate Corrective Action; and Unresolved Items identified L.
in Paragraph 3(c) and 3(d).
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s' DETAILS Exit Meeting Attendees-at Ann Arbor, Michigan, December 11, 1980 Nuclear Regulatory Commission
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E. J. Gallagher, Civil Engineer Inspector, IE: Region III R. B. Landsman, Civil Engineer' Inspector, IE: Region III J. W. Gilray, Quality Assurance Branch, NRR f
Consumers Power Company J. W. Cook, Vice President, Projects, Engineering and Construction B. W. Marguglio, Director, Environmental Services and Quality Assurance W. R. Bird, Quality Assurance Manager, Midland Project D. M.-Turnbull, Site Quality Assurance Superintendent G. R. Eagle, Supervising Quality Assurance Engineer i
G. S. Keeley, Midland Project Manager G..E. Clyde, Licensing Engineer H.-P. Leonard, Section Head, Quality Assurance Engineer i
j D. E. Horn, Group Civil Supervisor, Quality Assurance Engineer Bechtel, Ann Arbor Office i
J. Rutgers, Midland Project Manager
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J. Milandin, Manager of Quality Assurance L. A. Dreisbach, Assistant Project Manager i
V. J. Manta, Project Quality Engineer N. Swanberg, Assistant Project Engineer j
G. L. Richardson, Quality Assurance Manager, Midland Project D. F. Lewis, Licensing Engineer R. E. Sevo, Quality Assurance Engineer-A. E. Bico, Quality Assurance Engineer R. L. Rixford, Quality Assurance Engineer J. R. McBride, Quality Engineer t
R. C. Hollar, Quality Engineer
===1.
Background===
i Meetings were held on February 23, 1979 and March 5, 1979 at the NRC Region III office in Glen Ellyn, Illinois to discuss the circumstances associated with the settlement of the diesel generator building at the Midland facility.
This discussion was part of the investigation conducted by Region III as documented in NRC Investigation Report No. 50-329/78-20; 50-330/78-20, dated March 22, 1979. Representatives of the.NRC staff from headquarters attended the meeting on March 5, 1979. The staff stated that it's concern was not limited to the narrow scope of the settlement of the diesel generator building, but extended to various buildings, utilities and other structures located in and on~the plant area fill.
In addition, the staff expressed concern with the Consumers Power Company Quality Assurance Program.
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Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, and Section 50.54(f) of 10 CFR Part 50, additional in-formation was requested regarding the adequacy of the fill and the quality assurance program for the Midland site in order for the Commission to determine whether enforcement action such as license modification, suspension or revocation should be taken. Question 1 of the 50.54(f) letter dated March 21, 1979 requested information l'
regarding the, quality assurance program. On April 24, 1979, Consumers Power Company submitted the initial response to the 50.54(f) request, Questions 1 through 22.
As a result of the NRC staff review of Question 1, the NRC concluded that the information provided was not sufficient for a complete review. Subsequently, on September II, 1979 i
the NRC issued a request for additional quality assurance information (Question 23). On November 13, 1979, Consumers Power Company submitted revision 4 to the 50.54(f) responses which included response to Question 23.
As a result of the Region III investigation report and CPC0 responses, the NRC issued an Order modifying construction Permits No. CPPR-81 and No. CPPR-82, dated December 6, 1979. The latest revision to Consumers Power Company response to the 50.54(f) request is revision 10, dated November 21, 1980.
l 2.
Purpose of Inspection The inspection was conducted at the Bechtel Power Company Ann Arbor, Michigan offices on December 8-11, 1980 to verify implementation of the specific commitments and action items reflected in Consumers Power
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Company response to 10 CFR 50.54(f) Questions 1 and 23 with the exception of those areas where completion of commitments has not been satisfied as of this time.
The inspection was divided into the following areas:
A review of CPCo response to Question 1, Part (a) and Question 23, a.
Part (1) regarding the identification of the specific quality assurance deficiencies that contributed to the. soils problem, including the root cause-of the deficiency, remedial action in the soils area, the programmatic and generic corrective actions as committed to in the response.
b.
A review of CPCo response to Question 1, Part (b) and Question 23, Part (2) regarding the provisions to be implemented to preclude areas of contradictions between the PSAR, FSAR and design docu-ments.
A review of CPCo response to Question 1, Part (c) and Question 23, c.
Part (3) regarding the programmatic and generic corrective actions to provide confidence that quality assurance deficiencies do not (or will not) exist in other areas.
The following sections of this report discuss the results of the review of the above areas of CPCo response to_ Questions 1 and 23.
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3.
Review of Question 1, Part (a) and Question 23, Part (1)
The identification of quality assurance deficiencies that contributed to the soils problem was discussed in Question 1, Part (a) and Question 23, Part (1). Coneumers Power Company identified the root cause of the deficiencies, the remedial measures in the soils area, and the programmatic and generic corrective action to preclude further
~
recurrence of the deficiencies.
CPCo complied a list of specific action items that would have to be accomplished in order to satisfy the commitments made in response to Questions 1 and 23 of the 50.54(f) request.
Attachment No. I provides an action item tracking system which includes the action item description and reference and the status and documenta-tion verified by the NRC during this inspection.
Those action items for which CPCo commitments have been accomplished are identified as being " closed"; items identified as "open" either have not been completed by CPCo or the action taken was considered insufficient.
Question 1 provided 26 action items of which the NRC verified 18 had been satisfactorily accomplished while 8 remain open. Question 23 provided 57 action items of which 34 were determined to be satisfac-torily accomplished while 23 remain open.
The following are NRC findings regading the implementation of certain I
CPCo commitments.
Action items 23-5 and 23-38 as identified in Attachment No. 1 a.
provided commitments to examine current procedures and practices for the preparation and control of the FSAR in view of past experiences.
CPCo committed to procedural changes to existing engineering department procedures.
Seven Bechtel procedures were examined and revised to clarify design control procedures for the FSAR. Engineering Department Procedure Instruction (EDPI) 4.25.1, Design Interface Control, was revised by Revision 7 by including section 4.2 which states, "It is the responsibility of the originator of a design document change to effect coordination of the change with all groups which reviewed and/or used the original or subsequent revisions of that design document."
Subsequently, Revision 8 to EDPI 4.25.1, changes the above by adding to the end of the statement, "as determined by the group supervisor of the discipline which originated the document." The
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originator of Revision 8 stated that the intent was that only technical changes have to be interfaced while edito. rial changes would not necessarily require this interface control. The pro-cedural change, however, does not reflect the intent and permits
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the group supervisor to waive interface control for any changes as evidenced by inspection finding in Paragraph 3(b) of this report. The engineering procedures EDPI 4.25.1 does not satisfy CPCo commitment made to the NRC in response to Question 23, subsection 3.3, page 11 and identified as action item 23-5 of Attachment No. 1.
This failure to provide adequate design interface control is considered contrary to 10 CFR 50, Appendix B, Criterion III as described in the Notice of Violation.
(50-329/80-32-01; 50-330/
80-33-01).
b.
Engineering Department Procedure Instruction, EDPI 4.25.1, Section 6.1 requires that, "each originating design group shall maintain a log of all documents which are routed to personnel external to the design group. These logs shall be retained...
providing visibility of the projects design interface control."
It was determined bzsed on a review of specification C-208, Revision 20, Materials Testing Services, Section 9, Soils Testing and C-211, Revision 12, Technical Specification for Backfill, that the civil project engineering group is not matotaining a complete coordination log of specifications and ipecification change notices.
Interviews with cognizant Bechtel personnel indicated that it is up to the originator of the document to transmit the design docu-ment to the coordinator clerk to log it in as being interfaced
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with the appropriate groups.
It was determined from reviewing the interface log that the originator of the documents are not aware of this requirement and documents are not being interfaced with other design groups as required by the procedure.
In addition, Regulatory Guide 1.64, Quality Assurance Requirements for the Design of Nuclear Power Plants and ANSI N.45.2.11-1974, Section 10 requires design interface records to be maintained.
This failure to maintain design interface and coordinator control is considered contrary to 10 CFR 50, Appendix B, Criterion III as described in the Notice of Violation.
(50-329/80-32-02; 50-330/
80-33-02).
c.
Specification C-208, Revision 10, Section 9 regarding soil testing requirements was reviewed for technical content.
It was determined that the specification was not adequate as written.
The following specific findings were identified.
(1) CPCo was identified in Question 1, Appendix I, Page I-13, Paragraph A.4(a) that the subcontractors test procedures for soil testing service were inadequate; specifically, U. S. Testing procedures did not provide for developing and updating a family of proctor curves used to compare in-place field density tests to maximum laboratory standards. CPCo committed to the remedial action on Page I-17, Paragraph 4(a) l l
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which states, " Selection of proctor curves will no longer be a problem because each field density test will be accompanied j
by a separate laboratory standard compaction test which will provide a direct comparison." It was also stated that SCN-9004, j_
dated April 13, 1979 was issued to require the above.
It was determined,that SCN-9004 was issued as committed; e
however, during Revision 16, dated August 24, 1979, of specification C-208, the civil project engineer failed to p
include the above requirement _and instead revised Table 9-1 to permit the frequency of the laboratory test to be "as l
directed by the or.-site geotechnical engineer" rather than L
for each field density test.
1 j
This does not comply with the commitment made in 50.54(f) response to Question 1.
This occurred because adequate design interface l
controls had not been implemented as required by ANSI N 45.2.11.
There was no evidence that the geotechnical group had reviewed or f
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approved the revision to the specification.
This failure to provide adequate design ' interface control is 4
considered contrary to 10 CFR 50, Appendix B, Criterion III as described in the Notice of Violation.
(50-329/80-32-03; 50-330/-
80-33-03).
(2) Specification C-208, Section 9.1.1 should be reworded to j -(-
remove confusion which exists about the word " compaction".
This section should read: Modified proctor tests on cohesive
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i material shall be performed in accordance with ASTM D 1557, Method D.
i (3) Section 9.1.3 (first paragraph) does.not.specifically i,
indicate how ASTM D 1566 has been 'aodified by USBR DES E-24..
In addition, why does.the specification prohibit the use of the nuclear density device for measuring in-place field density? This device is an industry accepted method with a j'
standard ASTM designation.
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(4) Section 9.1.3 (second paragraph) assumes a' specific gravity.
of 2.75.
The actual specific gravity should be known and used as is the' industry practice.
(5) Section 9.1.3(c) should also include: - if the'results still
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plot to the right of the ZAV curve the' test should be rejected'and a new density test performed.
l (6) Section 9.1.3(d) uses the phrase 101% compaction. This should' read 101% of maximum proctor density. This section also permits.
the.on-site geotechnical engineer "to evaluate" the results of l
tests that exceed 101% proctor density for. cohesive material and
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105% for cohesionless material. This section should include O
the qualitative acceptance criteria and/or instructions to be used for the basis of.this evaluation.
The above items 3(c) 2, 3, 4, 5 and 6 are considered unresolved items pending a review of CPCo response to each item.
(50-329/
80-32-04; 50-330/80-33-04).
d.
Specification C-211,* Revision 12 regarding backfill work activities was reviewed for technical content.
It was determined that the specification was not adequate as written. The following specific items were identified.
(1) Section 8.1 does not specify the type of material to be used beneath Category I, safety related structures. This should be included in this. specification.
(2) Section 8.1.1 does not specify the type of material to be used around pipes and duct banks.
The specification should specify or refer to appropriate instructions.
(3) Section 8.3.2 (third paragraph) states, "the uncompacted lift thickness of the backfill material shall be determined by the on-site geotechnical soils engineer..." The on-site soils engineer should not have to determine the lift
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thickness when Attachment No. 1 to specification C-211 specifies the requirement for each type of equipment based on equipment qualification tests.
(4) Section 8.5.2 permits the use of rubber-tired rollers to compact structural backfill and sand. Attachment No I to specification C-211 does not indicate rubber-tir'ed rollers as having been qualified and rubber-tired rollers should not be used to compact structural backfill and sand.
The above items 3(d) 1, 2, 3 and 4 are considered unresolved items pending a review of CPCo response to each ites.
(50-329/80-32-05; 50-330/80-33-05).
4.
Review of Question 1, Part (b) and Question 23, Part (2)
The provisions and the procedures to be implemented to preclude conflicts between PSAR, FSAR and design documents was discussed in response to Question 1, Part (b) and Question 23, Part (2). Consumers Power Company included in their response a procedure entitled, "FSAR Rereview Procedure" to be implemented to accomplish this commitment.
Action items 23-1, 23-44 and 23-44(a) as identified'in Attachment No. 1 provided the commitments.to be; implemented to' assure FSAR accuracy. The following are the NRC findings regarding the implementation of these-commitments.
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It was detemined that, in general, consultant reports were not attached to the FSAR. However, the complete text of a consultant report prepared s
by Weston Geophysical Engineering Company was found as an attachment to the FSAR and included in the FSAR, as Appendix 2C.
Therefore, the CPCo response which states, " Consultant reports were not attached to the FSAR, but portions of consultant reports were extracted and incorporated into the FSAR text itself" (re: Question 23, Page 23-7) is not correct.
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CPCo also stated that the FSAR was rereviewed against design documents such as consultant reports for conflicts.
It was determined that verification of portions of consultant reports incorporated into the FSAR have been adequately reflected in design documents has not been satisfactorily accomplished. FSAR Rereview Pro-cedure, Revision 1, dated March 13, 1980, Subsection 2.1.3 states that each FSAR section should be carefully reviewed against design documents
.. as a minimum, the following should be checked... references at the end of the FSAR chapter. The procedure also requires in Item 8 that engineering design documents against which the FSAR review package is to be reviewed are to be listed by the primary review engineer in Block 8 of the FSAR rereview form. A review of FSAR packages Nos. 9474, 9473, 9472, 9471, 9096, 9097 and 9098 indicates that no design documents other than a.few drawings were identified and listed.
Numerous reports were referenced throughout the FSAR text of these sections, however, they were not recorded as required in Block 8 as being reviewed for consistency with the FSAR text.
An interview with a Bechtel cognizant primary review engineer indi-cated that he physically checked the references to make sure that they agreed with the FSAR text. Subsequently, after the NRC inspector found an apparent discrepancy between the FSAR-text and one of the references,-
+
the Bechtel reviewer indicated that he did not check the text of the references, but merely checked the reference for consistency of subject
- matter, i.e., title vs. sentence content not technical substance vs.-
FSAR statements. Another cognizant Bechtel primary review engineer indicated he could not check references'in his section because he was not qualified to review the technical matter in this area. He indicated that he relied on the Bechtel Geotech group (the interface reviewer in Block 11) to verify the references. Discussions with a Geiotech reviewer indicated he did check reports for consistency with the FSAR, but did not list them in Block 8 as required.
After this was determined, the inspector was informed that a CPCo l
interim audit No. M-01-53-0, dated March-1980, identified the same problem concerning the lack of identifying design documents'in Block 8.of the FSAR review form. At this time approximat'ely 600 of a total of 900 FSAR rereview packages had been' completed. However, no corrective' action was taken. CPCo final audit of this activity, audit No. M-03-202-0, dated November 1980, once again identified an unresolved ites, URI-3, regarding this same problem. The FSAR rereview is now complete and the unresolved ~iten was pending resolution as of:
the date of this inspection.,
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Cognizant individuals indicated that one of the reasons why documents were not listed in Block 8 was because there was not sufficient space.
An interview with the preparer of the FSAR rereview document indicated that the intent of Block 8, and it's instructions, was to list all of the design documents to which the FSAR section was reviewed against in order to assure there were no more conflicts between design documents and the FSAR text.
Based on the above, it was determined the CPCo failed to provide
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adequate corrective action with regard to the identified audit results.
This is considered contrary to 10 CFR 50, Appendix B, Criterion XVI, as described in the Notice of Violation.
(50-329/80-32-06; 50-330/80-33-06).
Due to this finding, CPCo implementation of the specific ccamitment as discussed in response to Question 23, Part (2) has not been accom-plished and the adequacy of the FSAR rereview which has been completed is questionable.
5.
Review of Question 1, Part (c) and Question 23, Part (3)
CPCo and Bechtel have performed a detailed re-review of specifications, installations, and construction inspection plans, procurement documents, inspection and test procedures, including the results of inspections and tests to determine the completeness and accuracy of documents and the acceptability of hardware.
In this regard, the IE inspection activities involved a review and evaluation of activities associated
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with the above re-review actions and included discussions with main participants in the re-review effort. The following is a summary of this inspection.
a.
CPCo and Bechtel were able to demonstrate that an extensive re-review of specification, inspections and test procedures, and documents associated with procurements were conducted with mean-ingful results. The documents were evaluated by CPCo and Bechtel to assure that the necessary tolerance call outs and quality requirements were specified; that the qualification requirements were adequately called out and met; that there were sufficient specificity provided in the documents; and that there were the necessary inspection requirements specified.
In addition, the completed documentation was evaluated to determine that technical and quality requirements were met in an acceptable manner.
Areas that were found deficient resulted in revision and improve-ment to procedural controls and specifications. Hardware suspected of not meeting quality requirements were re-evaluated by engineering 4
and quality assurance to determine their accept, repair, or reject status.
Throughout this particular IE inspection effort, specifications, procedures, and instructions were reviewed and a determination made that revisions and improvements were accomplished.
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The improved trend analysis and corrective action prograu estab-lished by CPCo and Bechtel was evaluated and found acceptable.
It is expected that this program will prove effective in detecting major weaknesses in the early stages such that meaningful, prompt corrective actions can be initiated during the design and construction phase.
c.
The " flag program," which-provides assurance that problems, simila -
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to those experienced with reactor vessels holddown anchor bolts, do not exist in other similar procurement actions where in process source inspection activities are involved, was evaluated.
Purchase orders and receiving documentation were reviewed by Bechtel to determine that critical design.and specification requirements were properly carried out and where questions were raised concerning product function, a " flag" was identified to the concern requiring further evaluation, discussions, and resolution by engineering and quality assurance. Evidence showed this activity to be productive and in accordance with documented instructions.
d.
The 1978 and 1980 independent audit results performed by the Management Analysis Corporation on CPCo and Bechtel were evaluated and found in accordance with program requirements.
Overall, the personnel contacted conveyed their QA knowledge and their sincerity and dedication towards performing the activities described above. However, as a result of the findings identified I
during this inspection, it is clear that more emphasis must be placed on the attention to detail in the preparation and review of documents.
In order to accompl'ish this, upper management must play a more active role in conveying this principle to the working staff and observing attitudes and activities to assure QA principles and attention to detail are being properly carried out.
Unresolved Item Unresolved items disclosed during the inspection are discussed in Para-graph 3(c) and 3(d) of the report.
Exit Meeting The inspector met with licensee and contractor representatives at the conclusion of the inspection on December 11, 1980 and summarized the inspection scope and findings. The items of noncompliance identified during the inspection were discussed in detail. The licensee acknowl-edged the inspection results.
Attachment:
Attachment No. 1
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7, ATTACHMENT h
.t 1 1/5 ACTION ITCMS i
PROGRAMMATIC AND GENERIC CORRECTIVE ACTIONS COMMITTED TO IN Tile RESPONSE 'ID QUESTION 1, PART (a)
AND IN Ti!E !!ESPONSE TO QUESTION 23, PAllTS (1) AND (2)
' Action Action Item Item Description Actions Verified Number and Reference (Status) liuring NRC Inspection 23-1 Consultant reports other than Dames & Moore were considered in accordance with the guidelines provided in NRC Hegulatory Guide -1. 70, Itevision 2.
Consultant reports were not attached to the PSAlt, but portions of consultant reports were extracted and incorporated into the FSA't text itself.
Those portions incorporated into the PSAlt become commitments.. Therefore, disposition of recommendations in consulting reports has been adequately accounted for in the prepara-tion of the PSAR.
Verification that those portions of consultant (Open)
Refer to Action Item 44 for Review of reports determined to be commitments and incor-FSAR Re-review porated'into the PSAR have been adequately reflected in project design documents' is being.
accomplished via the-PSAll rereview program
, described in the response to Question 23, Part (2).
23-1(a)
The two Bechtel OA audit findings reported in (closed)
Reviewed quality assurance audit 4.0-cnd our April 24,-1979, response-(Paragraph D.1, special 1. "SAR change control", & audit findings
~ - Il Page I-8) have been closed out.
The results A-34 & A-35.
The audit was performed to assure of this audit are being utilized in the PSAR that there is a system to assure design changes
, control system study committed to in Subsection are reflected in the FSAR. Audit findings ident-3.3 of this' response to Part (1).
ified casen where design changes were not reflected in the FSAR. Corrective action resulted in a
'(Ouestion 1, Appendix I,
Section D.1, Page I-8 review of all design requirement verification Question 23, Subsection 3.1, Page 7) checklists (DRVCL's) for groups identified with problems. This review is documented in QE monitoring report DRVC-8.
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1/5/d1 Acticn-Action Item Item Description Number and lleference
- l (Status) 23-2 On April 3, 1979, Midland Project Engineering (Closed) Reviewed & verified memos & Ictters Group Supervisors in all disciplines were instructing proj. engr. field eng, & QC of pro-reinstructed that the only procedurally cedure for implementing clarification or change correct methods of implementing specification to approved drawings or specifications:
changes are through the use of specification (1) Bechtel memo to QCE's, dtd 5/30/79.
revisions or Specification Change Notices.
This (2) Bechtel memo to Field Engr's, dtd 3/28/79.
was followed by an interof fice memorandum from (3) CPCo letter to Bechtel, dtd 3/12/79.
.the Project Engineer to all Engineering Croup (4) Bechtel memo to Proj. Engr, dtd 3/21/79.
Supervisors on April 12,-1979.
(5) Bechtel memo to Group Suprv, dtd 3/12/79.
(6) Bechtel letter' to CPCo, dtd 6/5/79.
(Question 23, Subsection 3.2, Page 8; and Subsection 3.9, Page 24) 23-3
~ Engineering Department Project Instruction (Closed) Reviewed & verified EDPI 4.49.1, Rev. 4, cxd 4.49.1 was revised in Revision 2 to state,
" specification change notice'to include require.
1 - 12 "Under no circumstances will interoffice.
ment that IOM's, memo's, telex's, TWS's, etc. can memoranda, memoranda, telexes, 'IWXs, etc not be used to change spec. requirements. A spec.
be used to change the requirements of a change notice must be issued in order to change specification."
spec. requirements.
(Question 1, Appendix I, Section 0.2.d, Page I-8 Question 23, subsection 3.2, Page 9, and Subsection 3.9, Page 24)
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Action Action Item Item Description Number and Reference (Status) 23-4 A review of interoffice memoranda, memo ra nda,
telexes, 1HXs, and other correspondence relating to speci fica tions for cons truction and selected procurements of 0-listed items will be initiated.
The purpose-of' the review will be 'to identify any clarifications which might reasonably have been interpreted as modifying a specification requirement and for which the specification itself was not formally changed.
An evaluation will be made to determine the effect on the technical acceptability, saf ety implica tions
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i of the potential specifica tion modifica tion, and any work that has been or may be affected.
If.it is-determined that the interpretation may have affected any completed work or future work, a formal change will be issued and remedial action necessary for product quality will be taken in accordance with approved procedures.
The foregoing procedure will be fol1Nwed for all (closed)
Verifled Bechtel memo dated 12/20/79 speci fica tions applying ' to construction of (File 0455) which.provides the procedure for 0-Listed items.
review of all (100%) Q-listed construction type spec's, and sampling plan procedure for procurement For specifica tions concerning the procurement type spec's.
of O-Listed items, the foregoing procedure will be implemented on a random sampling basis.
The sample size has been established and the speci fica tion selection has been made.
(21)'
Review'and acceptance criteria for the specifi-(Open)
Review criteria has been established (see cations have been defined, above action item 4); acceptance criteria was not defined. Audit report H01-200-0 also identified (47)
The review-of construction and selected this as an unresolved item.
procurement specifications is' scheduled to be completed by April 1,
1981.
(Open)
File had no review data for construction type or procurement type spec's.
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Acti:n Action Item
./81 It a Description Number and Reference (Status)
(47)
If the acceptance criteria are not met, the (open) Preliminary indication per Bechtel (c nt'd) review will be expanded to include other Representative indicated that the review will specifica tions for 0-lis ted items.
At that be required to be expanded to include other time, a revised completion date will be spec's than sampling plan identified, established.
(Question 23, subsection 3.2, Page 9, and Subsection 3.9, Page 25) 23-5 A study was completed which examined current (23-38) procedures and practices for the preparation and control of the PSAR in view of these experiences.
Procedural changes have been initiated by the revision of or addition to the Engineering Department Procedures.
i (Ouestion' 23, Subsection 3.3, Page 11) 23-6 An 'interof fice memorandum da ted April 12, 1979, (Closed) Reviewed & verified inter-office memo was issued by Geotechnical Services to alert from S. Blue to Ceotech personnel, dated 4/12/79 personnel of the need to revise or annotate which requires that changes in design be reflected calculations to reflect current design status.
in the original calculations & to reflect proper interdepartmental coordination has been achieved.
(Question 23,-Subsection 3.4, Page 13) 5 23-7 rield Instruction FIC 1.100, "0-Listed Soils (Closed)
Reviewed-6 verified, field instruction Placement Job Responsibilities Ma trix," has been FIC1.100, Rev. 3, dated 8/15/80 to include daily prepared and establishes responsibilities for
. job responsibilities of the onsite geotechnical performing soils placement and compaction.
engineer.
(Ouestion 23, subsection 3.6, Page 18; Subsection 3.7, Page 20; and Subsection 3.11, Page 30) e
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Action Action Item Item Description humber and Reference (Status) e 23-7A Review Pield Procedure FPG-3.000 to ensure (closed)
Verified that FPC-3,000, Rev. O," Job cnd clarity and completeness responsibilities for field engineers'was reviewed 1 - 17,
as a result of this review FIC 1.100," lob responsi '
(Question 1, Appendix I, Section 0.2, Page I-ll) bilities for the onsite geotechnical engineer"was established.
23-8 Construction specifications, instructions, and and procedures were reviewed to identify any other (open) cPco commitment.not completed.
1 - 16 equipment requiring qualification which had not yet been qualified.
No such equipment was identified.
(Question 1, Appendix I, Section D.1, Page I-ll-Question 23, subsection 3.6, Page 18)
I 23-9 A dimensional tolerance study was completed (Closed) Verified that dimensional tolerance using the reactor building spray pump and study was performed on the reactor building spray ancillary system as the study mechanism.
pump system.
(Ouestion 1, Appendix I, Section D.2.b, Page I-8 )
(cinsed) verified that a review of spec's A-17, 23-10 Engineering reviewed specifications not previously and
- reviewed for the specificity or tolerance studies.
C-67, H-342, c-208, c-231 & A-41 was performed 1-5 for specificity & tolerances.
Revisions were (Question 1, Appendix I, Section D. 2.c, Page I-8 )
made to spec. as needed.
fCinsed)
Verified a review of FSAR & Spec (
23-11 A specific review of the PSAR and specification requirements for the qualification of electrical requirements for qualification of electrical and mechanical components has been made as part and mcch nical components has been performed of the corrective action relating to CPCo's
& documented in CPCO letter to NRC, Region III dated December 5, 1980, as required by 50.55(e) 50.55(e) report on component qualification.
reporting requirements.
.(Ouestion 1, Appendix I, Section D.2.e, Page I-8)
(open)
CPCo commitment not completed, 23-12 Ouality Assurance will schedule yearly audits of the design calculational process for techniques and actual analysis in each of the design disci-plines.
(Question.', Appendix I,
Section D.4, Page I-8 )
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1/5/81 LAction' Action Item Item Description Number.
and Reference (Status)
- 13 Audits of ITT Grinnell hanger design and CPCo (Closed) verified that audit-0T-ITT crinnel relay setting calculation have been conducted.
(April 5, 1979) and audit of electrical and I&C
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(Question 1,, Appendin I, Section D.4, -Page I-8) 23-14 Bechtel Project: Engineering will. review -design (closed) Reviewed file No. 54601-54618 and
. drawings for cases where ducts. penetrate (calc #41-1) dated 9/5/78 which identifies each-
"1 - 10 vertically through foundations.
The possibility duct bank in the plant and interface with any
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of - the duct. being enlarged ' over the design buildings. -Results of study were documented in requirements,and the effect this ' enlargement memo from L. Curtis to R. Rixford dated 5/27/80 may have upon the structure's behavior will be which' indicates no other safety-related structure
~ evaluated by June-1, 1979. -Proper remedial except D. G. Bldg was effected by an interface measures will be taken =if the' investigation with duct banks.
Provisions were made to. allow shows potentialcproblems.
Independent vertical movement between the diesel generator bldg and duct banks.
(Question 1,. Appendix I, Section C.5.b, Page I-7) 23-15 An in-depth audit of U.S. Testing operations, (closed) Reviewed and verified audit 25-2-7 of
,and-
-covering testing and implementation of their U.S. Testing Company was performed on April 25-26, 1 - 20 QA program will be. conducted in late. April or 1979.
early Hay 1979, by - Dechtel Project QA and Engineering.-
'(Question.1, Appendix I,' Section C.4.b, Page I-18; Section D.3.c,-Page I-18) 23-16.
.An:in-depth training session'will' be given to (open) See review of Action Item 23-17 i
and Midland OA Engineers covering the settlement i
1 - 25
- problem and methods to identify similar conditions 'in the future.
(Ouestion 1, - Appendix 'I, Section D.l.b, Page I-22) l F
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'e Actlon I tem Item Description-N_u,ber and Itc l e re nce (Status) m s,
J3-l~L An in-depth training session will be given to (Open) Reviewed IOM dated July 27, 1979 and
-and,
all CPC74and Bechtel OA Engineers and Auditors June 4, 1979 documenting training to CPCo and to incressa their awareness of the settlement Bechtel QA personnel on Midland. plant fill
_ n i - 25' ' problem 'andJ to.,di.scuss audi ting and moni toring experiences. The file.does not contain docu-4.[( q techniques to increase audit et f ectiveness.
mentation of the contents or detail of the training nor any material handed out to parti-(Question 1, Appendix I, Section D.2, Page I-22) cipants for their future reference.
23-18 An in-depth review of the Bechtel trend (open) CPCo comm'itsent not con.pleted, and program data will be' undertaken by Ucchtel OA p
1 g 24 management to ensurez the identification of d
l-any other similar areas that were not analyzed in sufficient depth.in the past reviews.
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-(Question 1, Appendix I, Section D.l.a, Page I-22)
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pq 23-195 Quality Control Ins'tructions have been evaluated (Closed) verified the QCI's were reviewed _and and sto ensure'that the ' documentation characteristics items requiring further action and resolution s
1 N-21 which are to be inspected (i.e.,
survcillance and identified (Sce Action Item 23-19A).
' ~C 1 ' 22-review callouts) are clearly',specified.
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23-l'la '- (This: action modified to Include necessary revi-(Open) Completion of required changes to QCI's 3
and s; ytontto OCIs resulting fr.om evaluation of, surveil-per Action item 23-19 have not been completed.
1 - 21A la tfce nd Jevicw callouts.)
(Ouestioni, Appendix I, Section D.3.'a, Page I-la-and Se,ct ion D.1, Page I-18)
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Field Ins truction 1.100 has been supplemented (open)' CPCo commitment not completed. Records (b
by establishing requirements for demonstrating identifying equip. capability not documented in q
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' Action Item file.
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for equipment approval, and providing records
-identifying this capability.
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- y l(Question 23,' Subsection 3.6,_Page 18) 23-21 See, Action Item Number 4 (21)
_ Action Item 4 for review).
(Open) Acceptance criteria not defined (See
anuus s ur 1/5/81 Action Action Item Item Description
- Number and Reference (Status)
- 2 2 Guidelines for surveillance of testing operations (Closed) Responsibilities for on-site have been developed and included in Field In-Geotechnical Engineer have been established per structions for the onsite Soils Engineer.
FIC 1.100, Rev. 3 which include requirements.
Engineering /Geotechnical Services has developed the guidelines.
(Question 23, Subsection 3.10, Page 27) 23-23.
Engineering has revised Engineering Depart-(Closed) Verified.EDP 4.22 has been revised by cnd ment Procedure 4.22 to clarify that Engineering issuance of MED 4.22 Rev. 6 to include Regulatory 1-3' personnel preparing the FSAll will follow the Guide 1.70 which requires consultant reports to requirements of Regulatory Guide 1.70, Revision 2, be referred with specific commitments included in
" Standard Format and Content of Safety Analysis text of the FSAR.
Reports for Nuclear Power Plants" (September 1975).
Specifically, negulatory Guide 1.70 (Pages iv and v of the Introduction) requires that such consul-tant reports only be referenced with.the applicable commitments and supporting informa-tion included in the test (third paragraph, Page v).
Such a requirement precludes repetition of this circumstance. -
(Question 23, subsection 3.1, Page 7 and Subsection 3.3d, Page 46) tt 23-24 To preclude any future. inconsistencies between (Closed) Verified EDP 4.1.1, Rev. 2, Preparation the FSAR and specifications, Engineering Depart-of the design requirement verification checklist','
ment Proj.ect Instruction 4.1.1 has been revised Para. 3.1 requires the discipline engineer who to' state that.all specification changes, rather originates a design change document to fill out than just. " major changes," will be reviewed for a DRVC as the change is developed. The DRVC consistency with the PSAit.
include verification of consistency with the FSAR for design changes.
(Ouestion 23, subsection 3.3, Page 11) t 9
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'l 1/5/81 Action Action Item Item Desc ription Fumber and Reference (Status) 23-25 Quality Assurance has issued a Nuclear Quality (Closed) Quality Assurance policy.Section II, Assurance Manual amendment to clarify the No. 2,"acsign control procedures 7 Para. 3.1.4, requirement that' procedures include measures for Rev. 2B states, engin*c'ering department procedure qualifying equipment under specified conditions.
shall include criteria for specifying equip.
qualification requirements.
Also construction (Question 23, Subsection 3.6, Page 18) quality program,Section IV, No.
1, Rev. 2B Para. 3.2.3(P) requires instructions for quali-23-26 In view of Action Item 6, Geotechnical Services fications of equip.
has revised Procedure FP-6437 to require that calculations be annotated to reflect current (Closed) Reviewed and verified procedure design status.
FP-6437-A2 was issued (See ref. letter from (Question 23, subsection 3.4; Page 13)
S. Blue to R. RixfOrd dated 4/10/80).
23-27 Engineering Department Procedure 4.37 har, also (Closed) Verified procedure MED 4.37, Rev. 11, been revised to require that calculations be
= Design Calculation"and EDPI 4.25.1, Rev. 7, annotated to reflect current design status.
" Design Interf ace Control"was issued to require the (Question 23, Subsection 3.4, Page 13) originator of a design change to notify all groups which used the original design document and to 23-28.
Civil / Structural Design Criteria 72202C-501 check the latest design info prior to revising calculations.
has been modified to contain the requirements that a duct bank penetration shall be designed (Closed) Verified civil design criteria C-501, to eliminate the possibility of the nonspecific size-duct interacting with the structures.
Rev, 11, Para. 6.6 has been added which states,
,,All interfaces between b1dg's or foundations and (Question 23, Subsection 3.5, Page 15) duct banks designed after Jan.
1, 1980 shall be included on civil design drawings and shall indi-23-29 The civil standard detail drawings have been c te clearances or const. restrictions as required revised to include a detail showing horizontal to account for differential settlement, seismic and vertical clearance requi remen ts for duct m vement, etc.
bank penetrations.
The detail addresses any mud mat restrictions.
(Closed) Verifled civil standards and misc.
concrete details, sheet 2, dwg C-141, Rev. 6 (Ouestion 23, Subsection 3.5, Page 15) detail 12 provides duct bank clearance criteria.
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Action Action Item Item Description
.. Numbe r and Reference (Status) 23-30 Engineering clarified specifications and (closed) Verified spec C-211. Rev. 12, (39)
Construction prepared procedures (governing Para. 8.5.1 (compaction equipment) now requires the soils compaction equipment) to implement proposed compaction equipment to be qualified to the requirements of the Nuclear Quality Assurance demonstrate compaction can be achieved at a Manual as stated in Action Item 25.
specified lift thickness, number of passes, speed of equipment and frequency of vibration for (Ques tion 23, subsection 3.6, Page 18) vibrating equip.
23-31.
Design documents, instructions, and procedures (Open) CPCo commitment not completed.
for those activities requiring inprocess controls have been reviewed to assess the adequacy of existing i
procedural controls and technical direction.
Engineering review has been' comple ted.
(Question 1, Appendix I, Section D.2, Page I-ll; and Question 23, Subsection 3.7, Page 20; and Subsection 3.11, Page 30) 23-32 Guidelines for surveillance of testing operations (Closed) See Action Item 23-22.
have been developed and included in for the onsite Soils Engineer.('ield Instruc-tions Engineering /
Geotechnical Services has developed the guidelines and Field Engineering has prepared the instructions.
(Ques tion 23, Subsection 3.10, Page 27) 23-33 The ' Quality Assurance audit and monitoring program (open) CPCo commitment not completed, will be revised to emphasize and increase attention to the need for evaluating policy and procedural adequacy and assessment of product quality.
A specialized' audit training program will be developed and implemented to ensure guidance for this revised approach.
(Oues tion 23,. Subsection.3.13, Page 35) e
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Action Action Item Item Description Number and Reference (Status) 23-34 Control Document SP/ PSP G-6.1 has been revised (Closed) Verified Procedure C-6.1, Rev. 5 has J
and to provide requirements for inspection planning been revised to incluji,e requirements for planning, i
1 - 23 speci f.:.ci ty and for the utilization of scientific specificity (Para. 3.3.2) and utilization of sampling ra the r than pe rcentage sampling.
scientific sampling (Para. 3.3.3.a.8).
This deleted surveillance type inspection and now (Question 1, Appendix I,
Section D.5.f, Page I-20; andequires inspection by witness or test.
Ques tion 23, subsection 3.8, Page 22; Subsection 3.9, Page 24; Subsection 4.2.2, Page 59) a 23-35 Control Documents SP/ PSP G-3.2,
" Control of (Closed) Verified C-3'2, Rev. 6, Control of Nonconf o rming Items," and Nonconforming Items'and Q' PP C-101"QA Trend A
23-36 OADP C-101, " Project Quality Assurance Trend Analysis *have been modified to provide for and Analysis" have been revised to provide an identifying repetitive nonconforming conditions.
1 - 24 improved definition of implementing require-Interviewed Mr. T. K. Subramanian.
1 - 25 ments for identifying repetitive noncor %rming conditions.
(Ques tion 23, Subsection 3.12, Page 33) 1 23-37 Consistent with the intent of Action ' Item Numbers (0 pen) CPCo commitment not completed.
35 and 36, Quality Assurance will review noncon-formance reports which we re open as of November 13, 1979, or became open prior to implementation of the improved Project Quality Assurance Trend Analysis program as stated in Action Item 36.
This review will be to identi f y any repetitive nonconf o rming conditions pertatning to product type or activi ty, or pe rtaining to noncon f orma nce cause.
(Question 23, Subsection 3.12, Page 33)
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1/5/81 Action Action Item I tem Description Number and Reference (Status) 23-38 h study was comple ted which examined current (0 pen) See Action Item 23-5 (23-5) procedures and practices for the preparation and control of the PSAR in view of these experiences.
Procedural changes have been initiated by the revision of or addi tion to the Engineering Department Procedures.
(Ouestion 23, subsection 3.3, Page 11) 23-39 Engineering clarified specifica tions and (Closed) Verified FIC 1.100, Rev. 3 requires (30)
Construction prepared procedures (governing on-site geotechnical engineer to ensure compaction the soils compaction equipme.nt) to implement equipment is qualified andilisted in the spec and the requirements of the Nuclear Quali ty Assurance can deliver required degree of compaction.
Manual as stated in Action Item 25.
(Oues tion 23, Subsection 3.6, Page 18) 23-40 Design documents, ins truc t ions, and procedures (Open) CPCo commitment not completed.
for those activities requiring inprocess controls will be reviewed to assess the adequacy of existing procedural cont'rols and technical (31) direction.
Engineering, review has been com-oleted, and Field Engineering and quality control review is scheduled for completion by February 27, 1981.
(Ou.es tion 1, Appendix I, Section D.2, Page I-ll; Ouestion~23, subsection 3.7,.Page 20, and Subsection 3.11, Page 30) 9
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-Action Act ion I tem Item Description Number and Reference (Status) 23-41 OCIs in use will be reviewed to ascertain that (Open) CPCo commitment not completed.
provisions have been included consistent with the revised control document, SF/ PSP G-6.1, "Ouality Control Inspection Plans."
(Ouestion 1, Appendix I,
Section D.1, Page I-18; Ques tion 23, Subsection 3.8, Page 22; and i
Subsection 3.9, Page 24) 23-42 Design documents, instructions, and procedures (Open) CPCo commitment not completed.
for those activities requiring inprocess controls will be reviewed to assess the adequacy of 8
existing procedural controls.and technical (31) direction.
Engineering review has been completed, (40) and Field Engineering and quality control review is scheduled for comple tion by February 27, 1981.
Any revisions required will be completed by. April 17, 1981.
(Oues tion 1, Appendix I, Section D.2.,
Page I-ll; Oues tion 23, subsection 3.7, Page 20; and Subsection 3.11, Page 30) 23'-43 The impact of Action Item 41 on completed work (Open) CPCo commitment not completed.
will be evaluated, and appropriate actions will be taken as necessary.
(Oues tion 23, subsection 3.8, Page 22; and Subsection 3.9, Page 25) 23-44 FSAR sections have been rereviewed as discussed (Open) 9 re-review packages were reviewed
'in the Response to Question 23, Part (2).
by the NRC.
Not all of the design documents were 7
listed in Block 8 of required form per procedure (Oues tion 23, Subsection 3.1, Page 7; for performing review issued 3/13/80. This was Subsection 3.3, Page.11; identified as an item of noncompliance as dis-Subsection 3.2, Page 41; and Section 4.0, Page 47) cussed in Paragraph 4 of this report.
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Action Action Item Item Description Number and Reference 23 44A The audit committed to in our response to (Open)
(1) CPCo Audit not completed & (2)
Question 1, Part b, and described in Part (2),
Existing Audit findings (M01-53-0) not satis-Section 5.0 was conducted once during the factorily resolve; i.e.,
inadequate corrective course of the FSAR rereview (commencing March 17, action. This item has been identified as an 1980) and again after completion of the rereview item of noncompliance as discussed in para-(commen,cing November 3, 1980).
graph 4 of this report.
(Ouestion 23, Part (2),.Section 5.0, Page 48) i S
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1/5/8, Action
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Action Item Iten Description and Reference Number 23-45 '
U.S. Testing was required to demonstrate to (open) CPCo commitment not completed.
cognizant Engineering Representatives. that testing procedures, equipment, and personnel i
used for quality verification test ng (for other than NDE and soils) were capable of providing accurate test results in accordance with the requirements of applicable design documents.
(Ques tion 1, Appendix I, Section D.3.b, Page I-18;
- - Question 23, Subsection 3.10, Page 27; and f
Subsection 3.11, Page 31) 23,46 A sampling of U.S. Testing's test reports (for (0 pen) CPCo commitment not completed.
other than NDE and soils) were reviewed by coonizant Engineering Representatives to ascertain that results evidence confonnance to testing requirements and design document limits.
(Question 23, subsection 3.10, Page 28.; and Subsection 3.11, Page 31) 2347 See Action ' Item Number 4 (47)
(Open) CPCo commitment not completed.
23-48 CPCo performs overinspection for soils (Closed) Verified CPCo overinspection plan.
placement, utilizing a specific overinspection 01-C-3A, Rev. 1 for soil placement and reviewed
- plan, completed overinspection results performed on weekly basis.This overinspection program is an (Ques tion 1, Appendix I, Section C.2.b, Page I-ll; ongoing activity by Midland QA group.
Section C.l.c, Page I-16) 23-49 CPCo performs overinspection of the U.S.
(Closed) verified CPCo overinspection plan Testing soils testing activities and reports, 01-C-4A, Revision 3, for soil testing and utilizing a specific overinspection plan, review completed overinspections performed on U. S. Testing.
(Ques tion 1,. Appendix I, Section C.3.c, Page I-17)
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Sheet 16 of 2 1/5/81 Action Action Item Item Description Number and Reference 23-50 CPCo Project Management and OA review field (Closed) Verified CPCo reviews of field pro-procedures (new and revised) and CPCo OA reviews cedures and quality control instruction in OCIs (new and revised) in line with Dechtel before addition to Bechtel pr'ior to release, release.
(Question,1, Appendix I, Section D.5.b, Page I-19) 23-51
.In 1978, CPCo implemented an overinspection plan (Closed) Verified CPCo has overinspection plans struction and the Dechtel inspection process, in the civil, electrical, mechanical, and with the exception of civil activities.
Re-welding /NDE work activitics, inforcing steel and embeds were covered in the i
overinspection.
(Ouestion 1, Appendix I, Sectior$ D. 5.c, Page I-19) 23-52 CPCo reviews onsite subcontractor OA manuals (Closed) Verified CPCo reviews subcontractor and covers their work in the audit process.
QA manuals and audits subcontractor work.
(Question 1, Appendix I, Section D.S.d, Page I-19) 23 53 An ongoing ef fort is improving the " surveillance" (closed) Verified that SF/ PSP G-6.1, Rev. 5 mode called for in the OCIs by causing more
" procedure for quality Control inspection plans' specific accountability as to what character-have deleted surveillance method and new require-istics are inspected on what specific hardware ments direct inspection by witness or test to and in some cases changing " surveillance" to be performed by Quality Control surveillance
" inspection.a method has been deleted in para 3.3.3.a.3 of C-6.1, Rev. 5.
(Question 1, Appendix I, _Section D.S.e, Page I-19)
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1/5/81 Action Action Item Item Description Number and Reference (Status) 1-1 Perform a final review & update of PSAR commitment list.
(Open)
Action item not reviewed by NRC during the inspection.
1-2 Review sections of FSAR determined to be inactive.
(Open). See Action Item 23-44 for NRC review &
results.
1-3 Review EDP 4.22.
(closed) See Action Item 23-23 for NRC review.
1-4 Audit Action Items 1-3 (Open) See Action Item 23-44A for NRC review &
results.
1-5 Review specifications not included in specificity (Closed)
See Action Item 23-10 for NRC review study initially, and results.
i 1-6 Dames and Moore Report was reviewed and recommendations (Open)
File indicated review was complete, identified and dispositioned.
however, no details of the recommendations identified or the dispositions were available.
(Question 23, Subsection 3.1, Page 23-6)
(Question 1, Apx, I, Page 1-6, Para C.1.(b) 1-7 Complete review of pertinent portions of FSAR sections (Closed)
Verified FSAR, Revision 18 to have 2.5 and'3.8.
corrected:
(1) inconsistency between FSAR 3.8.5.5 and 2.5.4, Figure 2.5-48, settlement values, (2)
Inconsistencies between FSAR subection 2.5.4. and Table 2.5-9 and Table 2.5-14 regarding soil type 3.8.5 have been corrected via FSAR Amendment 18 supporting structures from clay to (Zone 2)
(Feb 28, 1979) the same revision also corrected ramdom fill, (3) Table 2.5-16, index of compressi-inconsistency between 2.5.4 and drawing C-45.
bility factors to be determined from fill studies.
(4) Table 2.5-21 compaction requirements.
'(Question 23, Subsection 3.3, Page 23-11)
Reviews of Section 2.5.4. are on "Ilold" until (Question 1 Apx I, Page I-6, Para 3) resolution of soils issue.NRC office of NRR Ceotechnical Branch will review FSAR section when final.
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,g Action Action Item Item Description Number and Reference 1-8 Correct Settlement Calculations (Closed)
Verified settlement calculations have been made subsequent to surcharge operations (RE:
Settlement calculations will be revised af ter calculation No. S-105 File 8230, dated February 14, completion of diesel generator building sur-1980), results of these calculations have been charge operations.
included in response to question 27 of 50.54(f) requests.
Review of this response and results (Question 23, Subsection 3.4, Para 23-13) of calculations are being made by NRC office of NRR Ceotechnical Branch.
(Question 1, Apx I, Page I-6, Para C.4.a) 1-9 Schedule audits of the Geotechnical Section on a six (Closed)
Review audits of Bechtel Ceotechnical month basis, dated February 26-28, 1979, and August 29-31, 1979, and February 26-28, 1980.
8 A recent Bechtel QA audit of Bechtel Ceotech Section was conducted in February 1979. Additional audits will Audits are scheduled for every six months.
be performed in this area on a six month cycle until completion of soil work.
(Question 1, Apx I, Page I-7, Para C.4.c) 1 - 10 Review drawings for possible effect of vertical duct (Closed) See Action Item 23-14 for NRC review.
bank restrictions.
1 - 'll Complete actions in response to DRUCL audit.
(Closed)
See Action Item 23-1 for NRC review.
1 - 12 Revise EDp 4-49 to incorporate clarifications and (Closed)
See Action Item 23-3 for NRC review.
instructors for use of specification change notices.
1 13 Schedule audits of each design discipline calculations (0 pen)
CPCo commitment not completed, on a yearly basis.
1 - 14 Re-evaluate construction equipment used for conpaction.
(Closed)
Verified 50.54(f) submittal, " Report on Test Fill program" which provides documentation for Compaction equipment currently in use has been qualified qualification of compaction equipment currently in and construction notified of parameters governing use of use, Spec. C-211, attachment 1, provides a list of equipment, co.ulpment to be used and compaction requirements.
(Question 23, Subsection 3.6., Page 23-18).
(Ques tion 1, Apx I, Page I-11, Para C.1)
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1/5/81 Action Action Item Item Description Number and Reference l'
15 Assign Field Soils Engineer and Soils Engineer from (Closed)
Verified Spec. C-211 Para 8.3.5. requires design section.
soil work to be performed under direction of.
qualified onsite soils engineer.
One full time and one part time onsite Geotechnical Soils Engineer has been assigned.
(Question 23, Subsection 3.7.,
Page 23-20)
(Question 1 Apx I, Page I-ll, Para C.2.a) 1 - 16 Review construction specifications and procedures to (Open)
See Action Item 23-8, CPCo Commitment identify equipment requiring qualifications.
not completed.
1 - 17 Review field procedure FPG-3.00 to ensure clarify and (closed) See Action Item 23-Ja for NRC review.
completeness, 1 - 18 PQCI'1.02 has been revised to incorporate the specific (Closed) Verified PQCI 1.02 (Rev. 5) has been characteristics to be verified by quality Control.
revised to include specific characteristics to be inspected.
(Question 23, Subsection 3.8, Page 23-22)
(Question 1, Apx I, Page I-16, Para C.l.a)
Project Quality Control Instructions C-1.02 was revised (Closed) Verified C-1.02, Rev. 5 requires compaction to include ve,'.fication of use of qualified equipment &
equipment to be qualified and will adequately com-compliance with qualified procedures, pact the material being placed and provides for a daily soil placement report.
(Question 23.. Subsection 3.6, Page 23-18)
-(Question 1 Apx I, Page I-16, Para C.I.a)
(Question 1, Apx I, Page'I-17, Para C.4.a)
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Sheet af 21 1/5/81 Action Action Item Item Description Number and Reference 1 - 18 PQCI 1.02 was revised to provide specific inspection (closed) Verified PQCI 1.02 (Rev. 5) Para 2.3 Cont' requirements for verifying soil moisture contents, has been revised to provide inspection of moisture rather than surveillance.
testing.
(Question 23 Subsection 3.9, Para 23-24) 1 - 19 Complete in depth review of soil test results (Closed) Reviewed and verified report entitled, Geotechnical Services has completed an investigation
" Review of U. S. Testing Field and Laboratory which includes an in depth review of testing performed Construction Test Data on Soil Uses as Fill",
by U. S. Testing and reported test results, dated July, 1979 was performed.
(Question 23, Subsection 3.10, Page 23-27) i (Question 1, Apx I, Page I-17, Para C.3.a)
An in depth soils investigation program provides verifi-(Closed) Verified that berings test pits, cation of the acceptability of the soils or identified laboratory tests, analysis of past test results any nonconformances requiring further remedial action.
and plots of all tes6 have been performed as part of the investigation of the subsurface materials.
(Question 23, Subsection 3.8, Page 23-23)
This informatio' has been submitted to the NRC and is currently under review by NRC office of NRR, (Question 1, Apx I, Page I-17, Para 3.a)
Geotechnical Branch.
1 - 20 Perform in depth audits of U. S. Testing.
(Closed) See Action Item 23-15 for NRC review.
1 - 21 Review of QCI's for surveillance call outs.
(Closed) See Action Item 23-19 for NRC review.
1 - 21 A Modify QCI's Based on Item 1-21.
(Oren)
CPCo commitment not completed.
1 - 22 Evaluate documentation call outs on QCI's (Closed) See Action Item 23-19 for NRC review.
1 - 23 Incorporate scientific sampling plans for (Closed! See Action Item 23-34 for NRC review.
inspection.
1 - 24 Complete in depth review of Bechtel trend program.
(Closed) See Action Items 23-35 and 23-36 for NRC review.
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1/5/81-s Action Action Item Item Description and Reference Number (Open) See Action Items 23-16 and 23-17 for NRC 1 - 25 Conduct QA Training.
review.
(Open) A review of this commitment resulted in (Uns;us.bered) Selection of protor curves will no longer be a problem an item of noncompliance as discussed in paragraph because each field density test will be accompanied by l
a separate laboratory standard which will provide a 3.(c) of this report.
direct comparison. This was directed by a letter to U. S. Testing and reflected in specification change notice j
C-208-9004, dated April 13, 1979.
l (Question 23, Subsection 3.10, Page 23-27)
(Question 1. Apx I, Page I-17, Para C.4a)
(Unnumbered)
Specifications wer-revised to provide more definition (Closed) Verified spec. C-211, Rev. 12. Para 8.4 (moisture control) has been revised to provide j
requirement for soil moisture testing.
specific requirements for moisture testing.
(Question 1. Apx I, Page I-16, Para C.2.a.)
Spec, C-210 and 211 were revised to incorporate inter-(0 pen)
Interpretations had not been identified or evidence of being incorporated into specifications.
I (Unausbered) pretations that affected specification requirements, (Question 23, Subsection 3.2., Page 23-8)
(Question 1. Apx I, Page I-6, Page C.I.a)
)
(Unnu bered)
The requirements for the control of testing were (Closed) Reviewed and verified Spec. C-208, Rev. 20 adjusted, requiring the testing subcontractor to 20, Para 9.1.3. to require all field devsity tests f
i check all field density tests for cohesive material to be checked to the zero-air volds curve.
against the zero-air-voids curve.
(
(question 23, Subsection 3 10, Page 23-27)
(
PQCI SC-1.05 was revised to add more. stringent require-(closed) Verified PQCI 1.05, Rev. 11 was revised (Unnumbered) ments for in process inspections of U. S. Testing.
to include requirements for inspecting in process testing activities.
(Question 23, Subsection 3.10, Page 23-27)
_